IC_2127-0019_CAFE_Supporting Statements_Fuel Economy Reports_(final)-08252018

Supporting Statement

for

49 CFR Part 537, Automotive Fuel Economy Reports

OMB Control Number: 2127-0019

1. Explain the circumstances that make the collection of information necessary. Attach a copy of the appropriate statute or regulation mandating or authorizing collection of information.

Congress established under the EPCA¹, and later amended by EISA², several reporting provisions for automobile manufacturers complying with corporate average fuel economy (CAFE) standards prescribed in 49 U.S.C. § 32902. The National Highway Traffic Safety Administration (NHTSA), on behalf of the Secretary of Transportation, interpreted those provisions and established several regulations defining the exact content of the reported information. The previous collection addressed reporting requirements specified by Congress under 49 U.S.C § 32907(a) and established by NHTSA in 49 CFR Part 537 “Automotive Fuel Economy Reports.” The reporting requirements in 49 CFR Part 537 obligate a manufacturer to submit reports to the Secretary of Transportation regarding whether the manufacturer will comply with an applicable CAFE standard for the model year for which the report is made; the actions a manufacturer has taken or intends to take to comply with the standard; and other information the Secretary requires by regulation. A manufacturer must submit a report containing the above information during the 30-day period before the beginning of each model year, and during the 30-day period beginning the 180^th day of the model year. When a manufacturer decides that actions reported are not sufficient to ensure compliance with that standard, the manufacturer must report additional actions it intends to take to comply with the standard and include a statement about whether those actions are sufficient to ensure compliance.

This current collection is issued to renew and modify the previous collection. The actions in this collection include:

1. A reinstatement of a previous collection for CAFE reports required by 49 U.S.C § 32907(a) and 49 CFR Part 537.

2. Added burden for other types of CAFE reporting requirements established by Congress and NHTSA in 49 CFR Parts 525, 534 and 536 which applies to manufacturers seeking exemptions, making changes in corporate relationships and managing CAFE credits.

3. Added burden for CAFE reporting included in the October 15, 2012, final rule (see 77 FR 62623) and the August 2, 2018, Notice of Proposed Rulemaking (see SAFE Vehicles NPRM at https://www.nhtsa.gov/corporate-average-fuel-economy/safe).

Renewal for CAFE Reports

NHTSA issued 49 CFR Part 537, “Automotive Fuel Economy Reports,” which specifies three types of CAFE reports for complying with 49 U.S.C. § 32907(a). The first report, the pre-model year (PMY) report, is required to be submitted to NHTSA before December 31^st of the calendar year prior to the corresponding model year, and contains a manufacturer’s projected information for that upcoming model year. The second report, the mid-model year (MMY) report, is required to be submitted by July 31^st of the given model year, and contains updated information from manufacturers based upon actual and projected information known midway through the model year. Finally, a supplementary report is required to be submitted anytime a manufacturer needs to correct information previously submitted to NHTSA.

Manufacturer reports include information on light-duty automobiles and medium-duty passenger vehicles for each model year, and describe projected and actual fuel economy standards, fuel economy performance values, production volumes and information on vehicle design features (e.g., engine displacement and transmission class) and other vehicle attribute characteristics (e.g., track width, wheel base and other off-road features for light trucks). Manufacturers submit both non-confidential and confidential versions of CAFE reports to NHTSA. Confidential reports differ by including estimated production sales information that is withheld from public disclosure to protect each manufacturer’s competitive sales strategies. NHTSA uses these reports for reference to help the agency anticipate potential compliance issues as early as possible, and help manufacturers plan compliance strategies. NHTSA also uses the reports for auditing and testing purposes, which helps manufacturers correct errors prior to the end of the model year, and facilitates acceptance of their final CAFE report by the Environmental Protection Agency (EPA).

Added Burden for Other Types of CAFE Reporting Requirements

NHTSA also seeks to add to this collection the CAFE reporting provisions in other CAFE regulations. To support these additions, NHTSA proposes to change the name of this collection to more accurately represent all CAFE reporting requirements. NHTSA includes the additional CAFE reporting requirements, as prescribed by Congress, in 49 CFR Parts 525, 534 and 536. In 49 CFR Part 525, small volume manufacturers submit petitions to NHTSA for exemption from an applicable average fuel economy standard and to request to comply with a less stringent alternative average fuel economy standard. In accordance with 49 CFR Part 534, manufacturers are required to submit information to NHTSA when making a corporate controlled relationship change (i.e., joining, splitting or acting to address liabilities or assets such as CAFE credits) with another manufacturer. A controlled relationship is a business relationship between manufacturers that control, are controlled by, or are under common control with one or more other manufacturers. Accordingly, manufacturers who have entered into written contracts transferring rights and responsibilities to other manufacturers in controlled relationships for CAFE purposes are required to provide reports to NHTSA. 49 CFR Part 536 prescribes reporting requirements for manufacturers to submit credit transaction instructions including credit allocation plans, trades, transfers, and carryback plans to NHTSA. A credit transaction instruction is a manufacturer’s written instruction (including credit values) to NHTSA to carry-forward, carry-back or trade CAFE credits within the manufacturer’s CAFE credit account(s). Credit instructions can be sent to NHTSA at any time throughout the model year but mainly manufacturers issue them along with a credit allocation plan. A credit allocation plan is a plan that must be sent to NHTSA describing a manufacturer approach to resolving a credit deficit resulting from the manufacturer’s fleet performance for a given compliance category falling below its required CAFE standard after the end of the model year. Credit allocation plans may also include traded credits or credit carryback plans as the approach for resolving an end-of-the year credit deficit. A credit trade includes trade documents from a credit seller obligating the exchange of earned credit from its credit account(s) to the credit account(s) of the buyer. A carryback plan is a plan, pursuant to 49 U.S.C. 32903(b), that validates a manufacturers capability to produce vehicles in future model years (up to 3 model years in advance of any given model year with a credit deficit) that will earn CAFE credits by over-complying and the manufacturers designation of those credits to be carrybacks to address the current model year’s credit deficit.

The list of all CAFE reporting requirements and regulations for automobile manufacturers is summarized below.

Table 1 – Required CAFE Reporting

Requirement	Application	Description of Required Reporting
§ 525.6 and 7	Petitions for an alternative CAFE standard	Petitions for small volume manufacturers seeking relief by complying with less stringent alternative CAFE standards.
§ 525.6 and 8	Federal Register Notice	NHTSA issues a Federal register notice upon approving or denying a petition for alternative standard.
§ 534.5(e) and 6 536.8(c)	Reports on corporate transactions	1. Manufacturers file reports when changes in control relationship occur affecting the allocation of credits or liabilities 2. Manufacturers file certified reports when one manufacturer has assumed a controlling stock ownership or control over the design, production or sale of vehicles of another manufacturer.
§ 536.5(c) and 8	Credit Trade Contract	A verified instruction to trade credits from an existing credit holder.
§ 536.5(d)	Credit Allocation Plan	If a manufacturer's vehicles in a particular compliance category have below standard fuel economy, upon notification from NHTSA, the manufacturer will be required submit a plan indicating how it will allocate existing credits or earn, transfer and/or acquire credits; or pay the appropriate civil penalty.
§ 536.5(e)	1. Manufacturers submit credit transactions to NHTSA and 2. NHTSA issues credit balance reports to the public and credit holders (i.e., manufacturers)	1. Manufacturers submit instructions to NHTSA to execute credit transactions using earned, expired, transferred, traded, carry-forward and carry-back credit transactions/allocations. 2. NHTSA periodically publishes the names and credit holdings of all credit holders and issues an annual credit status letter to each party that is a credit holder at that time.
§ 536.7	Credit Carry-back Plan	Manufacturers submit plans to carryback credits earned in a compliance category in any model year, pursuant to 49 U.S.C. 32903(b), for up to three model years prior to the year in which the credit was earned.
§ 536.8	Credit Cancellation Report	A credit holder may instruct NHTSA to cancel its currently held credits, specifying the originating manufacturer, vintage, and compliance category of the credits to be cancelled.
§ 537.5	PMY Reports MMY Reports Supplementary Reports	General reporting information for identifying the manufacturer and any confidential information.
§ 537.7(b)	PMY Reports MMY Reports	Projected required fuel economy
§ 537.7(c)(1) and (2)	PMY Reports MMY Reports	Combined fuel economy and projected sales information
§ 537.7(c)(3) and (4)	PMY Reports	Vehicle configuration design and attribute data (e.g., transmission and engine information).
§ 537.7(c)(5)	PMY Reports	Non-passenger vehicle (light truck) attribute data (e.g., 4WD and ground clearance measurements).
§ 537.7(c)(7)	PMY Reports	Any improved air-conditioning (AC), off-cycle and full-size pick-up truck technologies used each model year to calculate the average fuel economy specified in 40 CFR § 600.510-12(c).
§ 537.8	Supplementary Reports	Any corrections to information in any previously submitted reports.
§ 537.12	PMY Reports MMY Reports Supplementary Reports	Any confidential information

Added Burden for the October 2012 Final Rule

Beginning with model year 2017, manufacturers may also provide projected information in their CAFE reports on any air-conditioning (AC) systems with improved efficiency, off-cycle technologies (e.g., vehicle stop-start systems) and any hybrid/electric full-size pick-up truck technologies used each model year to calculate the average fuel economy specified in 40 CFR § 600.510-12(c) (see the October 15, 2012, final rule at 77 FR 62623). Manufacturers identify the makes and model types equipped with a “fuel consumption improvement” technology, which compliance category those vehicles belong to, the number of vehicles for each model equipped with the technology, the associated fuel consumption improvement value and the resulting adjust to the manufacturer’s fleet economy average performance.

Manufacturers using these fuel consumption improvement technologies derive the benefits from a predefined list established by EPA and NHTSA or by testing vehicle model types using the EPA’s 5-cycle test procedure. As an alternative, manufacturers can also petition the EPA and NHTSA, in accordance with 40 CFR 86.1868-12 or 40 CFR 86.1869-12, to gain additional credits based upon the improved performance of any of the fuel consumption improvement technologies allowed for model year 2017. EPA approves these petitions in collaboration with NHTSA and equivalent credits can be used for both the EPA and the NHTSA compliance programs. As a part of its consultation, NHTSA provides EPA with an evaluation of each new technology to ensure its direct impact on fuel economy and an assessment on the suitability of each technology for use in increasing a manufacturer’s fuel economy performance. Furthermore, at times, NHTSA may independently request additional information from a manufacturer to support its evaluations. Manufacturers provide this supplemental information to NHTSA to justify or explain the benefits of these technologies. This information along with any research conclusions shared with EPA and NHTSA in the petitions is required to be submitted in coordination with the manufacturer’s CAFE reports.

Added Burden for the August 2018 SAFE NPRM

With the intent of simplifying reporting for manufacturers, NHTSA issued the August 2018 NPRM proposing to adopt standardized templates for CAFE reports specified in 49 CFR Parts 536 and 49 CFR Part 537. The standardized templates reduce the amount of time manufactures spend (i.e., reduces the amount of information for many manufacturers and reduces errors in credit calculations) preparing reports, and the amount of time NHTSA spends auditing and analyzing the data, and executing credit transactions. The proposed reporting changes sought in the NPRM are summarized below:

• A standardized reporting template (NHTSA Form 1474) for CAFE PMY, MMY, and Supplementary reports required under 49 Parts 537.5 and 535.7. All CAFE reports are now proposed to include the same information via the template. The template also includes a standardized format for collecting information on air conditioning (AC) systems with improved efficiency, off-cycle technologies, and advanced full sized pickup truck features for calculating manufacturers’ improved fuel economy performance values in 49 CFR Part 537.7(c)(7).

• A standardized reporting template (NHTSA Form 1475) for manufacturers to report credit transactions in accordance with 49 CFR Parts 536.5(d) and 536.5(e). This template includes the adjustment factor calculator for preserving fuel savings and clarifies the level of precision for calculating credits. The template can also used for reporting credit trade documents in accordance with 49 CFR Part 536.5(c) and 536.8.

• To set CAFE standards as required by 49 U.S.C. 32902, NHTSA creates an analysis fleet from which to model potential future economy improvements. To compose this fleet, the agency uses a mixture of compliance data and information from other sources to best replicate the fleet from a recent model year. While refining the analysis fleet, NHTSA occasionally asks manufacturers for information that is similar to information submitted as part of EPA’s final model year report (e.g., final model year vehicle volumes). Periodically, NHTSA may ask manufacturers for more detailed information than what is required for compliance (e.g., what engines are shared across vehicle models). The more accurate the analysis fleet is, the more accurate the agencies’ modeling of what technologies could be applied will be. Therefore, NHTSA is accounting for the burden on manufacturers to provide the agency with this additional information. In almost all instances, manufacturers already have the information NHTSA seeks, but it might need to be reformatted or recompiled. Because of this, NHTSA believes the burden to provide this information will often be minimal.

• All standardized templates will be available for manufacturers from the NHTSA public information center (PIC) site at https://one.nhtsa.gov/cafe_pic/CAFE_PIC_Home.htm.

2. Indicate how, by whom, and for what purpose the information is used. Indicate actual use of Information received from the current collection.

• NHTSA collects, reviews, mantains and stores CAFE reports for accuracy and completeness and then conducts analysis on CAFE report data to analyze trends, respond to public inquires and selects vehicles for footprint testing per TP-537-02

• NHTSA responds to CAFE report confidentiality requests from automobile manufacturers

• NHTSA produces public reports on its Public Information Center (PIC) https://one.nhtsa.gov/cafe_pic/CAFE_PIC_Credit_LIVE.html using CAFE reports recieved from automobile manufacturers.

• NHTSA reviews, approves and audits information for improved AC, off-cycle and hyrid/electric full size pickups.

• NHTSA conducts analysis for determining future CAFE standards using CAFE reports recieved from automobile manufacturers.

• NHTSA reviews petition for alternative standards and issues a Federal register notice either approving or denying a small volume manufacturers proposed less stringent alternative CAFE standard.

• NHTSA reviews and provides a final determination on the status of corporate relationships and responds to corporate changes.

• NHTSA reviews trade documents for completeness and transfers traded credits from one manufacturer's credit account to another.

• NHTSA issues credit shortfall letters and after receiving a credit allocation plans executes the manufacturers credit transaction requests in its credit account to resolve its credit shortfall.

• NHTSA reviews credit transaction instructions and executes the manufacturers credit transaction requests in its credit accounts.

• NHTSA sends credit account balance letters to manufacturers.

• NHTSA makes a determination on the carry-back plan and issues a Federal register notice to inform the manufacturer and the public of its decision to approve/ deny and provides the public the opportunity to comment.

3. Describe whether the collection of information involves the use of technological

collection techniques or other forms of information technology.

49 CFR § 537.5(c)(4) specifies that confidential versions of CAFE reports are required to be submitted electronically on CD-ROM to the NHTSA Administrator and non-confidential reports sent by email to the NHTSA CAFE secure email account ([email protected]). The content of reports must be provided in a PDF or Microsoft Word format except for the information required in 49 CFR 537.7, which must be provided in a Microsoft Excel format.

The August 2018 NPRM proposes to adopt several new electronic reporting templates that manufacturers will use to modify their existing CAFE database systems or create new ones for preparing reports sent to NHTSA. NHTSA also plans to modify its existing CAFE database system to collect the information submitted by manufacturers and to improve the functionality of its analysis routines and other database functions that facilitate CAFE rulemaking and enforcement activities.

4. Describe efforts to identify duplication. Show specifically why similar information cannot be used.

To the extent practicable, NHTSA and EPA share data for the CAFE and GHG programs to avoid duplication. Some data required in CAFE reports are also collected by the Environmental Protection Agency (EPA), but the timeframe for the information required by NHTSA differ from the EPA due to statutory or regulatory requirements. For example, NHTSA CAFE reports are required to include fuel economy data based on information available prior to the model year, whereas EPA requires the same data, but at the end of a model year.

5. If the collection of information involves small business or other small entities, describe the methods used to minimize burden.

Any manufacturer that independently manufactures (whether in the customs territory of the United States) 10,000 or less passenger automobiles is eligible for an exemption for that affected model year from the average fuel economy standards in 49 CFR Parts 531 and 533 as well as excluded from providing CAFE PMY, MMY and Supplimentary reports covered by 49 CFR Part 537. NHTSA identifies these manufacturers as small business manufacturers. If the exemption is granted, these manufacturers comply with standards in accordance with 49 CFR Part 525, “Exemptions from Average Fuel Economy Standards,” and are excluded from reporting covered by this collection. NHTSA grants exemptions based upon a manufacturer’s legitimate inability to incorporate fuel saving technology capable of complying with conventional CAFE standards. To date, no requests from small business manufacturers producing less than 10,000 passenger automobiles have been denied.

6. Describe the consequences to the Federal program or policy activities if the information collection were conducted less frequently.

If the reports were required less frequently, NHTSA would not have current information to evaluate whether automotive manufacturers comply with the applicable fuel economy standards as required by statute. NHTSA would not have the necessary information to prepare its annual CAFE reports on the NHTSA website (available at https://one.nhtsa.gov/cafe_pic/CAFE_PIC_Home.htm). NHTSA could not effectively respond to inquiries received from Congress, other Federal agencies, and the public. NHTSA would not have sufficient information to evaluate possible future average fuel economy standards for passenger automobiles and light trucks, or to initiate other rulemaking activities. Manufacturers would also not be able to send instructions to adjust their credit account(s) within the allocated timing to final compliance for each model year. Finally, manufacturers submitting petitions for less stringent CAFE standards would have to comply with conventional CAFE standards imposing hardships upon these manufacturers.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR § 1320.6.

The procedures for reporting automotive fuel economy information are fully consistent with the guidelines set forth in 5 CFR § 1320.6.

8. Provide a copy of the FEDERAL REGISTER document soliciting comments on extending the collection of information, a summary of all public comments responding to the notice, a description of a description of the agency’s action in response to the comments. Describe efforts to consult with persons outside the agency to obtain their views.

The following document is included:

1. The August 2, 2018, NPRM (see DOT Docket NHTSA-2018-0067)

NHTSA will address any responses to the NPRM for changes to this collection and the templates as a part of publishing the final rule.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payment or gift will be provided to any respondent.

10. Provide any assurance of confidentiality provided to respondents.

NHTSA’s regulations in 49 CFR § 537.12 establishes the procedures by which the agency will consider claims that information submitted to the agency should be treated as confidential information. The regulation provides that if a respondent claims its reports contain confidential information, the agency will consider that claim under this section.

11. Provide additional justification for any question matters that are commonly considered private.

There are no questions of a sensitive nature.

12. Provide estimates of the hour burden of collection of information on the respondents.

The total number of burden hours associated with this collection is 3,774.5 hours. The hours pertain to automobile manufacturers providing CAFE information to NHTSA. A breakdown of the calculation for the hours is shown in Table 3 and explained in further detail in the following paragraphs:

Table 3 – Manufacturer Annual Burden Hours

An average of 23 automobile manufacturers submitted CAFE PMY and MMY reports over model years 2010 to 2015 for 49 CFR Part 537. Manufacturers use engineers, managers, legal, and clerical staff to prepare and submit CAFE reports to NHTSA. All manufacturers use electronic database systems to produce CAFE reports, and manufacturers can use those databases to export the compliance data required by Part 537. The burden hours associated with producing CAFE reports primarily involves engineers and managers reviewing the output of these database systems. Non-confidential versions of reports are emailed directly to NHTSA. Confidential versions are sent through each manufacturer’s legal department to add confidentiality requests before clerical staff compile all documents on CD-ROMs to send to the NHTSA Administrator. The NHTSA Administrator forwards the documents to NHTSA’s Chief Counsel’s Office for legal review and processing. As for supplementary reports, NHTSA receives on average three reports from manufacturers each year requesting to make corrections to previously submitted reports.

NHTSA estimates that manufacturers spend a total of 2,339.5 hours each year producing the required PMY and MMY CAFE reports. The total number of manufacturers who submitted reports decreased from the previous collection. Several smaller manufacturers who were in existence during the previous collection are no longer producing vehicles. Several manufacturers such as Porsche, Audi and Jaguar and Land Rover who were separate entities for compliance purpose at the time are now in controlled relationships with other manufacturers, who are now responsible for their reporting in accordance with Part 537.

Starting with the 2017 compliance model year, manufacturers will start incurring additional burden hours for incorporating information regarding off-cycle technologies, air conditioning technologies, and advanced technology that is applied to full sized pick-up trucks into PMY reports. Despite only eight manufacturers submitting information related to these incentives for model year 2017, NHTSA estimates that, in the next three years, all manufacturers will elect to report information on these incentives as part of their compliance strategies as stringency targets increase. It is estimated that an additional 161 annual hours will be needed for manufacturers to provide the information and to respond to any requests from NHTSA for additional information or data to justify the benefit of these technologies. NHTSA estimates that manufacturers spend a total of 2,500.5 hours each year in producing the required CAFE reports PMY and MMY with information on fuel consumption technologies.

For the 2019 compliance model year, NHTSA is proposing to simplify CAFE reporting submissions by introducing a standardized reporting template. The templates will reduce the amount reported information currently submitted by manufacturers. However, manufacturers will incur the initial burden to build IT resources to restructure their databases to conform to the format of the template. NHTSA anticipates that the added timing necessary for manufacturers to restructure their database systems in MY 2019 will be offset by the reduction in burden hours saved by using the templates. After that time, manufacturers will continue saving 138 hours annually by using the template resulting in manufacturers spending a total of 2362.5 hours each year in producing the required CAFE reports PMY and MMY with information on fuel consumption technologies.

Manufacturers may also be required to occasionally submit existing production information (e.g., what engines are shared across vehicle models) to NHTSA for its analysis in modeling potential future economy improvements and standards. The production information is similar to the information submitted as part of EPA’s final model year report (e.g., final model year vehicle volumes). NHTSA anticipates that each manufacturer may periodically spend 13 hours for each submission of information for NHTSA’s analysis which will result in a total burden of 299 annual for the automotive industry.

On average, three small volume manufacturers submit petitions for alternative standards to NHTSA seeking relief from complying with conventional CAFE standards. These small volume manufacturers primarily include exotic sports car manufacturers (i.e., Aston Martin and McLaren) and have submitted a total of 44 petitions covering 14 model years of production vehicles (MYs 2008-2021). The associated burden hours involve attorneys, engineers and managers collecting fuel economy performance and production information on their production vehicles and preparing petitions for submission to NHTSA. These professionals will spend approximately 89 hours to prepare each petition. As a result, the estimated total industry burden will be 267 annual hours for preparing and submitting CAFE petitions for alternative standards to NHTSA.

Very few manufacturers incur burden each year in submitting documents to NHTSA for corporate relationship changes. On average, only one manufacturer each model year submits documents to NHTSA for corporate relationship changes. The burden hours associated with this activity primarily involves attorneys preparing documents. Minimal amounts of burden hours are necessary for engineers and managers to review documents and clerical staff to submit them to NHTSA. The estimated total industry burden will be 19 annual hours for preparing and submitting information on corporate relationship changes to NHTSA.

Nearly half of all vehicle manufacturers will incur burden hours in managing their CAFE credit accounts each year. Credit management is a significant active for vehicle manufacturers who are addressing a current credit shortfall or are preparing to avoid one in the future. Manufacturers manage their credit accounts using engineers, managers and attorneys to prepare documents and then clerical staff to submit credit allocation plans, credit transaction instructions and trade documents to NHTSA. Manufacturers submit credit transaction instructions to NHTSA at various times throughout the model year when transferring credit trades from one manufacturer to another or when submitting a credit allocation plan to NHTSA because of a credit shortfall. On average, based upon compliance data for MYs 2011 to 2016, NHTSA receives 23 credit transaction instructions from vehicle manufacturers each model year. Of these instructions, 11 are a result of a credit shortfall and are included along with a credit allocation plan. Three of these cases also include a credit trade with accompanying credit trades documents. The remaining 12 credit transaction instructions are a result of credit trades processed throughout the model year and are included along with the manufacturers credit trade documents sent to NHTSA. NHTSA estimates each year that for all manufacturers credit instruction instructions will require an estimated 460 hours, credit allocation plan 319 hours and credit trade document 228 hours. NHTSA rarely receives carry back plans. Over the last ten years, NHTSA has only received plans from two manufacturers. NHTSA estimates (to be conservative) that on average 23 hours will incurred by any manufacturer preparing a credit carryback plans each year. Upon release of the NPRM, NHTSA proposes for manufacturers to start using the new credit template immediately. NHTSA anticipates that the new templates will drastically reduce the errors in credit calculations manufacturers continue to make. NHTSA anticipates a reduction of 207 hours for the industry to use the proposed template. Therefore, the net combined hours for the industry to manage their credit accounts will be 827 hours annually.

13. Provide estimates of the total annual cost to the respondents or record keepers.

The estimated total annual cost associated with CAFE reporting is $187,530.82. The cost is based upon the hours and current average labor rates for engineers, managers, attorneys and clerical staff to prepare and send CAFE information to NHTSA. Table 4 provides the breakdown of the associated costs based the upon average labor estimates from the Bureau of Labor Statistics in the May 2016 National Industry-Specific Occupational Employment and Wage Estimates (https://www.bls.gov/oes/current/oes_nat.htm, last modified March 31, 2017).

Table 4 – Manufacturer Annual Costs

* Based upon the labor hours in Table 2

** Based upon the number of manufacturers involved in each activity as described in Table 2

14. Provide estimates of annualized cost to the Federal Government.

The annual cost to the government to administer CAFE reporting is $141,246.78. The cost breakdown is shown in Table 5. Table 5 includes the labor costs and hours for NHTSA and explains each activity. The Government labor costs in Table 5 are based upon calendar year 2017 pay scales from the Office of Personal Management adjusted to the applicable rates for Washington, D.C. (see https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2017/DCB_h.pdf ).

Table 5 – Government Annual Burden Hours and Costs

15. Explain the reason for any program changes or adjustments reported in Item 13 or 14 of the OMB Form 83-I.

The current collection is a reinstatement of a previously approved collection. In comparison to prior collection, the total hours and cost for this collection after the 2019 compliance model year will be 3,774.5 hours and at a cost of $187,530.82 for manufacturers and 2,998 hours for the government at a cost of $141,246.78. This represents an increase from the previous collection by 585.50 hours and an increase in cost by $162,957.32 for manufacturers. While for the government, this collection has an increase of 2,063.00 hours and at a cost of $109,717.78 more. These costs are also adjusted based upon currently labor rates and corrected for the types of professions involved in each activity.

Table 6 provides the breakdown in hours and costs for the previous and current collections. The reasons for these increases (and decreases in some instances) are detailed as follows:

• The number and labor categories of manufacturer and government employees changed based upon current industry and government processes to produce and administer CAFE reports.

• Adjustments in the number of required employees were made without increases the previously reported labor hours for manufacturers or the governments. Changes were made to better explain the processes and employees involved with CAFE reports.

• The labor rates for manufacturers and the government were adjusted to reflect 2017 statistics.

• NHTSA is adding the burden hours and costs for manufacturers and the government for 49 CFR Part 525, 534 and 536 required by Congress and incorporated previously in NHTSA regulations but omitted in prior collections.

• NHTSA is adding the burden and costs from the October 2012 CAFE final rule.

• NHTSA is adding the burden and costs associated with the August 2, 2018, Notice of Proposed Rulemaking (see SAFE Vehicles NPRM at https://www.nhtsa.gov/corporate-average-fuel-economy/safe) and the information it collects to create an analysis fleet to model potential future economy improvements in setting CAFE standards.

Table 6 – Annual Burden Hours and Cost Differences

Applies to:	Manufacturer		Government
	Hours	Cost	Hours	Cost
Prior Collection	3,189.00	$24,573.50	975.00	$31,529.00
Current Collection	3,774.50	$187,530.82	3,038.00	$141,246.78
Difference	585.50	$162,957.32	2,063.00	$109,717.78

16. For collection of information whose results are planned to be published for statistical use.

This collection of information will not have results published for statistical use.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

Approval is not sought to not display the expiration date for OMB approval.

18. Explain each exception to the certification statement identified in Item 19. “Certification for Paperwork Reduction Act Submissions,” of OMB Form 8301.

No exceptions to the certification statement are made.

19. Collections of information employing statistical methods.

This collection of information does not employ statistical methonds.

1 Energy Policy and Conservation Act of 1975.

2 Energy Independence and Security Act of 2007.