Burden Tables

Copy of NRSI Worksheet Computations_05032021.xlsx

Certification and Compliance Requirements for Nonroad Spark-ignition Engines (Renewal)

Burden Tables

OMB: 2060-0338

Document [xlsx]
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Overview

Requirements for Cert and Comp
Sector Production
Total Respondent Burden Tally
All Certification and Reporting
Respondent Labor rates
Truncated Charts
IC Respondent Burden Tally
PLT
ABT
In-Use Test
SEA
EPA Burden
Regulatory Appendix


Sheet 1: Requirements for Cert and Comp

CERTIFICATION APPLICATION Include all information underThe standard setting part (typically section 205 in the applicable regulation). Additional information includes disclosing AECD and adjustable paramenters, explaining each in detail. Some manufacturers (Marine) must demonstrate that they also meet Not-to-exceed (NTE) standards within their certification testing. Other manufacturers (Large SI) must conduct an in-situ test as well as a certification test (sometimes also called an in-use test), where the engine is inserted into a piece of equipment and tested in application prior to certification and introduction into commerce (not to be confused in in-use compliance testing).

Amend Cert App

Prepare Maintenance instructions

Prepare label under the regulations



TESTING

Cert Testing Cert testing should include both certification test to meet standard and durability test for deterioration factor testing, generally at least half the useful life of the engine family. Generally, between 25% and 35% of manufacturers use data from previous certification years to certify for the current model year. This is a flexibility that reduces the amount of testing required annually for all manufacturers, provided no changes have occurred in the emissions characteristics of the engine family. However, the EPA may request new testing where information may seem old or out of date.
Production-Line Testing Many, but not all, manufacturers must also test a minimum number of production engines per quarter throughout the model year, run calculations, and report production-line testing (PLT) reports on a quarterly and final report basis.
In_Use Testing Some sectors within GECC must conduct in-use testing of engines in the field. These reports must be generated over a longer period of time (3-years, for example) to demonstrate continued compliance.
Selective Enforcement Audits The EPA may require a manufacturer to conduct a selective enforcement audit of their production of an engine family. Generally, up to 30-engines (or vehicles) must be selected at random and sequestered until the completion of this test audit.



REPORTING AND RECORDKEEPING

End-of-year All manufactures must submit a report representing their U.S. directed production for the previous model year for all engine families.
ABT Report As an alternative to traditional certification programs, some manufacturers may certify multiple engine families in an ABT (averaging, banking, and trading) group, which is averaged across all families and quantities, and certified to one standard. These reports must be verified at the end of the model year on the basis of actual sales.
PLT Reporting Along with the certification testing above, manufacturers subject to PLT testing must provide the EPA quarterly reports of their PLT testing progress and a final report 45-days after the end of the model year to demonstrate compliance with the finished products. This should not be confused with the end-of-year report required for all U.S. directed production, whether a PLT family or not.
Final and/or end-of-year report Not to be confused with the Production report, though one may serve as the other, all manufacturers must provide a final report on all sales activities after the end of the model year.
Maintenance of Records Several sections of the regulations, certification testing, PLT testing, In-use testing, engine family information, require manufacturers to maintain these records for a designated number of years following the end of the model year. The EPA may request this informaiton at any time, whether or not you previously disclosed this information to the Agency.

Sheet 2: Sector Production

Computation of all NRSI manufacturers and certificates issued (three-year period and average) MY 2017 MY 2018 MY 2019 MY 2020 Average Number of manufacturers and certificates Carryover families PLT ABT NRSI and Evaporative Certificates (Part 1060 only certifications) In-use New test Efs



Nonroad Spark Ignition Engines Small SI: Small nonroad gasoline powered equipment, such as lawnmowers, string trimmers, chain saws, small compressors, pumps, utility vehicles < 25 mph, snow blowers, rammers, floor cleaners Manufacturers 107 105 103 100 104
59 14 Non-handheld 182 349

4.96


Certificates 972 1006 1076 993 1012 728 567
Handheld 63 77
283 283.29


Marine SI: e.g. Gasoline boats and personal watercraft Manufacturers 23 22 19 (13) 21 (11) 21 21 9 7


7
461


Certificates 178 175 163 (27) 163 (59) 170 127 80
Vessel Cert 2 3 11 43 566.5


Large SI: Large nonroad gasoline powered equipment, such as forklifts, compressors, generators, and stationary equipment Manufacturers 37 36 35 36 36
21
Marine SI diurnal 20 32

672


Certificates 226 231 220 244 230 166 60
Large SI 0 0
64



Evaporative components (manufacturers certifying their own equipment under the standard setting part) Manufacturers 137 140 145 143 141 40 0









Certificates 396 416 415 408 409 294 0




114



Recreational Vehicles Recreational Vehicles (All-terrain vehicles / utility vehicles/Snowmobiles/Off-Highway mtorcycles) Manufacturers 109 111 100 107 107











0 6 2



0



0





0




Total Certificates 281 270 254 262 267 192 27




75



Heavy Duty Highway Vehicles/Evaporative components Manufacturers 15 14 13 10 13
0









Certificates 36 28 29 22 29 21 0




8



Evap Manufacturers 7 9 8 7 8
0









Evap Certificates 16 15 13 23 17 12 0




5



Total  Manufacturers



430
95 23 Total
112
592.64



Certificates



2133 1601 734 23













()=New certification Data

































GECC-related Defects/Recalls for 2019/2020






Small SI New
Carryover





Defect Reports
Recall Reports



MY (New) # of Mfr's # of EF's
MY (Carryover) # of Mfr's # of EF's




Industry 2019 2020 2019 2020


2010 1 1








Small SI engines 2 1 0 0


2011 71 300








Marine SI engines 10 0 0 0


2012 83 296








Large SI engines 1 1 2 0


2013 52 187








Evap Components/Equipment 1 1 1 0


2014 60 181








Highway Motorcycle 3 8 3 2


2015 54 169








Recreational - ATV 4 2 2 1


2016 55 186








Recreational - Offroad Motorcycle 0 0 0 0


2017 53 150








Recreational - Snowmobile 3 1 0 0


2018 53 207








Heavy-duty SI engines 3 7 1 3


2019 55 350 60
48 726 42



Heavy-duty Evap 0 1 0 0


2020 64 459 405
36 534 630



Total for all GECC Industries 27 22 9 6
Average Defect and Recall 2021 38 108








Total for Nonroad SI 24 14 6 4
19 5 Marine MY (New) # of Mfr's # of EF's
MY (Carryover) # of Mfr's # of EF's












2011 8 13








Total New NRSI Cert Testing (Mfr) 178





2012 14 26
















2013 13 44








In-House or Contractor Contractor
Own



2014 16 22








283 159 Small SI 125 42


2015 16 35








64 36 Large SI 28 4


2016 7 16








75 42 Rec Veh Test 33 30


2017 13 27








43 24 Marine SI Test 19 3


2018 8 26








8 4 Heavy Duty SI 4 4


2019 11 27 12
8 136 8



5 3 Heavy Duty Si Evap Components 2 2


2020 13 59 43
8 104 120



114 64 Components (per manufacturer) 50 39


2021 8 10








592.64 331
261 593

LSI MY # of Mfr's # of EF's
Carryover # Mfr # EF




In-House or Contractor Cert Contractor Cert
Own Cert



2011 7 10








283 159 Small SI 125 0 29

2012 9 28








64 36 Large SI 28 0 4

2013 12 26








75 42 Rec Veh Test 33 0 30

2014 15 41








43 24 Marine SI Test 19 0 3

2015 17 29








8 5 Heavy Duty SI 4 0 4

2016 16 31








5 3 Heavy Duty Si Evap Components 2 0 2

2017 15 36








114 64 Components (per manufacturer) 50 0 40

2018 8 23








Manf. Contractor Manf
Own Manf.



2019 14 21 14
21 199 22



29 16 Small SI 13



2020 13 31 26
23 213 206



10 6 Large SI 4



2021 11 16








30 17 Rec Veh Test 13


HDSI MY # of Mfr's # of EF's
Carryover # of Mfr's # of EF's




3 3 Marine SI Test 2



2015 1 2








4 2 Heavy Duty SI 2



2016 10 22








2 1 Heavy Duty Si Evap Components 1



2017 14 25








40 22 Components (per manufacturer) 17



2018 7 11
















2019 5 9 7
8 20 5











2020 8 11 10
2 11 16











2021 3 4















Rec Vehicle 2019

Total Carry Over

2019











Mfr EF Mfr's EF's Mfr EF Carryover Total Mfr EF








ATVA-Meet EPA & ARB ATV Definition
17 24 86 76 1 31 14 18 55 100 254







ATVB & UTV - EPA only
11 6

1 16 178 12 22








Utility Vehicle - EPA Only
12 8

-4 8
8 16








ATVB-Meeting EPA ATV Definition
18 12

8 62
26 74








All Terrain Vehicle
13 14

6 31
19 45








Off-Road Motorcycle
14 12

3 30
17 42








ATVB & ENGINE - EPA only
1 0

-1 0
0 0








Off-Road Utility Vehicle
0 0

0 0
0 0








Engine - EPA Only
0 0

0 0
0 0









2020




0
2020











Mfr EF




Mfr EF








ATVA-Meet EPA & ARB ATV Definition
8 14

9 45
17 59 107 262







ATVB & UTV - EPA only
10 3

1 20
11 23








Utility Vehicle - EPA Only
8 5

0 13
8 18








ATVB-Meeting EPA ATV Definition
22 18

6 58
28 76








All Terrain Vehicle
11 11

13 31
24 42








Off-Road Motorcycle
15 9

4 35
19 44








ATVB & ENGINE - EPA only
0 0

0 0
0 0








Off-Road Utility Vehicle
0 0

0 0
0 0








Engine - EPA Only
0 0

0 0
0 0


Sheet 3: Total Respondent Burden Tally

Each Sector should compile the below chart ofr the data submitted and the reporting required.











Table 7
Respondent Burden Tally

Program Number of Respond. [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: May not be necessary for our calculation Number of Activities/per Respondent Total Labor Hours Per Year Total Labor Cost Per Year Total Annual Capital Costs Total Annual O&M Costs Total Costs Total Responses
Certification Application and Testing 430 4.91 591,103 $52,822,946.64 - $26,947,438.89 $82,000,580 2,113.00
Totals:

591,103 $52,822,946.64 - $26,947,438.89 $82,000,580 -
Preparing and Submitting Annual Production Report 430 1 6,450 $631,721.60
$72,240.00 $703,962 430.00
PLT Reporting and Record Keeping 95 8 153,406 $13,606,855.30
$292,405.86 $15,866,075 734.00
ABT Reporting 23 1 1,495 $153,584.80
$3,864.00 $157,449 23.00
In-Use Testing and Reporting 7 2 2,154 $163,153.14
$21,545.69 $196,980 10.99
SEA Testing and Reporting 2 1 344 $31,333.02
$6,155.91 $37,489 2.00
[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Voluntary Emissions Recall Reporting Defect Reporting (EDIR) 19 1 266 $28,268.77
$3,192.00 $31,461 19.00
Recall Reporting (VERR) 5 4 480 $43,116.60
$840.00 $46,477 20.00
Final (Year-End and End-Of-Model Year) Reporting 430 1 3,440 $354,578.00
$72,240.00 $426,818 430.00 8
Reporting and Recordkeeping Totals 430
164,595 $14,658,033.23
$400,243.47 $17,039,892 1,668.99








5450.98








12.7



8


$99,040,472




(277,911)








8.00






Sheet 4: All Certification and Reporting













[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: We may not have calculated the number of applications that were carryover. recalculate...











Table 2 - Annual Respondent Burden and Cost for SI Engine Certification









Hours and Cost per Application Total Hours and Cost








Information Collection Activity Engineer/ 94.86 Manager/ 152.31 Legal (if applicable)/ 180.08 Technician/ 66.80 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: We are ending a separate category for this column as this activity is now accounted for under the Technician column. Transport $38.58/hr Administrative/ 45.97 Respondents hr/yr Labor Cost/yr Davis, Julian: Capital costs have been assumed to be $0.00 due to being far outside the ten-year period following original promulgation. We do not expect continued Capital cost but refer to the Operation and Maintenance cost at this point in time. Capital Startup Cost O&M Cost, Annualized (1) Applications/Respondent (2) Number of Respondents/ Responses Total hr/yr Total Cost/yr Applications/ Efs Total O&M Activities Tally
Total Labor Cost/yr



Review of regulations and guidance documents 18.0 9.0 10.0 4.0 0.0 1.0 42 $5,192.24 $0.00 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Adjusted by the CPI from the previous 2018 estimate. $16.36 1.0 430 18,060 2,239,698 2133 $7,034.80 430 430.00 $2,232,663.20



Developing eng families groups 15.0 3.0 1.0 0.0 0.0 1.0 20 $2,105.88 $0.00 $0.00 1.0 430 8,600 905,528
$0.00 430 430.00 $905,528.40



Gathering durability data 12.0 5.0 0.0 38.0 0.0 3.0 58 $4,576.18 $0.00 $0.00 6.0 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: The number of manufacturers minus the evaporative component manufacturers. (R7) 289 99,992 7,889,334 1724 $0.00 1724 1724.00 $7,889,334.32



[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: All testing is calculated below for in-house testing and contractor testing. Testing/Gathering emission or evaporative data on test engines 30.0 14.0 0.0 22.0 0.0 14.0 80 $7,091.32 $0.00 $0.00 5.0 430 170,640 15,125,786
$0.00 2133 2133.00 $15,125,785.56 1.53883202889825 1661
746.4625
Laboratory maintenance(1) 200.0 150.0 0.0 400.0 0.0 0.0 750 $68,538.50 $0.00 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Adjusted for 2021 by the CPI. We state the following in the Supporting Statement, "Engine manufacturers that have in-house testing facilities use them for all their certification and compliance testing needs as well as for research and development. The cost of maintaining these laboratories have been estimated at $73,300 per year. This estimate (which appears under the certification program estimates) includes the cost of test fuels, calibration gases and equipment." $79,952.08 1.0 299 224,070 44,363,046
$23,886,483.42 298.76 298.76 $20,476,562.26 0.65 1386.45

Cert, Durability & Evap Testing (annualized)(1)














$0.00 Contract Test Labs 0.00
[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Running change estimation 279.5


Small SI 10.0 4.0 1.0 20.0 0.0 2.0 37 $3,165.86 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: These O&M costs were calculated in the above "Lab Maintenance" cell. $0.00
9.8 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: For testing, these are individual engine families (certificates). 13 4,612 1,100,953 125 $0.00 125 124.65 $394,616.85



Large SI 10.0 4.0 1.0 60.0
2.0 77 $5,837.86

7.1 4 2,184 591,103 28 $0.00 28 28.37 $165,601.41



Rec Veh Test 50.0 4.0 0.0 80.0 0.0
134 $10,696.24 $0.00
2.5 13 4,404 592,517 33 $0.00 33 32.86 $351,516.95



Marine SI Test 10.0 4.0 1.0 20.0 0.0 2.0 37 $3,165.86 $0.00
9.5 2 700 343,698 19 $0.00 19 18.92 $59,898.07



Heavy Duty SI 10.0 4.0 1.0 20.0
2.0 37 $3,165.86 $0.00
2.6 2

4 $0.00 4 4.05 $12,821.73



Heavy Duty Si Evap Components 10.0 4.0 1.0 20.0
2.0 37 $3,165.86 $0.00
2.2 1

2 $0.00 2 2.06 $6,533.07



Components (per manufacturer) 10.0 4.0 1.0 20.0 0.0 2.0 37 $3,165.86 $0.00
2.9 17 1,863 587,469 50 $0.00 50 50.36 $159,426.38 $44,642,096.60

261
[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: This section for testing would be a subset of the above "new" test data for cert, durability, evap. Contracted Cert, Durability & Evap Testing (annualized)(1)








Projected Contract rates per engine/vehicle






0.00




Small SI








[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: If the above 79,952.08 for O&M on Lab maintenance, why these estimates for O&M? $5,666.67 9.8 16

159 $898,973.60 0 158.64 $0.00



Large SI








$15,000.00 6.0 6

36 $541,548.00 0 36.10 $0.00



Rec Veh Test








$7,333.33 2.5 17

42 $306,726.93 0 41.83 $0.00



Marine SI Test








$15,000.00 8.0 3

24 $361,200.00 0 24.08 $0.00



Heavy Duty SI








$15,000.00 2.0 2

4 $60,000.00 0 4.00 $0.00



Heavy Duty Si Evap Components








[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: This figure represents the average cost for both fuel lines and fuel tanks for certification testing. $8,500.00 2.2 1

3 $22,324.40 0 2.63 $0.00



Components (per manufacturer)








$8,500.00 2.9 22

64 $544,782.00 0 64.09 $0.00



Analyze data to determine compliance 6.0 4.0 1.0 0.0 0.0 1.0 12 $1,404.45 $0.00 $0.00 2.9 52 1,804 211,131
$0.00 150 150.33 $211,131.43



Preparing and submitting new certification application 2.0 0.5 1.0 0.0 0.0 1.0 5 $491.93 $0.00 $6.00 11.1 67 3,362 371,950 747 $4,482.00 747 747.00 $367,467.98



Preparing and submitting "carry over" applications 1.0 0.5 0.0 0.0 0.0 2.0 4 $262.96 $0.00 $3.00 3.8 363 4,851 368,614 1386 $4,158.00 1386 1386.00 $364,455.63



Paying Certification Fee 0.5 0.5 0.0 0.0 0.0 0.5 3 $146.57 $0.00 $1.00 5.3 430 6,837 336,312
$2,279.00 2279 2279.00 $334,033.03



Certification Fee (3)














$0.00 0 0.00 $0.00



Components 0.0 0.0 0.0 0.0 0.0 0.0 0 $0.00 $0.00 $397.00 2.9 141 0 161,976
$161,976.00 408 408.00 $0.00


32
All Other SI Engines 0.0 0.0 0.0 0.0 0.0 0.0 0 $0.00 $0.00 $563.00 6.0 289 0 970,612
$970,612.00 1724 1724.00 $0.00


289
Post Bond 1.0 1.0 0.5 0.0 0.0 1.0 4 $383.18 $0.00 $20.00 5.4 71 1,337 154,052
$7,641.84 382 382.09 $146,410.05



[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Applies to Small SI manufacutrers only Apply for Bond Waivers 2.0 0.5 0.5 0.0 0.0 1.0 4 $401.89 $0.00 $2.00 1.0 20 80 8,078
$40.00 20 20.00 $8,037.70



Preparing and supporting running changes 3.0 2.0 1.0 3.0 0.0 2.0 11 $1,061.62 $0.00 $6.00 3.9 280 12,012 1,165,841
$6,552.00 1092 1092.00 $1,159,289.04



Store, file and maintain records 3.0 1.0 1.0 0.0 0.0 7.0 12 $938.76 $0.00 $6.00 1.0 430 5,160 406,247
$2,580.00 430 430.00 $403,666.80



Preparing and Submitting Annual Production Report 8.0 2.0 1.0 2.0 0.0 2.0 15 $1,469.12 0 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: For O&M cost for reporting obligations we computed the average cost to maintain a computer system as the cost of labor and repair, in addtion to office and computig supplies per unit. Assesed expenses include $65 labor charge and ~$100 for parts and repair. $168 1.0 430 6,450 703,962
$72,240.00 430 430.00 $631,721.60



PLT Reporting and Record Keeping 101.0 8.0 11.0 80.0
9.0 209 $18,537.95
[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: O&M cost include test cell maintenance outside that accounted for in certification testing above. $3,078 7.7 95 153,406 15,866,075 734 $2,259,220.00 734 734.00 $13,606,855.30


734
ABT Reporting 40.0 10.0 5.0 0.0
10.0 65 $6,677.60
$168 1.0 23 1,495 157,449
$3,864.00 23 23.00 $153,584.80



In-Use Testing and Reporting 95.0 4.0 4.0 11.0
82.0 196 $14,845.60
[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: O&M cost include test cell maintenance outside that accounted for in certification testing above. $3,078 1.6 7 2,154 196,980
$33,826.74 10.99 10.99 $163,153.14



SEA Testing and Reporting 102.0 13.0 4.0 41.0
12.0 172 $15,666.51
$3,078 1.0 2 344 37,489
$6,155.91 2 2.00 $31,333.02



Defect Reporting (EDIR) [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Determine whether a substantial number have exceeded 1068 Part F requirements. File a defect and determine if recall is warranted. 8.0 3.0 1.0 0.0
2.0 14 $1,487.83
$168 1.0 19 266 31,461 19 $3,192.00 19 19.00 $28,268.77



Recall Reporting (VERR) [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Determine a "fix" for the recall condition. Some recalls are for labelling issues only. 8 3 1 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Test to conduct proper resolution for a voluntary recall. 10
2 24 $2,155.83
$168 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Recall reports are on a quarterly basis, similar to PLT reporting. 4 5 480 46,477 5 $3,360.00 20 20.00 $43,116.60


$77,937.37
Final (Year-End and End-Of-Model Year) Reporting 4 1 1 1 0 1 8 $824.60
$168 1 430 3,440 426,818 261 $72,240.00 430 430.00 $354,578.00



Total per respondent 411.5 221 23 709 0 48.5 1,414.5 $126,428 0 varies varies N/A 1,717.68 N/A
$63,774.94
36.97 $152,993.93



Total for the industry N/A N/A N/A N/A N/A N/A N/A $51,406,501 0
varies 52 738,603.0 $95,360,655
$30,243,492.65 15,564
$65,940,385.02



(1) See section 6(b)ii for details.






$124,958.87 Total Certification Cost [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Certification only. $27,789,394

570,568.0 $77,893,945.25
$27,789,394.00

$50,774,779.85



(2) See section 6(d) for details.








[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Certification only. $2,454,099

168,035 $221,768.97
$2,454,098.65 47.45













































































White=Certification






















Gray=Reporting and Recordkeeping






















Manager/ 152.31













































Engineer/ 94.86













































Technician/ 66.80













































Administrative/ 45.97













































Legal (if applicable)/ 180.08





































































Contract expenditures






















Small SI [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: If the above 79,952.08 for O&M on Lab maintenance, why these estimates for O&M? $5,666.67





















Large SI $11,836.67





















Rec Veh Test $7,333.33





















Marine SI Test $15,000.00





















Heavy Duty SI $15,000.00





















Heavy Duty Si Components $333.33





















Components (per manufacturer) $333.33






















Sheet 5: Respondent Labor rates

Table 1



Occupation SOC Code Number Mean Hourly Rate (BLS) Rate Increased by Factor of 2.1
Mechanical Engineers 17-2141 ($45.17) ($94.86) 94.857
Engineering Managers Nov-41 ($72.53) ($152.31) 152.313
Lawyers 23-1011 ($85.75) ($180.08)
Secretaries, Except Legal, Medical and Executive 43-6014 ($21.89) ($45.97)
Mechanical Engineering Technicians 17-3027 ($31.81) ($66.80)

Sheet 6: Truncated Charts

Information Collection Activity Engineer/ 94.86 Manager/ 152.31 Legal (if applicable)/ 180.08 Technician/ 66.80 Transport $38.58/hr Administrative/ 45.97 Respondents hr/yr Labor Cost/yr Capital Startup Cost O&M Cost, Annualized (1) Applications/Respondent (2) Number of Respondents/ Responses Total hr/yr Total Cost/yr Applications/ Efs Total O&M Total Responses
Total Labor Cost/yr
Preparing and Submitting Annual Production Report 8 2 1 2 0 2 15 1469.12 0 168 1 430 6450 703961.6
72240 430
$631,721.60
PLT Reporting and Record Keeping 101 8 11 80
9 209 18537.95
3077.95640326975 7.72631578947368 95 153406 15866075.3 734 292405.858310627 734
$13,606,855.30
ABT Reporting 40 10 5 0
10 65 6677.6
168 1 23 1495 157448.8
3864 23
$153,584.80
In-Use Testing and Reporting 95 4 4 11
82 196 14845.6
3077.95640326975 1.57 7 2154.04 196979.884871935
21545.6948228883 10.99
$163,153.14
SEA Testing and Reporting 102 13 4 41
12 172 15666.51
3077.95640326975 1 2 344 37488.9328065395
6155.91280653951 2
$31,333.02
Defect Reporting (EDIR) 8 3 1 0
2 14 1487.83
168 1 19 266 31460.77 19 3192 19
$28,268.77
Recall Reporting (VERR) 8 3 1 10
2 24 2155.83
168 4 5 480 46476.6 5 840 20
$43,116.60
Final (Year-End and End-Of-Model Year) Reporting 4 1 1 1 0 1 8 824.6
168 4.96046511627907 430 17064 2117215.8 2133 72240 2133
$1,758,871.80
Total Rpt and RCK 366 44 28 145 0 120 703 $61,665.04 0 Varies Varies 1,011 181,659 $19,157,107.69 2891 $472,483.47 3371.99 54 $16,416,905.03













85.17

























Table 2 - Annual Respondent Burden and Cost for SI Engine and Evaporative Components Certification










Hours and Cost per Application Total Hours and Cost










Information Collection Activity Respondents hr/yr Labor Cost/yr Capital Startup Cost O&M Cost, Annualized (1) Applications/Respondent (2) Number of Respondents Total hr/yr Total Cost/yr










Total per respondent 1326.9 $290.60 - varies varies N/A N/A N/A










Total for the industry N/A $124,958.87 - $27,789,394.00 varies 430.00 570,568.00 $50,774,779.85


















































Evaporative Components Composite
In-House and Contract testing












In-House Testing 6533.07
1695.11 in-house $12,510,151.64













159426.38

contract $5,455,650.71 $17,965,802.35












Contract Testing 22324.40
1695.14 in-house $44,642,096.60













544782.00

contract $211,131.43 $44,853,228.03












Total $733,065.85





































1695.11 O&M 1695.14 O&M

28268.77














$3,465,956.08 $15,012,611.23

43116.6 71385.37









































































IC 1695.11 1695.14 Difference Notes














In-House Lab testing $12,510,151.64 $44,642,096.60 $(32,131,944.96)















Contract testing $5,455,650.71 $211,131.43 $5,244,519.28















O&M Total $3,465,956.08 $15,012,611.23 $(11,546,655.15)















Defect and Recall $- $71,385.37 $(71,385.37)















Evaporative Components $233,200.00 $733,065.85 $(499,865.85)



































Total

$(39,005,332.05)
















Sheet 7: IC Respondent Burden Tally

Table 7


















Small SI Respondent Burden Tally








Hourly rate Wage Multiplier (2.1) Hourly rate Wage Multiplier (2.1) Hourly rate Wage Multiplier (2.1) Hourly rate Wage Multiplier (2.1) Hourly rate Wage Multiplier (2.1)



Hours Cost Burden Hours Cost Burden Hours Cost Burden Hours Cost Burden Hours Cost Burden









Manager Engineer Technician Administrative Legal (if applicable)
Program Number of Respond. Number of responses (Total) Manager/ 152.31 Engineer/ 94.86 Technician/ 66.80 Administrative/ 45.97 Legal (if applicable)/ 180.08 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: May not be necessary for our calculation Number of Activities/per Respondent Operations and Maintenance Cost Total Hours Per Year/per response Total Labor Cost Per Year Total Annual Capital Costs Total Annual O&M Costs Total Costs


72.53 152.31 45.17 94.86 31.81 66.80 21.89 45.97 85.75 180.08
Certification Application 104.00 1012.00 1.00 152.31 8.00 758.86 2.00 133.60 4.00 183.88 0.00 0.00 9.73
1252.38
















Cert Testing

4.00 609.25 10.00 948.57 20.00 1336.02 2.00 91.94 1.00 180.08



















Contract Testing































Evap Testing (if applicable)































PLT Testing

8.00 1218.48 40.00 3794.40 80.00 5344.00 8.00 367.76 4.00 720.32 0.00


















In-use Testing


0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00


















SEA Testing


0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00


















Totals:


0.00 58.00 5501.88 102.00 6813.60 14.00 643.58 5.00 900.40 9.73


















Reporting:


0.00
0.00
0.00
0.00
0.00



















PLT reports

2.00 304.62 8.00 758.88 2.00 133.60 2.00 91.94 1.00 180.08



















Sales production

1.00 152.31 1.00 94.86 1.00 66.80 1.00 45.97 1.00 180.08



















ABT reports

2.00 304.62 8.00 758.88
0.00 2.00 91.94 1.00 180.08



















Defect Reporting


0.00
0.00
0.00
0.00
0.00



















[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Voluntary Emissions Recall Reporting VERR


0.00
0.00
0.00
0.00
0.00



















Reporting Totals:


0.00
0.00
0.00
0.00
0.00





















































































Table 7


















Recreational Vehicles Respondent Burden Tally





















Hours Cost Burden Hours Cost Burden Hours Cost Burden Hours Cost Burden Hours Cost Burden



















Program Number of Respond.
Manager Engineer Technician Administrative Legal (if applicable) [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: May not be necessary for our calculation Number of Activities/per Respondent Operations and Maintenance Cost Total Hours Per Year Total Labor Cost Per Year Total Annual Capital Costs Total Annual O&M Costs Total Costs












Certification Application

0.5 76.155 4 379 - - - - - - -


















Cert Testing

4 609.24 50 4,743 80 5,344























Contract Testing

4 609.24 50 4,743 80 5,344























Evap Testing (if applicable)


0
-
-























PLT Testing

2 304.62 20 1,897 40 2,672 -
-
-


















In-use Testing


0 - - - - -
-
-


















SEA Testing


0 - - - - -
-
-


















Totals:


0 124 11,763 200 13,360 -
-
-


















Reporting:


0
-
-























PLT reports

2 304.62 40 3,794 40 2,672























Sales production

2 304.62 5 474
-























ABT reports

1 152.31 2 190
-























Defect Reporting


0
-
-























[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Voluntary Emissions Recall Reporting VERR


0
-
-























Reporting Totals:


0
-
-

























































































Table 7


















Large SI Respondent Burden Tally





















Hours Cost Burden Hours Cost Burden Hours Cost Burden Hours Cost Burden Hours Cost Burden



















Program Number of Respond.
Manager Engineer Technician Administrative Legal (if applicable) [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: May not be necessary for our calculation Number of Activities/per Respondent Operations and Maintenance Cost Total Hours Per Year Total Labor Cost Per Year Total Annual Capital Costs Total Annual O&M Costs Total Costs












Certification Application



-
-
-
-
-


















Cert Testing

4
10
60
2
1


[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: 1048.501(d) In place of the provisions of 40 CFR 1065.405, you may consider emission levels stable without measurement after 50 hours of engine operation.

















Contract Testing































Evap Testing (if applicable)































PLT Testing



-
-
-
-
-


















In-use Testing



-
-
-
-
-


















SEA Testing



-
-
-
-
-


















Totals:



10
60
2
1
-


















Reporting:































PLT reports































Sales production































ABT reports































Defect Reporting































[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Voluntary Emissions Recall Reporting VERR































Reporting Totals:

































































































Table 7


















Marine Respondent Burden Tally





















Hours Cost Burden Hours Cost Burden Hours Cost Burden Hours Cost Burden Hours Cost Burden



















Program Number of Respond.
Manager Engineer Technician Administrative Legal (if applicable) [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: May not be necessary for our calculation Number of Activities/per Respondent Operations and Maintenance Cost Total Hours Per Year Total Labor Cost Per Year Total Annual Capital Costs Total Annual O&M Costs Total Costs












Certification Application



-
-
-
-
-


















Cert Testing

4
10
20
2
1


[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: 1045.501(e) Engine stabilization. Instead of the provisions of 40 CFR 1065.405, you may consider emission levels stable without measurement after 12 hours of engine operation.

















Contract Testing































Evap Testing (if applicable)































PLT Testing



-
-
-
-
-


















In-use Testing



-
-
-
-
-


















SEA Testing



-
-
-
-
-


















Totals:



10
20
2
1
-


















Reporting:































PLT reports































Sales production































ABT reports































Defect Reporting































[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Voluntary Emissions Recall Reporting VERR































Reporting Totals:

































































































Table 7


















Heavy Duty SI Respondent Burden Tally (Similar to LSI)





















Hours Cost Burden Hours Cost Burden Hours Cost Burden Hours Cost Burden Hours Cost Burden



















Program Number of Respond.
Manager Engineer Technician Administrative Legal (if applicable) [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: May not be necessary for our calculation Number of Activities/per Respondent Operations and Maintenance Cost Total Hours Per Year Total Labor Cost Per Year Total Annual Capital Costs Total Annual O&M Costs Total Costs












Certification Application



-
-
-
-
-


















Cert Testing































Contract Testing































Evap Testing (if applicable)































PLT Testing



-
-
-
-
-


















In-use Testing



-
-
-
-
-


















SEA Testing



-
-
-
-
-


















Totals:



-
-
-
-
-


















Reporting:































PLT reports































Sales production































ABT reports































Defect Reporting































[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Voluntary Emissions Recall Reporting VERR































Reporting Totals:

































































































Table 7


















EVAP components Respondent Burden Tally (See 1060 Evap)





















Hours Cost Burden Hours Cost Burden Hours Cost Burden Hours Cost Burden Hours Cost Burden



















Program Number of Respond.
Manager Engineer Technician Administrative Legal (if applicable) [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: May not be necessary for our calculation Number of Activities/per Respondent Operations and Maintenance Cost Total Hours Per Year Total Labor Cost Per Year Total Annual Capital Costs Total Annual O&M Costs Total Costs












Certification Application



-
-
-
-
-


















Cert Testing































Contract Testing































PLT Testing



-
-
-
-
-


















In-use Testing



-
-
-
-
-


















SEA Testing



-
-
-
-
-


















Totals:



-
-
-
-
-


















Reporting:































PLT reports































Sales production































ABT reports































Defect Reporting































[Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: Voluntary Emissions Recall Reporting VERR































Reporting Totals:
































Sheet 8: PLT

Table 4 - Annual Respondent Burden and Cost - Production Line Testing Program

Hours and Cost per Engine Family Total Hours and Cost
Information Collection Activity Engineer/ 94.86 Respondents hr/yr Labor Cost/yr Capital Startup Cost O&M Cost(1) Frequency (2) Number of Respondents Total hr/yr Total Cost/yr Efs
Review of instructions and regulations 45 58 $6,470.89 $0.00 $0.00 1 95 5,510 $614,734.55
Training 8 9 $825.68 $0.00 $40.00 1 95 855 $82,239.60
Projecting testing needs and planning test schedules 11 13 $1,241.74 $0.00 $20.00 1 95 1,235 $119,865.30
Engine selection and transport 4 5 $446.24 $0.00 $20.00 8 95 3,670 $342,220.16
Engine inspection 1 7 $495.66 $0.00 $0.00 8 95 5,138 $363,814.44
Testing (In-house) 8 20 $1,560.48 $0.00 $300.00 Julian Maurice Davis: Based on average respondent burden per year (2018). 77 95 146,800 $13,655,923.20 734
Data entry and analysis 8 9 $804.85 $0.00 $30.00 8 95 6,606 $612,779.90
Other tasks (test equipment calibration, engine repair, etc.) 4 64 $4,387.44 $0.00 $100.00 1 95 6,080 $426,306.80
Testing (Contract Out)









Small SI



Nydia Yanira Reyes-Morales: from Phil, annualized, based on 125 hours of durability accumulation $5,666.67 Nydia Yanira Reyes-Morales: Used actual received from comp dabase 2011. Revised for 2018 (julian Davis). 0 0 0 $0.00
Large SI



Nydia Yanira Reyes-Morales: SwRI 2007, adjusted from inflation $11,836.67 0 0 0 $0.00
Marine SI



Nydia Yanira Reyes-Morales: adjusted from inflation from 2008: $1587 $15,000.00 0 0 0 $0.00
Setting up contract 2 7 $794.13 $0.00 $21.00 0 0 0 $0.00
Preparing and submitting report 8 12 $1,183.21 $0.00 $5.00 8 95 9,120 $903,039.60
Store, file and maintain records 2 5 $327.63 $0.00 $2.00 8 95 3,800 $250,518.80
Total per manufacturer 101 209 $18,537.95 $0.00 varies varies N/A N/A N/A
Total for the industry N/A N/A $15,112,222.35 $0.00 $2,259,220.00 N/A 179 188,814 17,371,442 734





$3,077.96
















































Total Number of manufacturers




















Engineer/ 94.86 Manager/ 152.31









Sheet 9: ABT

Table 3 - Annual Respondent Burden and Cost - Average, Trading and Banking Program







Hours and Cost per Application Total Hours and Cost
2020 with 2.1 multiplier




Information Collection Activity Engineer/ 94.86 Respondents hr/yr Labor Cost/yr Capital Startup Cost O&M Cost (1) Number of Respondents Total hr/yr Total Cost/yr
Engineer/ 94.86 Manager/ 152.31 Legal (if applicable)/ 180.08 Technician/ 66.80 Transport $38.58/hr Administrative/ 45.97
Precertification activities/Submit info in cert application 8 64 $673 $0 $25 23 1,472 $16,045






Gather Information regarding point of first retail sale (2) 8 188 $673 $0 $100 23 4,324 $17,770






Develop and submit end-of-year-report 8 43 $673 $0 $25 23 989 $16,045






Develop and submit final reports 8 26 $673 $0 $14 23 598 $15,792






Recordkeeping (2) 8 28 $673 $0 $14 23 644 $15,792






Total 40 349 $2,972 $0 $178 N/A N/A N/A






Total for the industry N/A N/A $77,349 $0 $8,900 50 8,027 $81,443






(1) See section 6(b)ii for details.

$3,363











(2) Numbers reflect one activity done four times a year.















Sheet 10: In-Use Test

Table 5 - In-use Estimated Annual Respondent Burden and Cost

Hours and cost per application Total hours and cost
Information Collection Activity Engineer/ 94.86 Transport $38.58/hr Respondent hr/yr Labor Cost/yr Capital Startup Cost O&M Cost(1) Frequency (2) Number of Respondents Total hr/yr Total Cost/yr
Review of instructions and regulations 7 0 9 $996 $0 $0 1 7 63 $6,975
Training 2 0 3 $257 $0 $120 1 7 21 $2,636
Plan activities 16 0 16 $1,518 $0 $20 1 7 112 $10,764
Procure engines 2 0 5 $434 $0 $100 1.57 7 55 $5,874
Ship Engines 1 0 1 $95 $0 $200 1.57 7 11 $3,243
Engine Maintenance 1 0 4 $295 $0 $210 1.57 7 44 $5,558
Testing In-house 8 0 46 $3,297 $0 $900 1.57 7 506 $46,170
Setting up contract 2 0 7 $794 $0 $25 0 0 0 $0
Testing (Contracting out)

0 $0





Small SI

0 $0
$5,667 0 0 0 $0
Large SI

0 $0
$11,837 0 0 0 $0
Marine SI

0 $0
$15,000 1.57 7 0 $165,000
Data entry and analysis 22 0 29 $2,450 $0 $10 1.57 7 319 $27,064
Preparing and submitting report 18 0 21 $2,086 $0 $15 1.57 7 231 $23,109
Store, file and maintain records 8 0 9 $805 $0 $5 1.57 7 99 $8,908
Total per manufacturer 87 0 150 $13,027 $0 varies varies N/A N/A N/A
Total for the industry N/A N/A $1,461 $123,482 $0 $181,820 N/A 7 1,461 $305,302






















Total number of manufacturers Engineer/ 94.86










150








Sheet 11: SEA

Table 6 - Annual Respondent Burden and Cost - Selective Enforcement Auditing (SEA) Program

Hours and Cost per Application Total Hours and Cost
Information Collection Activity Engineer $94.86/hr Respondent hr/yr Labor Cost/yr Capital Startup Cost O&M Cost(1) Frequency (2) Julian Maurice Davis: A total of 8-SEAs were condiucted in 2017. However, the three year average was about 5 per year. Number of Respondents (5) Total hr/yr Total Cost/yr
Provide Pre-audit information 20 37 $4,010 $0 $0 1 2 74 $8,021
Review of instructions and regulations 7 9 $996 $0 $0 1 2 18 $1,993
Training 3 5 $504 $0 $32 1 2 10 $1,071
Plan activities 16 16 $1,518 $0 $32 1 2 32 $3,100
Testing In-house 8 46 $3,297 $0 $200 1 2 92 $6,995
Testing Contract Out 0 0 $0 $0 $20,000 1 0 0 $0
Data entry and analysis 22 29 $2,450 $0 $1 1 2 58 $4,903
Preparing and submitting report 18 21 $2,086 $0 $3 1 2 42 $4,178
Store, file and maintain records 8 9 $805 $0 $1 1 2 18 $1,612
Total per manufacturer 102 172 $15,667 $0 varies varies N/A N/A N/A
Total for the industry N/A N/A $31,333 $0 $538 N/A 5 344 $31,871
(1) Includes diskettes, photocopying, postage expenses, phone calls, and testing costs, annualized. See section 6(b)(iii) for details.
(2) 1 = one time tasks; other # = number of tests performed/eng manufacturer/model year. Refer to Section 6(d) for further detail.
(3) EPA estimates it will audit 14 manufacturers over the next 3 years. It might, however, request pre-audit information from several manufacturers each year.
Average burden = total burden / # of respondents
Total of 8 SEAs in 2017, though the three year average was about 5 per year.






























Manager/ 152.31

















Engineer/ 94.86

















Technician/ 66.80

















Administrative/ 45.97

















Legal (if applicable)/ 180.08


















Sheet 12: EPA Burden

Table 8 - Annual Agency Burden and Cost
Employee Hours and Labor Cost
Level Rate Rate Increase by 1.6 Number of Employees Full time hours % of Time Total hr/yr Total Labor cost/yr









Engineer GS-13/6 $56.75 $90.80 10 2080 100% 20800 $1,888,672
Contract GS-13/6 $56.75 $90.80 1 2080 30% 624 $56,660
Attorney GS-13/7 $58.37 $93.40 1 2080 20% 416 $38,853
Managers GS-15/1 $66.72 $106.75 1 2080 100% 2080 $222,044
SES-1 SES - 1 $82.93 $132.69 1 2080 15% 312 $41,400
IT Support GS-13/6 $56.75 $90.80 5 2080 30% 3120 $283,301
SEE Support


6 2080 100% 12480 [Threaded comment] Your version of Excel allows you to read this threaded comment; however, any edits to it will get removed if the file is opened in a newer version of Excel. Learn more: https://go.microsoft.com/fwlink/?linkid=870924 Comment: We estimate a rate of $83,000 per person per year for SEE support. $415,000
Subtotal
25 N/A N/A 39,832 $2,945,930









O&M Costs
Testing






$200,000
Other






$20,000
SEE Support






$177,066
Contract Support - Compliance






$83,000
Contract Support -Certification






$200,000







Subtotal: $680,066
















TOTAL: $3,625,996

Sheet 13: Regulatory Appendix

CERTIFICATION APPLICATION REQUIREMENTS 1048.205 What must I include in my application?
This section specifies the information that must be in your application, unless we ask you to include less information under §1048.201(c). We may require you to provide additional information to evaluate your application.

(a) Describe the engine family's specifications and other basic parameters of the engine's design and emission controls. List the fuel types on which your engines are designed to operate (for example, gasoline and natural gas). List each distinguishable engine configuration in the engine family.

(b) Explain how the emission control systems operate. Describe the evaporative emission controls, if applicable. Also describe in detail all system components for controlling exhaust emissions, including all auxiliary emission control devices (AECDs) and all fuel-system components you will install on any production or test engine. Identify the part number of each component you describe. For this paragraph (b), treat as separate AECDs any devices that modulate or activate differently from each other. Include sufficient detail to allow us to evaluate whether the AECDs are consistent with the defeat device prohibition of §1048.115.

(c) Explain how the engine diagnostic system works, describing especially the engine conditions (with the corresponding diagnostic trouble codes) that cause the malfunction-indicator light to go on. Propose what you consider to be extreme conditions under which the diagnostic system should disregard trouble codes, as described in §1048.110.

(d) Describe the engines you selected for testing and the reasons for selecting them.

(e) Describe the test equipment and procedures that you used, including any special or alternate test procedures you used (see §1048.501).

(f) Describe how you operated the emission-data engine before testing, including the duty cycle and the number of engine operating hours used to stabilize emission levels. Explain why you selected the method of service accumulation. Describe any scheduled maintenance you did.

(g) List the specifications of each test fuel to show that it falls within the required ranges we specify in 40 CFR part 1065, subpart H.

(h) Identify the engine family's useful life.

(i) Include the maintenance instructions you will give to the ultimate purchaser of each new nonroad engine (see §1048.125).

(j) Include the emission-related installation instructions you will provide if someone else installs your engines in a piece of nonroad equipment (see §1048.130).

(k) Identify each high-cost warranted part and show us how you calculated its replacement cost, including the estimated retail cost of the part, labor rates, and labor hours to diagnose and replace defective parts.

(l) Describe your emission control information label (see §1048.135).

(m) Identify the emission standards to which you are certifying engines in the engine family.

(n) Identify the engine family's deterioration factors and describe how you developed them (see §1048.240). Present any emission test data you used for this.

(o) State that you operated your emission-data engines as described in the application (including the test procedures, test parameters, and test fuels) to show you meet the requirements of this part.

(p) Present emission data to show that you meet emission standards, as follows:

(1) Present exhaust emission data for HC, NOX, and CO on an emission-data engine to show your engines meet the applicable duty-cycle emission standards we specify in §1048.101. Show emission figures before and after applying deterioration factors for each engine. Include emission results for each mode if you do discrete-mode testing under §1048.505. Include test data for each type of fuel from 40 CFR part 1065, subpart H, on which you intend for engines in the engine family to operate (for example, gasoline, liquefied petroleum gas, methanol, or natural gas). If we specify more than one grade of any fuel type (for example, a summer grade and winter grade of gasoline), you need to submit test data only for one grade unless the regulations of this part specify otherwise for your engine. Note that §1048.235 allows you to submit an application in certain cases without new emission data.

(2) If your engine family includes a volatile liquid fuel (and you do not use design-based certification under §1048.245), present evaporative test data to show your vehicles meet the evaporative emission standards we specify in subpart B of this part. Show these figures before and after applying deterioration factors, where applicable.

(q) State that all the engines in the engine family comply with the field-testing emission standards we specify in §1048.101(c) for all normal operation and use when tested as specified in §1048.515. Describe any relevant testing, engineering analysis, or other information in sufficient detail to support your statement.

(r) For engines not subject to transient testing requirements in §148.101(a), include information showing how your emission controls will function during normal in-use transient operation. For example, this might include the following:

(1) Emission data from transient testing of engines using measurement systems designed for measuring in-use emissions.

(2) Comparison of the engine design for controlling transient emissions with that from engines for which you have emission data over the transient duty cycle for certification.

(3) Detailed descriptions of control algorithms and other design parameters for controlling transient emissions.

(s) Report test results as follows:

(1) Report all test results involving measurement of pollutants for which emission standards apply. Include test results from invalid tests or from any other tests, whether or not they were conducted according to the test procedures of subpart F of this part. We may ask you to send other information to confirm that your tests were valid under the requirements of this part and 40 CFR part 1065.

(2) Report measured CO2, N2O, and CH4 as described in §1048.235. Small-volume engine manufacturers may omit reporting N2O and CH4.

(t) Describe all adjustable operating parameters (see §1048.115(e)), including production tolerances. Include the following in your description of each parameter:

(1) The nominal or recommended setting.

(2) The intended physically adjustable range.

(3) The limits or stops used to establish adjustable ranges.

(4) Information showing why the limits, stops, or other means of inhibiting adjustment are effective in preventing adjustment of parameters on in-use engines to settings outside your intended physically adjustable ranges.

(u) Provide the information to read, record, and interpret all the information broadcast by an engine's onboard computers and electronic control units. State that, upon request, you will give us any hardware, software, or tools we would need to do this. If you broadcast a surrogate parameter for torque values, you must provide us what we need to convert these into torque units. You may reference any appropriate publicly released standards that define conventions for these messages and parameters. Format your information consistent with publicly released standards.

(v) Confirm that your emission-related installation instructions specify how to ensure that sampling of exhaust emissions will be possible after engines are installed in equipment and placed in service. If this cannot be done by simply adding a 20-centimeter extension to the exhaust pipe, show how to sample exhaust emissions in a way that prevents diluting the exhaust sample with ambient air.

(w) State whether your certification is intended to include engines used in stationary applications. Also state whether your certification is limited for certain engines. If this is the case, describe how you will prevent use of these engines in applications for which they are not certified. This applies for engines such as the following:

(1) Constant-speed engines.

(2) Variable-speed engines.

(x) Unconditionally certify that all the engines in the engine family comply with the requirements of this part, other referenced parts of the CFR, and the Clean Air Act.

(y) Include good-faith estimates of U.S.-directed production volumes. Include a justification for the estimated production volumes if they are substantially different than actual production volumes in earlier years for similar models.

(z) Include other applicable information, such as information specified in this part or part 1068 of this chapter related to requests for exemptions.

(aa) Name an agent for service located in the United States. Service on this agent constitutes service on you or any of your officers or employees for any action by EPA or otherwise by the United States related to the requirements of this part.


Amendment to the Application §1048.225 How do I amend my application for certification to include new or modified engine configurations?
Before we issue you a certificate of conformity, you may amend your application to include new or modified engine configurations, subject to the provisions of this section. After we have issued your certificate of conformity, you may send us an amended application requesting that we include new or modified engine configurations within the scope of the certificate, subject to the provisions of this section. You must amend your application if any changes occur with respect to any information included in your application.

(a) You must amend your application before you take any of the following actions:

(1) Add an engine configuration to an engine family. In this case, the engine configuration added must be consistent with other engine configurations in the engine family with respect to the criteria listed in §1048.230.

(2) Change an engine configuration already included in an engine family in a way that may affect emissions, or change any of the components you described in your application for certification. This includes production and design changes that may affect emissions any time during the engine's lifetime.

(b) To amend your application for certification, send the Designated Compliance Officer the following information:

(1) Describe in detail the addition or change in the engine model or configuration you intend to make.

(2) Include engineering evaluations or data showing that the amended engine family complies with all applicable requirements. You may do this by showing that the original emission-data engine is still appropriate for showing that the amended family complies with all applicable requirements.

(3) If the original emission-data engine for the engine family is not appropriate to show compliance for the new or modified engine configuration, include new test data showing that the new or modified engine configuration meets the requirements of this part.

(c) We may ask for more test data or engineering evaluations. You must give us these within 30 days after we request them.

(d) For engine families already covered by a certificate of conformity, we will determine whether the existing certificate of conformity covers your newly added or modified engine. You may ask for a hearing if we deny your request (see §1048.820).

(e) For engine families already covered by a certificate of conformity, you may start producing the new or modified engine configuration anytime after you send us your amended application and before we make a decision under paragraph (d) of this section. However, if we determine that the affected engines do not meet applicable requirements, we will notify you to cease production of the engines and may require you to recall the engines at no expense to the owner. Choosing to produce engines under this paragraph (e) is deemed to be consent to recall all engines that we determine do not meet applicable emission standards or other requirements and to remedy the nonconformity at no expense to the owner. If you do not provide information required under paragraph (c) of this section within 30 days after we request it, you must stop producing the new or modified engines.
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