UPDATED
COST
ANALYSIS
for
the
MOTOR
VEHICLE
AND
ENGINE
COMPLIANCE
PROGRAM
On
August
7,
2002
the
Environmental
Protection
Agency,
EPA
published
a
notice
of
proposed
rulemaking
for
Motor
Vehicle
and
Engine
Compliance
Program
Fees
for:
Light­
Duty
Vehicles;
Light­
Duty
Trucks;
Heavy­
Duty
Vehicles
and
Engines;
Nonroad
Engines;
and
Motorcycles
(
fees
rule
NPRM)
in
the
Federal
Register.
At
that
time
EPA
made
available
through
the
docket
a
Cost
Analysis
that
described
the
costs
incurred
by
EPA
in
conducting
the
Motor
Vehicle
and
Engine
Compliance
Program
(
MVECP).
The
MVECP
provides
certification
and
compliance
services
related
to
air
pollution
control
in
highway
and
nonroad
vehicles
and
engines.

Since
August
7,
2002,
EPA
held
a
public
hearing
on
September
19,
2002
and
received
comments
from
that
hearing
as
well
as
written
comments.
Also,
in
the
time
between
the
NPRM
and
the
FRM,
EPA
gathered
additional
information
about
the
programs
and
tests
that
it
plans
to
conduct
and
is
in
a
better
position
to
determine
the
actual
costs
of
its
compliance
programs
for
2004
and
beyond
than
it
was
at
the
time
of
that
the
NPRM
was
written.
As
a
result
of
an
internal
reassessment
of
testing
capabilities
and
requisite
levels
of
appropriate
compliance
oversight,
along
with
comments
received,
EPA
made
several
adjustments
that
resulted
in
a
change
in
costs
of
certificates
for
several
industry
categories.
EPA
used
the
information
on
resources
and
lab
capabilities
to
make
the
changes
and,
therefore,
the
current
rulemaking
more
accurately
represents
the
test
program
that
EPA
will
put
into
place.

The
changes
are
described
in
the
Final
Rulemaking
for
the
fees
rule,
Section
3.
The
issues
are
discussed
more
fully
in
the
Response
to
Comments
document.
This
Updated
Cost
Analysis
discusses
how
the
program
adjustments
are
reflected
the
updated
cost
study
and
the
implications
to
the
fees.
The
changes
are
reflected
in
the
attached
new
worksheets
which
are
based
on
"
Appendix
C"
which
was
attached
to
the
"
Motor
Vehicle
and
Engine
Compliance
Program
Cost
Analysis"
document.

The
revised
worksheets
are
attached
to
this
document.
Each
worksheet
number
and
title
corresponds
to
the
worksheets
from
"
Appendix
C"
which
was
attached
to
the
"
Motor
Vehicle
and
Engine
Compliance
Program
Cost
Analysis"
document.
The
direct
changes
to
the
cost
study
that
were
made
as
a
result
of
program
adjustments
and
the
corresponding
worksheet
totals
are
shaded
in
the
updated
worksheets.
These
changes
are
carried
forward
in
the
cost
study
to
the
LOD,
CCD
and
Overall
summary
sheets,
worksheets
#
3,
#
4
and
#
1,
respectively,
and,
ultimately,
to
the
fees
summary
sheet,
worksheet
#
2.
This
document
will
not
detail
the
indirect
changes
to
the
worksheets
that
were
made
as
a
result
of
the
direct
changes
because
the
relationship
between
the
worksheets
is
essentially
unchanged.

The
direct
changes
that
were
made
to
the
cost
study
are
indicated
on
the
table
below:
Worksheet
#
Row
Column
FRM
NPRM
2
Marine
SI
Other
­$
20,645
­

7
FTE­
Direct
Heavy­
Duty
Highway
Engine
1.25
2.25
7
FTE­
Indirect
Heavy­
Duty
Highway
Engine
0.25
0.50
10
HDE
#
2
HDE
Cell
Controller
Replacement
Recoverable
$
75,000
$
300,000
10
HDE
#
2
Analytical/
Sampling
System
Recoverable
$
182,500
$
730,000
10
HDE#
1&
2:
Diesel
Engine
Cell
Cooling
Control
Recoverable
$
3,750
$
30,000
10
HDE#
1&
2:
NOx
&
PM
Measurement
Methods/
Equipment
Recoverable
$
93,750
$
750,000
10
HDE
#
2:
SCR
Load
Controller
(
Heavy­
Duty
Engine
Test
Sites)
Recoverable
$
30,000
$
120,000
12
Engine
Procurement­
Heavy
Duty
Total
$
68,960
$
225,360
16
10%
of
Certified
Families
(
1
eng/
family)
NR
CI
6
families
10
families
16
10%
of
Certified
Families
(
1
eng/
family)
HD
HW
0
families
10
families
16
Contract­
$
20,000/
engine
NR
CI
$
120,000
$
200,000
16
Contract­
$
20,000/
engine
HD
HW
$
0
$
200,000
16
Selective
Enforcement
Audits
HD
HW
5
audits
10
audits
16
$
3,000/
audit
HD
HW
$
15,000
$
30,000
Details
of
Changes
to
Worksheets
1.
Worksheet
#
2
The
final
fees
rule
does
not
establish
fees
for
classes
of
nonroad
engines
and
equipment
where
EPA
had
not
proposed
emissions
standards
for
these
classes
before
the
Fees
NPRM
was
published
on
August
7,
2002.
Although
the
fees
proposal
included
fees
for
marine
SI
inboard
/
sterndrive
engines,
the
final
rule
does
not
set
fees
for
these
engines.
Therefore,
in
EPA's
revised
worksheet
#
2,
in
the
"
Other"
column,
we
reduced
the
total
cost
of
compliance
activities
by
$
20,645
to
reflect
that
the
marine
SI
category
will
not
be
covered
by
this
regulation.

2.
Worksheet
#
7
The
number
of
direct
FTE
and
indirect
FTE
listed
under
the
heavy­
duty
highway
column
had
been
decreased
to
1.25
and
0.25
FTE,
respectively,
from
the
2.25
and
0.5
FTE
that
were
listed
in
the
N
PRM.
This
is
a
net
reduction
of
1.25
FTE.

3.
Worksheet
#
10
EPA
determined
that
it
will
use
of
one
test
cell
for
one
quarter
of
a
year
to
conduct
HDE
compliance
testing
rather
than
the
two
test
cells
for
an
entire
year.
Therefore,
the
recoverable
costs
for
HDE
#
1
and
HDE
#
2
have
been
adjusted
to
reflect
the
actual
amount
of
time
that
the
cells
will
be
used
for
compliance
work.
The
recoverable
costs
that
are
specifically
dedicated
to
HDE
#
2
have
been
reduced
to
one
quarter
of
the
proposed
costs.
These
include
the
costs
for:

HDE
#
2:
HDE
Cell
Controller
Replacement
HDE
#
2:
Analytical
/
Sampling
System
and
HDE
#
2:
SCR
Load
Controller
(
Heavy
Duty
Engine
Test
Sites)

The
recoverable
costs
for
equipment
that
is
to
be
shared
between
HDE
#
1
and
HDE
#
2
have
been
reduced
to
one
eighth
of
the
proposed
cost
to
represent
the
portion
dedicated
to
one
cell
for
one
quarter
of
a
year.
These
include
the
costs
for:

HDE#
1&
2:
Diesel
Engine
Cell
Cooling
Control
HDE#
1&
2:
NOx
&
PM
Measurement
Methods/
Equipment
4.
Worksheet
#
12
EPA
proposed
procuring
10
in­
use
engines,
two
families
of
5
engines,
at
a
cost
of
$
25,240
for
the
first
engine
per
family
and
$
21,860
for
subsequent
engines
in
the
families.
The
revised
test
plan
specified
testing
3
engines
in
a
family.
The
cost
of
procuring
the
first
engine
is
$
25,240
and
the
subsequent
two
will
cost
$
21,860
per
engine.
The
final
revised
cost
is
$
68,960.

5.
Worksheet
#
16
The
costs
for
the
proposed
Enhanced
Engine
Compliance
Program
were
shown
on
worksheet
#
16.
The
number
of
tests
were
revised
as
follows:
the
number
of
confirmatory
tests
for
certification
at
a
contracted
facility
were
decreased
for
NR
CI
and
HD
HW
to
6
families
and
0
families,
respectively.
At
a
cost
of
$
20,000
per
engine,
the
costs
for
NR
CI
and
HD
HW
for
certification
confirmatory
testing
was
decreased
to
$
120,000
and
$
0,
respectively.

Furthermore,
the
number
of
selective
enforcement
audits
of
HD
HW
engines
was
revised
from
10
to
5
audits
resulting
in
a
revised
cost
of
$
15,000
for
the
cost
of
selective
enforcement
auditing.

Results
of
Changes
to
Worksheets
The
direct
changes
to
the
worksheets
listed
above
resulted
in
a
change
in
the
total
cost
figures
for
the
worksheets
which
were
carried
forward
to
the
LOD
and
CCD
summary
sheets,
worksheet
#
3
and
worksheet
#
4
respectively,
to
the
Overall
Cost
Summary
sheet,
worksheet
#
1
and,
ultimately,
resulted
in
a
change
in
fees.
The
specific
changes
to
the
summary
sheets
and
fees
are
not
discussed
in
this
document
as
the
relationship
between
the
worksheets
is
generally
the
same
as
described
in
the
original
Cost
Analysis
Document.
The
final
fees
are
shown
on
revised
Worksheet
#
2.
