INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
Information
Requirements
for
Nonroad
Diesel
Engines
(
Nonroad
Large
SI
Engines
and
Marine
Diesel
Engines)
(
Amendments)

Spring
2004
Assessment
and
Standards
Division
Office
of
Transportation
and
Air
Quality
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
1
Information
Collection
Request
1(
a).
Title
Information
Requirements
for
Nonroad
Diesel
Engines
ICR
Tracking
Number:
1897.07
1(
b).
Short
Characterization
The
Clean
Air
Act
authorizes
EPA
to
adopt
emission
standards
for
new
nonroad
engines.
We
need
information
to
verify
that
manufacturers
comply
with
emission
standards
 
before
production
begins,
during
production,
and
after
units
have
been
placed
into
service.
We
require
manufacturers
to
generate
or
retain
information
to
demonstrate
that
engines
comply
with
emission
standards.

Manufacturers
generally
send
us
the
data
they
collected
and
keep
these
records
and
other
pertinent
information.
We
may
request
to
see
any
of
these
records.
We
and
the
regulated
companies
will
use
the
data
exclusively
to
ensure
compliance
with
emission
standards.
Emission
rates
for
specific
pollutants
and
total
numbers
of
engines
built
are
examples
of
what
we
require.

This
ICR
is
a
revision
to
the
existing
information
collection
approved
under
OMB
control
number
2060­
0460.
The
revisions
generally
include
new
standards,
testing,
and
reporting
requirements
for
nonroad
diesel
engines.

2.
Need
For
and
Use
of
the
Collection
2(
a).
Need/
Authority
for
the
Collection
The
data
we
require
in
this
ICR
is
necessary
to
comply
with
Title
II
of
the
Clean
Air
Act,
as
amended
in
1990.
The
Act
directs
us
to
adopt
regulations
for
nonroad
engines
if
we
determine
those
engines
contribute
significantly
to
air
pollution
in
the
U.
S.
Now
that
we
have
made
this
determination,
the
Act
directs
us
to
set
emission
standards
for
any
category
of
nonroad
engines
that
contributes
to
air
quality
nonattainment
in
two
or
more
areas
in
the
U.
S.
We
can
only
meet
the
requirements
of
the
Act
by
collecting
data
from
the
regulated
industry.
Also,
we
will
only
have
an
effective
program
if
we
know
that
these
engines
maintain
their
certified
emission
level
throughout
their
operating
lives.

2(
b).
Use/
Users
of
the
Data
We
will
oversee
the
certification
process
and
maintain
the
program
database.
We
will
use
the
2
data
items
to
verify
compliance
with
the
following
requirements
associated
with
the
new
emission
standards:


Determine
whether
or
not
a
prototype
engine
may
adequately
represent
an
engine
family.


Ensure
compliance
of
production­
line
engines.


Issue
a
recall
to
correct
a
noncompliant
family
of
engines.


Confirm
actual
emission
benefits
gained
by
the
program.


Ensure
proper
maintenance
and
setting
of
physically
adjustable
parameters.


Aid
in
the
production
projections
to
randomly
select
the
engines
which
are
to
undergo
testing.


Determine
whether
a
prototype
or
freshly
manufactured
engine
should
be
issued
a
certificate
of
conformity.


Ensure
that
durability
of
emission
controls
is
consistent
with
the
manufacturer's
stated
useful
life.


Ensure
control
of
emissions
across
the
range
of
engine
operation
expected
in
the
normal
course
of
its
lifetime

Manage
the
importation
of
engines
that
meet
requirements
3.
Nonduplication,
Consultations,
and
other
Collection
Criteria
3(
a).
Nonduplication
State
and
local
governments
have
not
adopted
emission
standards
comparable
to
those
we
are
adopting.
The
information
requested
under
this
ICR
is
therefore
not
available
from
other
sources.

3(
b).
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
We
published
a
proposed
rulemaking
in
the
Federal
Register
regarding
emission
standards
for
nonroad
diesel
engines
on
May
23,
2003.
We
received
comments
on
several
issues
related
to
information
collection.
These
comments
are
summarized
in
the
following
table.

Table
1
Comments
Related
to
Information
Collection
Commenter
Comment
Response
EMA
Identifying
the
worst­
case
engine
configuration
in
an
engine
family
is
overly
burdensome.
Manufacturers
are
responsible
to
use
"
good
engineering
judgment"
in
selecting
the
worstcase
engine.
This
is
consistent
with
their
ongoing
liability
for
meeting
the
emission
standards
for
all
engine
configurations.

Yanmar
Manufacturers
should
be
able
to
choose
between
the
C1
and
the
G2
duty
cycles
for
testing
engines
below
19
kW.
We
proposed
to
specify
the
G2
duty
cycle
instead
of
the
C1
duty
cycle
for
testing
engines
below
19
kW.
We
agree
with
the
commenter,
but
only
for
engines
that
the
manufacturer
will
sell
into
applications
that
run
at
intermediate
speeds,
which
is
appropriate
for
the
C1
duty
cycle.
Commenter
Comment
Response
3
EMA
EPA
should
not
change
the
smoke
test.
We
proposed
to
rely
on
the
new
international
procedure
for
measuring
smoke.
However,
since
smoke
testing
will
continue
only
for
those
engines
that
do
not
have
PM
aftertreatment,
we
agree
with
manufacturers
that
it
is
not
worth
investing
in
new
measurement
equipment
and
procedures
for
smoke.

EMA
The
thresholds
for
investigating
and
reporting
defects
are
too
low.
We
have
adjusted
the
investigation
and
reporting
thresholds
to
reduce
the
recordkeeping
burden,
as
described
in
the
Summary
and
Analysis
of
Comments.

EMA
Manufacturers
should
not
have
to
make
production
engines
available
to
EPA
for
testing.
From
the
beginning
of
EPA
emission
standards,
we
have
reserved
the
right
to
procure
and
test
manufacturers'
production
engines.
While
this
is
not
a
frequent
occurrence,
we
believe
it
is
an
important
element
of
our
effort
to
ensure
compliance
with
emission
standards.

EMA
EPA
should
allow
for
treating
all
information
from
manufacturers
as
confidential,
not
just
information
EMA
sends
to
EPA.
The
proposed
regulatory
provisions
related
to
confidential
information
do
not
limit
manufacturers'
ability
to
identify
information
as
confidential,
whether
that
information
comes
from
site
visits,
inspections,
special
testing,
or
other
means.

3(
c)
Consultations
We
have
met
with
companies
that
will
be
subject
to
the
new
emission
standards.
These
contacts
are
summarized
in
Table
1.
4
Table
1
Industry
Contacts
Regarding
Information
Collection
Date
Contact
July
30­
31,
2002
William
Passie­
Caterpillar
passie_
william_
c@
cat.
com
August
13,
2002
Tom
Haley­
Vermeer
(
641)
628­
3141
September
16,
2002
SER
Outreach
Meeting
#
1
W.
Josh
Sutherland­
Wisconsin
Motors
(
901)
229­
0715
Eric
Ramsey­
Sweepster,
Inc.
(
734)
996­
9116
x391
Darrin
Drollinger­
Association
of
Equipment
Manufacturers
(
AEM)
(
312)
321­
1470
November
13,
2002
SER
Outreach
Meeting
#
2
Bob
Ball,
Mike
Spear,
Phil
Jenkins­
Sweepster,
Inc.
(
734)
996­
9116
Sensors,
Inc.

November
12,
2002
Bob
Ball,
Mike
Spear­
Sweepster,
Inc.
(
Site
visit)
(
734)
996­
9116
March
21,
2003
Engine
Manufacturers
Association
(
EMA)
Meeting
August
12,
2003
Case
New
Holland
November
17,
2003
Engine
Manufacturers
Association
(
EMA)
Meeting
March
23,
2004
Engine
Manufacturers
Association
(
EMA)
Meeting
July
9,
2003
Komatsu
July
14,
2003
Engine
Manufacturers
Association
(
EMA)
Meeting
July
15,
2003
John
Deere
July
16,
2003
Engine
Manufacturers
Association
(
EMA)
Meeting
October
20,
2003
Caterpillar
3(
d)
Effects
of
Less
Frequent
Collection
Annual
reporting
for
certifying
engine
families
is
necessary
to
align
with
the
regulatory
requirement
to
certify
engine
families
every
year.

3(
e)
General
Guidelines
5
This
ICR
complies
with
the
general
guidelines,
except
for
the
requirement
to
retain
records
for
up
to
eight
years,
as
described
in
4(
b)(
ii)
below.

3(
f)
Confidentiality
We
hold
information
from
the
engine
manufacturers
as
confidential
until
the
associated
engines
are
available
for
purchase.
Manufacturers
may
submit
proprietary
information,
consisting
generally
of
sales
projections
and
certain
sensitive
technical
descriptions.
We
grant
confidentiality
in
accordance
with
the
Freedom
of
Information
Act,
EPA
regulations
at
40
CFR
part
2,
subpart
B,
and
class
determinations
issued
by
our
Office
of
General
Council.

3(
g)
Sensitive
Questions
We
do
not
ask
sensitive
questions.
This
collection
complies
with
The
Privacy
Act
and
OMB
Circular
A­
108.

4.
Respondents
and
Information
Requested
4(
a)
Respondents/
NAICS
and
SIC
Codes
The
respondents
are
generally
involved
in
the
industries
shown
in
Table
2.

Table
2
NAICS
and
SIC
Codes
for
Respondent
Categories
Respondent
Categories
NAICS
Codesa
SIC
Codesb
Manufacturers
of
new
nonroad
diesel
engines
333618
3519
Manufacturers
of
farm
machinery
and
equipment
333111
3523
Manufacturers
of
lawn
and
garden
tractors
(
home)
333112
3524
Manufacturers
of
industrial
trucks
333924
3537
Manufacturers
of
construction
machinery
333120
3531
Manufacturers
of
mining
machinery
and
equipment
333131
3532
Manufacturers
of
oil
and
gas
field
machinery
and
equipment
333132
3533
aNorth
American
Industry
Classification
System
(
NAICS)
bStandard
Industrial
Classification
(
SIC)
system
code.

4(
b)
Respondents
and
Information
Requested
(
i)
Data
Items
6
Manufacturers
must
send
us
an
application
for
certification,
including
emission
data
and
other
descriptive
information.
In
addition,
manufacturers
create
engine
labels
and
send
us
information
in
some
cases
regarding
engines
that
are
exempt
from
emission
standards
or
other
specific
requirements.

(
ii)
Respondent
Activities
Companies
retain
records
as
hard
copy
and
may
also
reduce
the
information
to
microfilm,
computer
disks,
etc.
We
require
very
little
submission
of
information
to
process
applications
for
certification.
This
reduces
the
resource
burden,
both
for
the
industry
and
for
us.
However,
because
we
don't
have
the
information
on
file,
we
depend
on
manufacturers
to
retain
the
records
to
allow
us
to
verify
compliance
throughout
the
useful
life
of
the
engines.
Eight
years
is
sufficient
time
for
this
information
for
most
engines.
Any
investigation
of
in­
use
engines
generally
does
not
start
until
three
or
more
years
after
the
manufacturer
completes
the
application
for
certification.

Manufacturers
must
send
us
an
application
for
certification
with
extensive
information
about
their
engines.
For
example,
this
includes
the
following
things:

"
Data
showing
an
engine's
emission
level
of
various
regulated
pollutants
for
comparison
to
the
emission
standards.
We
also
require
manufacturers
to
send
data
regarding
CO
2
emissions
so
that
we
can
verify
their
calculations.
Emission
data
generally
relates
to
new
engines
or
to
engines
that
have
been
operated
for
an
extended
period
to
allow
for
estimating
the
performance
of
the
emission­
control
system
after
accounting
for
deterioration
over
the
full
useful
life.

"
A
description
of
all
their
emission­
related
components
and
emission­
control
strategies
and
how
they
tested
their
engines.

"
Maintenance
instructions
for
users.

"
Installation
instructions
for
equipment
manufacturers.

"
Information
related
to
adjustable
parameters.

"
Instructions
related
to
reading
information
from
the
engine's
onboard
computer.

"
Projected
production
volumes.

We
sometimes
exempt
engines
from
current
emission
standards,
but
require
manufacturers
to
meet
less
stringent
emission
standards
as
a
condition
of
the
exemption.
In
these
cases,
manufacturers
must
generally
use
engines
that
are
identical
to
those
they
have
already
certified.
If
they
can't
make
engines
that
are
identical
to
previously
certified
engines,
we
require
them
to
generate
the
same
information
that
they
would
need
to
certify,
but
stop
short
of
requiring
them
to
submit
the
data
and
apply
for
a
certificate
of
conformity.

Some
manufacturers
also
participate
in
emission­
credit
programs,
in
which
they
produce
some
engines
with
emissions
above
the
standard
and
others
with
emissions
below
the
standard
and
report
annually
to
show
that
they
have
sufficient
credits
to
meet
applicable
requirements.
This
is
an
optional
program,
so
we
don't
include
specific
estimates
related
to
any
additional
reporting
or
recordkeeping
for
generating
or
using
emission
credits.
7
As
part
of
the
requirements
related
to
certification,
manufacturers
must
label
all
their
engines
to
show
their
status
relative
to
certification.
Most
engines
will
have
a
label
describing
how
the
engine
is
certified.
Some
engines
need
a
label
describing
how
they
are
exempt
from
current
emission
standards.
In
some
cases,
engine
manufacturers
need
to
send
additional
labels
for
equipment
manufacturers
to
apply
to
equipment
after
installing
the
engine
to
alert
operators
to
any
particular
engine
requirements
related
to
fuel
quality.
Manufacturers
may
also
need
to
send
duplicates
of
their
certification
label
to
equipment
manufacturers
who
find
that
the
original
label
is
obscured
once
the
engine
is
installed
in
the
equipment.

Over
the
course
of
the
year,
manufacturers
must
amend
their
application
for
certification
if
they
change
their
engines
or
add
new
engines
under
an
existing
certificate.
They
must
also
notify
us
in
certain
cases
if
they
change
their
maintenance
instructions
for
users.
Manufacturers
must
annually
report
their
production
volumes,
divided
by
certain
characteristics.

We
may
require
manufacturers
to
test
their
engines
at
the
production
line
in
a
selective
enforcement
audit.
This
involves
testing
several
engines
to
show
that
the
meet
emission
standards.
Similarly,
we
may
require
manufacturers
to
supply
us
with
production
engines
for
our
testing.

Manufacturers
must
also
report
to
us
if
they
learn
that
a
substantial
number
of
their
engines
have
emission­
related
defects.
This
is
normally
not
a
requirement
to
collect
information,
but
if
manufacturers
learn
that
there
is
or
might
be
a
substantial
number
of
emission­
related
defects,
then
they
must
send
us
information
describing
the
defects.

Many
companies
import
engines.
First,
some
companies
import
engines
that
are
not
subject
to
emission
standards;
they
must,
however,
fill
out
a
form
documenting
the
status
of
their
engine
and
the
reason
for
their
exemption.
Since
most
engines
are
now
covered
by
emission
standards,
this
has
become
much
less
common.
It
is
now
generally
limited
to
engines
used
for
stationary,
underground
mining,
and
hobby
applications.
Second,
some
companies
import
engines
as
Independent
Commercial
Importers,
meaning
that
they
do
their
own
testing
instead
of
importing
engines
that
have
been
certified
by
engine
manufacturers.

We
have
also
adopted
special
provisions
that
allow
equipment
manufacturers
to
sell
equipment
with
uncertified
engines
(
or
engines
certified
to
less
stringent
standards).
This
involves
a
one­
time
notification
before
using
this
flexibility
and
annual
reporting
to
document
compliance
with
these
provisions.
This
is
a
voluntary
program
that
substantially
reduces
the
costs
of
compliance
for
engine
manufacturers,
so
we
have
not
included
specific
costs
related
to
these
reporting
or
recordkeeping
activities
here.

All
reports,
submissions,
notifications,
and
requests
for
approval
must
be
addressed
to:
Manager,
Engine
Programs
Group
(
6405­
J),
U.
S.
Environmental
Protection
Agency,
1200
Pennsylvania
Ave.,
Washington,
DC
20460.
Respondents
must
submit
information
in
an
approved
EPA
information
format.
8
5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5
(
a)
Agency
Activities
Our
certification
and
tracking
process
involves
reviewing
applications
and
emission
data
from
engine
and
vehicle
manufacturers.
From
this
data,
we
issue
certificates
of
conformity,
and
may
confirm
that
production
and
in­
use
engines
continue
to
comply
with
standards.
We
may
also
select
families
to
be
tested
in
a
given
production
year
and
require
additional
testing,
based
on
an
analysis
of
the
submitted
data.

5
(
b)
Collection
Methodology
and
Management
We
currently
use
computers
extensively
to
collect
information
from
vehicle
manufacturers.
Based
on
this
approach
as
a
model,
much
routine
information
(
test
results,
projections)
can
be
electronically
transmitted
directly
from
the
manufacturers
to
our
computer
database.
We
expect
to
publish
this
information
on
our
website
once
certified
engines
go
into
production
(
www.
epa.
gov/
otaq/).

5
(
c)
Small­
Entity
Flexibility
We
have
included
provisions
to
ease
the
compliance
burden
on
small
businesses.
For
instance,
some
small
manufacturers
of
nonroad
diesel
engines
will
be
allowed
the
option
to
delay
compliance
with
emission
standards.
For
small
manufacturers
of
nonroad
diesel
equipment,
we
also
permit
the
installation
of
a
limited
number
of
engines
that
meet
less
stringent
emission
standards.

5(
d)
Collection
Schedule
The
principal
reporting
requirements
are
associated
with
certification
to
the
emission
standards,
which
begin
to
apply
in
2008.
Reporting
requirements
therefore
do
not
begin
until
the
end
of
the
preceding
year
at
the
earliest.
Annual
reporting
is
based
on
the
beginning
of
the
model
year,
which
can
vary
for
each
manufacturer
and
for
each
engine
family.

6.
Estimating
Burden
and
Cost
of
the
Collection
Engine
manufacturers
comply
with
emission
standards
by
submitting
an
application
for
certification,
which
obligates
them
to
do
a
certain
amount
of
testing
to
show
they
comply
with
the
standards.
The
following
discussion
develops
burden
and
cost
estimates
for
the
first
three
years
of
the
program.

6
(
a)
Estimating
Respondent
Burden
9
The
estimates
of
respondent
burden
utilize
data
from
the
affected
industries
or
commercially
available
databases.
Burden
hours
per
engine
family
are
based
upon
established
hour
amounts
for
engine
families,
as
published
in
the
"
Application
for
Motor
Vehicle
Emission
Certification
and
Fuel
Economy
Labeling"
(
OMB
No.
2060­
0104).

The
burden
for
certification
testing
is
generally
based
on
conducting
four
engine
tests
for
each
engine
family,
then
using
that
test
data
for
several
years.
The
estimated
cost
for
full
certification
testing,
including
durability
demonstration
testing,
is
$
15,000
per
engine
test
(
combining
labor
and
O&
M
expenses).
The
manufacturer's
application
for
certification
involves
an
extensive
effort
the
first
year,
followed
by
relatively
little
effort
in
subsequent
years.
We
estimate
that
manufacturers
will
conduct
new
certification
testing
every
five
years;
the
costs
have
been
estimated
on
an
annual
average
basis.

In
addition
to
testing,
manufacturers
must
prepare
the
application
for
certification
and
maintain
appropriate
records.
We
have
estimated
the
cost
of
these
combined
activities,
which
include
engineering
and
clerical
effort,
to
be
$
10,000
per
engine
family
per
certification
cycle.
As
with
the
testing
costs,
we
are
presenting
annual
average
costs.

Manufacturers
are
also
expected
to
conduct
testing
on
their
production
engines
in
a
selective
enforcement
audit.
We
base
the
estimated
costs
on
testing
10
engine
families
annually,
at
approximately
$
80,000
per
family.
This
allows
for
testing
multiple
engines
in
each
family.

The
estimated
burden
also
takes
into
account
the
manufacturers'
need
to
investigate
and
report
emission­
related
defects.
The
analysis
bases
this
estimate
on
a
scenario
in
which
10
percent
of
engine
families
trigger
the
defect­
investigation
threshold.
We
estimate
that
each
of
these
families
would
require
on
average
126
hours
of
effort
to
perform
the
investigation
and
submit
the
required
reports.

These
burden
estimates
apply
equally
whether
the
manufacturer
conducts
the
required
activities,
or
if
the
manufacturer
hires
a
third
party
for
some
of
these
activities.

6
(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
Labor
rates
on
a
per­
hour
basis,
are
taken
from
the
Bureau
of
Labor
Statistics
web
site
at
http://
stats.
bls.
gov/
news.
release/
ecec.
t12.
htm
(
accessed
November
24,
2000).
Technical
labor
is
$
42.89/
hr,
managerial
labor
is
$
65.19/
hr,
clerical
labor
is
$
27.11/
hr.
Labor
rates
were
multiplied
by
1.5
to
account
for
fringe
benefits
and
other
overhead
expenses.

(
ii)
Estimating
Operations
and
Maintenance
Costs
Operation
and
maintenance
costs
include
expenses
related
to
engine
testing.
Costs
are
for
10
laboratory
time,
the
use
of
test
equipment,
engine
parts,
fuel
and
other
supplies,
and
fabrication
of
test
tools
and
fixtures.
Direct
labor
costs
and
operations
and
maintenance
costs
combine
for
the
total
test
costs
described
above.

(
iii)
Capital/
Start­
up
Costs
Companies
required
to
conduct
testing
generally
either
have
testing
facilities
or
are
expected
to
conduct
testing
at
a
contractor's
laboratory.
Thus,
no
capital
or
startup
costs
are
anticipated
for
purchasing
emission
testing
equipment.

(
iv)
Annualizing
Capital
Costs
With
no
estimated
capital
or
start­
up
costs,
there
is
no
need
to
annualize
these
costs.

6
(
c)
Estimating
Agency
Burden
and
Cost
Our
Engine
Programs
Compliance
Group
administers
emission
certification
programs.
This
group
has
approximately
17
full­
time
employees.
We
project
50
hours
per
week
of
staff
time
(
at
$
40
per
hour,
loaded)
to
manage
engine
compliance
programs
related
to
new
emission
standards.
This
comes
to
approximately
2,500
hours
or
$
100,000
per
year
to
oversee
the
requirements
of
the
final
rule.

6
(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
following
tables
shows
the
labor
and
other
costs
associated
with
meeting
the
new
requirements
for
each
engine
family.
This
includes
certification
costs,
plus
the
cost
of
any
additional
testing.
Per­
family
costs
are
multiplied
by
the
number
of
engine
families
and
added
to
estimated
capital
costs
to
arrive
at
an
estimated
total
cost.
11
Table
3
Annual
Respondent
Burden
and
Cost
 
Nonroad
Diesel
Engine
Manufacturers
Information
Collection
Activity
Average
annual
burden
and
cost
per
family
#
of
Families
Annualized
Capital
&

Startup
cost
Total
Hours
and
Costs
Mgr.
@

$
65/
hr
Tech.
@

$
43/
hr
Cler.
@

$
27/
hr
Hours
per
family
Labor
cost
per
family
O&
M
Cost
Total
Hours/
yr
Total
Cost/
yr
Cert.
application*
2
36
6
44
$
1,840
$
0
1077
$
0
47,388
$
4,303,692
Recordkeeping
0.2
2.2
2
4.4
$
162
$
0
1077
$
0
4,739
$
174,043
Cert./
durability
testing
0
168
0
168
$
7,224
$
4,776
1077
$
35,973,829
180,936
$
48,897,829
Selective
enforcement
audits
5
100
10
115
$
4,895
$
75,105
10
$
0
1,150
$
800,000
Defect
reporting
6
40
80
126
$
4,270
$
0
108
$
0
13,570
$
459,879
Subtotal
Total
O&
M
cost
=

$
5,894,802
 
$
35,973,829
247,783
$
54,635,443
*
Costs
for
certification
application
include
fees
assessed
at
$
2,156
per
family.
12
Table
4
Average
Annual
Respondent
Burden
and
Cost
 
Importers
Information
Collection
Activity
Average
annual
burden
and
cost
per
family
#
of
Families
Annualized
Capital
&

Startup
cost
Total
Hours
and
Costs
Mgr.
@

$
65/
hr
Tech.
@

$
43/
hr
Cler.
@

$
27/
hr
Hours
per
family
Labor
cost
per
family
O&
M
Cost
Total
Hours/
yr
Total
Cost/
yr
Reporting
1
0
6.5
7.5
$
241
$
0
15
$
0
113
$
3,608
Recordkeeping
1
0
6.5
7.5
$
241
$
0
15
$
0
113
$
3,608
Testing
0
16
0
16
$
688
$
10,000
15
$
0
240
$
160,320
Exemption
forms
(
3520­
21)
0
0
0.5
0.5
$
14
$
0
125
$
0
63
$
1,688
Subtotal
Total
O&
M
cost
=
$
150,000
 
$
0
529
$
169,224
13
6
(
e)
Bottom­
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
Bottom­
line
burden
and
cost
for
the
first
three
years
of
the
rulemaking
are
shown
in
Table
5.
The
table
shows
industry
totals
and
average
values
for
each
respondent
by
category.
These
estimated
costs
include
startup
expenses
(
for
example,
the
purchase
of
emission
sampling
equipment
and
new
recordkeeping
software).

Table
5
Summary
of
Bottom­
line
Burden
Hours
and
Cost
Affected
Entities
Number
of
Respondents
Industry
Totals
Average
per
Respondent
Annualized
Capital
Costs
Total
O&
M
Costs
per
Year
Total
Hours
per
Year
Total
Costs
per
Year
Total
Hours
per
Year
Total
Costs
per
Year
Nonroad
diesel
engine
manufacturers
75
$
35,973,829
$
5,894,802
247,783
$
54,635,443
3,304
$
728,473
Independent
Commercial
Importers
15
$
0
$
150,000
466
$
167,535
31
$
11,169
Exempt
importers
25
$
0
$
0
63
$
1,688
3
$
68
Total
115
$
35,973,829
$
6,044,802
248,312
54,804,666
2,159
$
476,562
(
ii)
Agency
Tally
Our
estimated
burden
is
approximately
2,500
hours
or
per
year
(
or
$
100,000)
to
oversee
the
requirements
of
the
final
rule,
as
described
in
Section
6(
c).

6
(
f)
Burden
Statement
As
shown
in
Table
5,
these
new
requirements
account
for
almost
250,000
burden
hours
and
about
$
6
million
dollars
in
O&
M
costs
annually.
These
estimates
include
time
to
conduct
testing,
prepare
applications,
prepare
and
submit
reports,
and
record
and
keep
required
information.

Burden
means
the
total
time
for,
or
financial
resources
expended
by,
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
14
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

Burden
Statement:
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
2,159
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2003­
0012,
which
is
available
for
public
viewing
at
the
Air
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
and
the
Air
Docket
is
(
202)
566­
1744.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
EDOCKET
is
available
for
submitting
or
viewing
public
comments,
accessing
the
index
listing
of
the
contents
of
the
public
docket,
and
accessing
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
(
OAR­
2003­
0012)
and
OMB
control
number
(
2060­
0460)
in
any
correspondence.

6
(
g)
Reason
for
Change
in
Burden
We
are
proposing
emission
standards
for
nonroad
diesel
engines.
This
information
collection
15
request
updates
the
estimated
burden
to
reflect
the
additional
effort
required
to
meet
the
new
standards
and
consolidates
all
the
various
recordkeeping
and
reporting
items
for
these
engines.
16
Appendix
to
ICR
#
1897.07
The
original
ICR
(#
1897.02)
for
marine
diesel
engines
was
approved
Oct.
12,
2001
and
announced
in
the
Federal
Register
on
February
28,
2003
(
68
FR
9746).

Summary
of
Bottom­
line
Burden
Hours
and
Cost
(
1897.02)

Affected
Entities
Number
of
Respondents
Industry
Totals
Average
per
Respondent
Annualized
Capital
Costs
Total
O&
M
Costs
per
Year
Total
Hours
per
Year
Total
Costs
per
Year
Total
Hours
per
Year
Total
Costs
per
Year
Manufacturers
and
Marinizers
12
$
0
$
200,000
20,280
$
2,453,632
1,690
$
204,469
Dressers
20
$
0
$
0
40
$
1,840
2
$
92
Rebuilders
200
$
0
$
0
1,200
$
38,800
6
$
194
Total
232
$
0
$
200,000
21,520
$
2,494,272
93
$
10,751
ICR
supplement
(#
1897.04)
for
multiple
engine
categories
was
approved
January
31,
2003.
The
ICR
items
for
recreational
marine
diesel
engines
and
for
Category
3
marine
diesel
engines
were
announced
in
the
Federal
Register
on
February
28,
2003
(
68
FR
9746).
The
items
for
Large
SI
engines,
recreational
vehicles,
and
engine
rebuilders
will
be
announced
in
the
nonroad
diesel
Tier
4
NPRM.

Summary
of
Bottom­
line
Burden
Hours
and
Cost
(
1897.04)

Affected
Entities
Number
of
Respondents
Industry
Totals
Average
per
Respondent
Annualized
Capital
Costs
Total
O&
M
Costs
per
Year
Total
Hours
per
Year
Total
Costs
per
Year
Total
Hours
per
Year
Total
Costs
per
Year
Large
SI
engine
manufacturers
12
$
174,419
$
2,507,790
21,986
$
3,617,683
1,832
$
301,474
Recreational
marine
diesel
engine
manufacturers
12
$
0
$
870,238
7,273
$
1,178,061
606
$
98,172
Category
3
marine
diesel
engine
manufacturers
6
$
0
$
67,104
1,812
$
144,022
302
$
24,004
Engine
rebuilders
200
$
0
$
0
1,200
$
38,800
6
$
194
Total
230
$
174,419
$
3,445,132
32,271
$
4,978,566
140
$
21,646
