Supporting
Statement
for
Information
Collection
Request
Marine
Engine
Manufacturer
In­
use
Emission
Testing
Program
Reporting
and
Recordkeeping
(
OMB
No.
2060­
0322)

December
2000
Certification
and
Compliance
Division
Office
of
Transportation
and
Air
Quality
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
2
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
TITLE
Marine
Engine
Manufacturer
In­
use
Emission
Testing
Program
Reporting
and
Record
Keeping
1(
b)
SHORT
CHARACTERIZATION
(
ABSTRACT)

The
Office
of
Transportation
and
Air
Quality
uses
information
and
data
generated
in
the
Marine
Engine
Manufacturer
In­
use
Emission
Testing
Program
to
assess
and
assure
compliance
of
in­
use
marine
engines
with
exhaust
emission
standards.
Section
213(
d)
of
the
Clean
Air
Act
as
amended
(
Act)
authorizes
application
of
section
207(
c)
(
the
recall
provision
of
the
Act)
to
marine
engines.
Section
208
authorizes
this
manufacturerbased
in­
use
emission
testing
program
and
the
associated
reporting
requirements.

This
information
collection
requires
manufacturers
of
marine
engines
to
generate
and
submit
quarterly
reports
of
engine
information
and
emissions
data
generated
in
the
manufacturer's
own
in­
use
testing
program.
The
Engine
Programs
Group
in
the
Certification
and
Compliance
Division,
Office
of
Transportation
and
Air
Quality,
Office
of
Air
and
Radiation
will
collect
this
information
and
evaluate
it
to
determine
whether
in­
use
marine
engines
comply
with
the
emission
standards
set
forth
in
the
regulations
at
40
CFR
Part
91.

At
the
Administrator's
request,
manufacturer's
may
be
required
to
submit
to
EPA
documents
generated
during
their
test
programs
pertaining
to
engine
procurement,
maintenance,
and
testing
processes
as
well
as
test­
equipment
calibration
and
maintenance
practices.

The
results
of
the
manufacturers
in­
use
testing
program
will
primarily
be
used
by
the
Office
of
Transportation
and
Air
Quality
to
verify
compliance
of
in­
use
marine
engines;
however,
emissions
data
generated
during
this
testing
becomes
public
information
after
the
testing
programs
are
concluded.
Consequently,
States
and
localities
may
also
use
data
generated
in
mobile
source
emission
inventory
estimates.
Additionally,
the
Certification
and
Compliance
Division
will
use
the
exhaust
emission
data
from
this
testing
to
evaluate
the
appropriateness
of
the
certification
process.

The
information
is
collected
by
the
Certification
and
Compliance
Division
and
stored
in
internal
files
and
data
bases.
Nonconfidential
copies
of
reports
from
manufacturers
in­
use
emission
results
are
available
to
the
public
upon
request,
and
3
they
will
be
eventually
posted
on
the
OTAQ
web
page
with
other
emission
data
from
mobile
sources.

The
estimated
annual
cost
to
industry
resulting
from
this
in­
use
testing
program
and
information
collection
is
$
947,611.
This
annual
cost
is
divided
among
10
marine
engine
manufacturers.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
This
information
collection
is
needed
by
EPA
to
ensure
that
marine
engine
manufacturers
are
producing
engines
which
comply
emission
requirements
in
use.
This
in­
use
compliance
program
is
beyond
the
certification
and
production
stages
to
verify
that
engines
comply
with
applicable
regulations
and
achieve
real
world
emission
reductions
well
into
the
engine's
useful
life.

Section
207(
c)
of
the
Clean
Air
Act
(
Act)
authorizes
EPA
to
enforce
applicable
standards
in
actual
use
and
to
recall
engines
which
do
not
comply
with
emission
standards
in­
use.
This
authority
provides
an
important
incentive
for
manufacturers
to
design
and
build
durable
engines.
Section
208(
a)
of
the
Act
requires
manufacturers
to
establish
and
maintain
records,
make
reports,
perform
tests,
and
provide
information
to
EPA.
Section
213(
d)
of
the
Act
authorizes
EPA
to
subject
nonroad
(
including
marine)
engines
to
sections
207
and
208
of
the
Act.
Regulations
at
40
CFR
Part
91
include
standards,
test
procedures
and
as
well
as
in­
use
testing
requirements
applicable
to
marine
sparkignition
engines.

2(
b)
USE/
USERS
OF
THE
DATA
The
Office
of
Transportation
and
Air
Quality
(
OTAQ)
will
use
this
information
collection
to
monitor
and
enforce
compliance
with
emission
requirements.

The
results
of
this
manufacturer­
based
in­
use
testing
are
used
by
the
Certification
and
Compliance
Division
of
OTAQ
to
verify
that
marine
engine
manufacturers
are
building
sufficiently
durable
engines
to
meet
emission
standards
when
in
actual
use.
Manufacturers
are
subject
to
recall
if
the
Administrator
determines
that
a
substantial
number
of
any
class
or
category
of
engines,
although
properly
maintained
and
used,
do
not
conform
to
applicable
emission
standards
when
in
actual
use.

The
Certification
and
Compliance
Division
also
uses
this
exhaust
emission
data
to
evaluate
the
appropriateness
of
the
deterioration
factors
developed
during
the
certification
process.
And,
data
generated
in
the
marine
in­
use
program
is
used
as
the
basis
for
the
In­
Use
Credit
Program
described
at
Part
91
Subpart
N.
4
States
and
localities
may
also
use
data
generated
in
mobile
source
emission
inventory
estimates.
Additionally,
the
Assessment
and
Standards
Division
of
OTAQ
may
use
in­
use
data
in
evaluating
the
effectiveness
of
the
marine
regulation
and
in
modeling
emission
inventories.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
NONDUPLICATION
The
Office
of
Transportation
and
Air
Quality
and
the
Office
of
Enforcement
and
Compliance
Assurance
(
OECA)
are
the
only
Federal
offices
which
regulate
the
emissions
of
in­
use
marine
engines.
On
October
27,
2000
Dennis
Johnson
of
CCD
confirmed
with
Anne
Wick
of
the
Air
Enforcement
Division
in
OECA
that
inuse
emission
data
from
marine
engines
is
not
currently
collected
by
OECA.

Within
the
Office
of
Transportation
and
Air
Quality,
the
Certification
and
Compliance
Division
obtains
other
emissions
data
from
marine
engines.
The
other
data
includes
certification
data
from
preproduction
prototype
engines,
and
emission
data
from
Production­
Line
Testing
(
PLT)
and
Selective
Enforcement
Audit
(
SEA)
testing
of
new
production
marine
engines.
Neither
of
these
programs
determine
the
emissions
performance
of
marine
engines
after
in­
use
operation.

Consequently,
it
has
been
confirmed
that
OTAQ
is
the
only
office
that
requires
generation
and
reporting
of
engine
and
emissions
data
from
in­
use
marine
engines.
This
data
is
not
gathered
by
or
available
from
other
agencies,
departments
or
program
offices.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
the
public
comment
period
for
this
ICR
renewal
was
published
in
the
Federal
Register
on
August
31,
2000.
No
comments
were
received.
A
copy
of
the
FR
notice
is
attached.

3(
c)
CONSULTATIONS
EPA
consulted
with
four
marine
(
nonroad)
engine
manufacturers
regarding
the
hourly
pay
rates
associated
with
this
type
of
information
collection.
All
of
these
manufacturers
have
conducted
marine
in­
use
testing
and
have
submitted
in­
use
marine
engine
data.

Contact
Affiliation
Phone
Number
Michael
Tyrrell
American
Honda
Motor
Co.
Inc.
310­
783­
3419
5
Thomas
Pugh
Yamaha
Motor
Corporation,
USA
714­
761­
7807
Susan
Bucheger
Mercury
Marine
920­
929­
4978
Lawrence
Keller
OMC
847­
689­
5620
3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
The
information
collection
schedules
listed
in
this
document
are
essential
for
compliance
assurance.
The
quarterly
reporting
schedule
provides
the
marine
engine
manufacturers
a
reasonable
time
frame
by
which
to
report
emission
results
from
their
in­
use
programs.
Manufacturers
have
twelve
months
after
receiving
notification
to
begin
testing
an
engine
family
selected
by
the
Agency,
and
this
testing
must
be
completed
within
a
twelve
month
period.
The
quarterly
reporting
schedule
only
takes
effect
once
emissions
data
has
been
generated
for
an
engine
family.

Providing
this
to
EPA
at
a
less
frequent
interval
would
compromise
the
Agency's
ability
to
expeditiously
evaluate
the
emissions
results
and
determine,
in
a
timely
manner,
whether
inuse
marine
engines
conform
to
Federal
emission
standards.
Any
delay
in
making
such
a
determination
reduces
the
universe
of
engines
which
will
be
reached
by
the
recall
because
both
engine
scrappage
and
owners
unwillingness
to
participate
in
recalls
increase
with
vehicle
age.

EPA
will
occasionally
require
manufacturers
to
submit
documents
pertaining
to
engine
procurement,
maintenance,
and
testing
processes
as
well
as
test­
equipment
calibration
and
maintenance
practices
which
will
ensure
the
Agency
that
manufacturers
are
testing
properly
used
and
maintained
engines
according
to
the
procedures
established
in
the
CFR.

The
manufacturers
are
required
to
provide
this
information
within
30
days
of
EPA's
request.
Providing
this
information
at
a
less
frequent
interval
would
hinder
the
Agency's
ability
to
ensure
manufacturers
are
generating
meaningful
emissions
data.

3(
e)
GENERAL
GUIDELINES
The
marine
engine
manufacturer
in­
use
emission
testing
program
exceeds
OMB
general
guidelines
by
requiring
that
records
be
maintained
for
more
than
three
years.
Regulations
at
91.121(
b)
require
that
manufactures
retain
records
for
eight
years.
This
recordkeeping
requirement
stems,
in
large
part,
from
the
statutory
requirement
at
Section
207
of
the
Act
that
engines
comply
with
emission
standards
throughout
their
useful
life.
In
addition,
the
manufacturers
must
comply
with
requirements
to
recall
vehicles
and
engines
failing
to
meet
emission
standards
during
their
useful
life.
6
No
other
general
guideline
is
exceeded
by
this
information
collection.

3(
f)
Confidentiality
The
production
information
is
considered
confidential
and
is
therefore
protected
under
40
CFR
Part
2.
All
other
reports
are
considered
public
information,
as
authorized
by
section
208(
b)
of
the
Act,
and
are
filed
in
EPA's
Public
Information
File.

3(
g)
Sensitive
Questions
Not
applicable.
No
questions
of
a
sensitive
nature
are
asked.

4.
THE
RESPONDENTS
AND
INFORMATION
REQUESTED
4(
a)
RESPONDENTS/
SIC
CODES
The
respondents
are
marine
engine
manufacturers
(
SIC
3519).
7
4(
b)
INFORMATION
REQUESTED
(
i)
Data
items
and
Recordkeeping
requirements
Reported
Items:
Regulation
Recordkeeping
Period
(
Years)

1.
Engine
Family
40
CFR
91.805(
a)(
1)
8
2.
Model
40
CFR
91.805(
a)(
2)
8
3.
Engine
Serial
Number
40
CFR
91.805(
a)(
3)
8
4.
Date
of
Manufacturer
40
CFR
91.805(
a)(
4)
8
5.
Estimated
hours
of
use
40
CFR
91.805(
a)(
5)
8
6.
Date
and
time
of
each
test
attempted
40
CFR
91.805(
a)(
6)
8
7.
Results
(
if
any)
of
each
test
attempted
40
CFR
91.805(
a)(
7)
8
8.
Results
of
all
emission
testing
40
CFR
91.805(
a)(
8)
8
9.
Summary
of
all
maintenance
and/
or
adjustments
performed
40
CFR
91.805(
a)(
9)
8
10
Summary
of
all
modifications
and/
or
repairs
40
CFR
91.805(
a)(
10)
8
11
Determinations
of
noncompliance
40
CFR
91.805(
a)(
11)
8
Documents
Maintained
and
Provided
upon
EPA
Request
Items
Maintained
and
Provided
upon
EPA
Request
Regulation
Recordkeeping
Period
(
Years)

1.
Documents
in
the
procurement
process
40
CFR
91.804(
a)(
2)
8
2.
Documentation
of
all
maintenance
and
adjustments
40
CFR
91.804(
b)
8
3.
Routine
emission
test
data
40
CFR
91.121(
b)
1
4.
Standard
test
documentation
40
CFR
91.121(
b)
8
8
(
ii)
Respondent
Activities
Marine
engine
manufacturers
conducting
in­
use
testing
must
perform
the
following:

Reading
regulations
and
procedures,
have
meetings
and
conduct
training
­
Manufacturers
will
likely
have
a
number
of
individuals
involved
in
an
in­
use
test
program.
Consequently,
various
individuals
may
be
periodically
included
for
different
aspects
of
the
program.
Individuals
will
likely
periodically
review
regulations
at
Part
91
Subpart
I
for
In­
use
Test
program
requirements
as
well
as
regulations
at
Part
91
Subpart
E
for
Test
Procedures.
Meetings
to
discuss
and
schedule
procurement,
testing
and
results
will
likely
be
conducted.

Plan
Activities
­
After
EPA
notifies
a
manufacturer
of
the
need
to
conduct
in­
use
testing
on
a
specific
engine
family,
the
manufacturer
will
likely
plan
how
and
when
the
in­
use
engines
will
be
procured
and
tested.

Procure
engines
­
Within
twelve
calendar
months
after
EPA
notifies
a
manufacturer
that
in­
use
testing
must
be
performed
on
configurations
within
an
engine
family,
the
manufacturer
must
obtain
in­
use
engines
from
fleets
(
associated
with
the
manufacturer
or
not)
or
individual
owners.
In
the
procurement
process,
the
manufacturer
will
evaluate
and
obtain
documents
related
to
the
maintenance,
service
and
usage
history
of
the
engine.
Depending
on
where
the
engine
is
procured
and
where
the
test
facility
is
located,
engines
will
likely
be
shipped
or
transported
for
a
number
of
miles.
In
some
cases
manufactures
may
employ
operators
(
drivers)
to
accumulate
hours
on
engines.

Preparation
for
Testing
­
Prior
to
testing
an
engine,
the
manufacturer
may
perform
minimal
set­
to­
spec
maintenance,
and
documentation
must
be
generated
and
maintained
for
all
maintenance
and
adjustments.
The
manufacturer
will
need
to
remove
some
components
and
attach
testing
equipment
to
the
engine
while
installing
it
in
the
test
cell.

Testing
­
Emission
testing
must
be
performed
in
accordance
with
applicable
regulations.
Because
the
same
test
procedures
are
used
for
certification
and
production
line
testing,
personnel
are
familiar
with
procedures
and
documentation
requirements,
and
the
facilities
are
used
multiple
testing
programs
simultaneously.
During
testing
documents
will
be
generated
detailing
engine
information,
test
conditions
and
results.
Manufacturers
are
required,
under
certification
requirements,
to
maintain
calibration
and
maintenance
documentation
for
test
equipment.
Equipment
documentation
may
be
reviewed
and
used
during
in­
use
testing,
but
additional
test
equipment
documentation
will
not
9
likely
be
generated.

Data
Review
and
Analysis
­
After
each
test,
manufacturers
will
validate
and
review
the
test
results.
If
an
engine
fails,
the
manufacturer
must
determine
the
reason
and
report
that
information
to
EPA.
Additionally,
after
an
engine
fails,
more
engines
will
likely
need
to
procure
and
test
additional
engines.

Post
test
engine
use
­
After
testing
is
completed
on
an
engine,
it
will
be
removed
from
the
test
cell.
Depending
on
the
final
disposition
of
the
engine,
the
manufacturer
may
reinstall
components
and
return
it
to
the
field,
or
use
the
engine
for
another
purpose.

Test
Data
compilation
­
Manufacturers
will
likely
input
test
data
into
electronic
spreadsheets
to
help
analyze
results
and
perform
statistical
analysis.

Report
Writing
­
Manufacturers
will
input
engine
information,
maintenance
and
test
data
and
provide
it
in
EPA
prescribed
forms
(
which
may
be
completed
and
filed
electronically),
and
submit
them
quarterly
during
an
in­
use
test
program.

Copying,
Filing
and
Recordkeeping
­
During
and
after
a
test
program
is
competed,
manufacturers
will
keep
copies
and
originals
of
documents
related
to
the
steps
listed
above.
These
documents
will
be
maintained
in
files
at
the
manufacturers'
facilities
and/
or
provided
to
EPA
upon
request.

5.
Information
Collected
­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
AGENCY
ACTIVITIES
EPA
will
perform
the
following
activities
associated
with
the
Marine
in­
use
test
program:

1.
EPA
may
evaluate
engine
technologies
and
/
or
plan
to
target
in­
use
testing
requirements
to
address
emission
durability
concerns.

2.
Review
certification
information
and
prior
in­
use
data
(
if
applicable)
to
identify
engines
for
testing.

3.
Inform
manufacturers
of
the
need
to
conduct
in­
use
testing
on
a
family
and
/
or
configurations.

4.
Answer
manufacturers
questions.
10
5.
Review
submissions
to
verify
they
are
in
the
proper
format
and
complete,
in
accordance
with
91.805.

6.
Enter
results
(
which
are
submitted
in
electronic
format)
into
an
information
management
system
(
IMS)
which
links
test
data
and
other
relevant
information
to
certification
information
for
tracking
engine
family
emission
performance.

7.
Analyze,
compare
and
file
information
submitted
by
manufacturers
in
their
Quarterly
Report
on
Emissions
Testing
report.

8.
Periodically
EPA
may
request
additional
information
or
documentation
regarding
an
engines
procurement,
use
or
maintenance.
This
will
typically
only
be
as
spot
checks
to
verify
that
manufacturers
are
complying
with
regulations.
This
information
will
be
filed
and
retained
by
EPA.

9.
Periodically
EPA
may
perform
maintenance
or
make
enhancements
to
the
IMS
described
above.
This
IMS
is
fully
functional;
however,
some
work
on
the
in­
use
part
of
this
system
may
be
anticipated.

10.
Post
data
from
completed
test
programs
on
the
Internet.
In
2001,
EPA
will
be
developing
the
format
and
streamlining
the
process
for
posting
this
data
on
the
Internet.
The
increased
work
in
this
area
will
be
averaged
over
the
3
year
period
of
this
ICR.

11.
Analyze
requests
for
confidentiality.

5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
uses
computers,
software
and
an
IMS.
As
described
above,
data
is
submitted
to
EPA
in
electronic
format,
either
on
disk
or
via
e­
mail.
After
scanning
submitted
information,
EPA
imports
information
and
data
into
the
IMS
which
performs
automated
preliminary
checks
to
evaluate
the
submission.
Data
is
stored
on
the
IMS
where
it
may
be
used
by
EPA
staff.
Nonconfidential
information
is
provided
to
the
public
upon
request;
however,
in
the
near
future,
this
information
will
be
posted
with
other
engine
emission
data
on
the
Internet.

5(
c)
SMALL
ENTITY
FLEXIBILITY
Not
applicable.
None
of
the
respondents
are
small
entities.

5(
d)
COLLECTION
SCHEDULE
11
EPA
requires
manufacturers
of
marine
engines
to
submit
to
EPA
all
emissions
data
generated
from
their
in­
use
testing
programs
on
a
quarterly
basis.
Manufacturers,
once
receiving
notification
that
the
Agency
has
selected
an
engine
family
for
testing,
have
up
to
twelve
months
to
begin
testing
the
engine
family
and
another
twelve
months
to
complete
this
testing.
Therefore,
manufacturers
are
afforded
great
discretion
in
the
amount
of
data
that
will
be
submitted
each
quarter.
However,
manufacturers
will
be
required
to
provide
emissions
data
within
one
full
quarter
of
when
the
data
was
generated,
as
well
as
provide
a
summary
table
for
any
engine
family
that
has
completed
testing,
within
one
full
quarter
of
when
the
testing
was
completed.

Additionally,
EPA
may
require
marine
engine
manufacturers
to
submit
documents
used
in
their
engine
procurement,
maintenance
and
testing
processes
as
well
their
test­
equipment
calibration
and
maintenance
procedures
within
30
days
of
the
Agency's
request.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
ESTIMATING
RESPONDENT
BURDEN
Reference
Table
6(
a).

The
following
tables
estimate
respondent's
burden
for
this
information
collection
activity.
The
estimates
listed
below
are
averaged
values
from
the
consultation
mentioned
in
section
3(
c)
of
this
document.
These
manufacturers
provided
hourly
pay
rates
and
burden
hours
for
the
activities
described
in
this
ICR.
EPA
believes
these
rates
are
representative
of
hourly
pay
rates
and
burden
hours
for
the
marine
industry.

The
results
of
these
consultations
are
incorporated
in
this
document.
Regarding
hourly
pay
rates,
manufacturers
provided
pay
rates,
including
benefits,
overhead,
office
space
and
equipment
as
well
as
other
business
expenses.
Regarding
the
activities
associated
with
the
in­
use
program,
these
manufacturers
identified
the
hours
each
occupation
is
required
for
testing
an
engine
family.
Because
these
manufactures
have
multiple
engine
families,
and
the
test
facilities
are
often
use
for
multiple
purposes
(
such
as
research
and
development,
certification,
PLT
and
in­
use
testing),
facility
costs,
capital
/
start­
up,
operating
and
maintenance
costs
were
also
estimated
on
a
per
engine
family
basis.
By
estimating
costs
on
an
engine
family
basis,
this
burden
estimate
better
predicts
the
total
cost
to
industry
and
the
average
cost
to
individual
manufactures
since
the
number
of
families
certified
by
a
manufacturer
may
vary
from
year
to
year.

The
frequency
of
the
information
collection
is
based
on
an
12
anticipated
average
total
of
17
engine
families
being
tested
annually.
These
17
test
families
will
likely
be
divided
over
the
industry
which
results
in
approximately
1.7
test
families
per
manufacturer
per
year.
13
Annual
Hrs
&
Costs
/
Response
(
engine
family)
Av.
Tot.
Hrs
&
Costs
per
Manufr.

Legal
Technical
Manager
Clerical
Test
Cell
Sr.
Mech.
Transport
Boat
Driver
Av.
No.
of
Total
Total
In­
use
Marine
Engine
Manufacturer
Information
Collection
Activity
$
95.00
$
46.25
$
82.50
$
36.67
$
31.25
$
38.00
$
23.75
$
17.00
Responses
Hours
/
Cost
/

per
hour
per
hour
per
hour
per
hour
per
hour
per
hour
per
hour
per
hour
(
Families)
Year
Year
Read
Instructions
and/
or
Regulations
0.5
6.425
0.25
1.7
12.20
$
620.98
Plan
Activities
16
1.7
27.20
$
1,258.00
Procure
Engines
1.825
0.25
4
1.7
10.33
$
320.57
Ship
Engines
0.125
2.5
1.7
4.46
$
110.77
Engine
Maintenance
0.8
3
33
1.7
62.56
$
2,354.08
Test
Engines
8.325
38
421.5
1.7
795.30
$
14,854.65
Review
&
Analyze
Results
22.45
1.7
38.17
$
1,765.13
Enter
Data
in
Spread
Sheets
16.55
4.75
1.7
36.21
$
1,597.33
Write
Report(
s)
18.2
0.25
1.25
1.7
33.49
$
1,543.95
Copy,
File
&
Mail
Information
8.3
0.75
1.7
15.39
$
699.34
Train
Personnel
2.3125
0.75
1.7
5.21
$
228.57
Subtotal
0.5
101.3125
0.5
7.75
41
33
6.5
421.5
1.7
1040.51
$
25,353.37
Table
6(
a)
Respondent
Burden
14
6(
b)
Estimating
Respondent
Cost
(
i)
Estimating
Labor
Costs
Reference
Table
6(
a).

As
described
above,
labor
rates,
capital/
start­
up
costs
and
operating
and
maintenance
are
average
values
from
consultations
with
manufacturers
specified
in
section
3(
c).

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
Marine
engine
manufactures
primarily
incur
expenses
related
to
the
emission
test
equipment
used
for
testing
engines.
The
estimate
here
is
based
on
the
average
capital
and
operations
and
maintenance
costs
provided
by
the
manufacturers
listed
in
section
3(
c).
These
manufacturers
have
experience
with
the
in­
use
testing
program
and
were
specifically
asked
to
provide
estimates
of
these
costs.
Over
the
past
three
years,
marine
manufacturers
have
started
conducting
in­
use
testing;
therefore,
the
extra
startup
costs
are
not
included
here.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
Costs
The
capital/
start­
up
cost
estimates
from
these
manufacturers
include
costs
from
facility
construction,
test
equipment
and
computer
purchases.
The
operating
and
maintenance
(
O&
M)
costs
include
ongoing
costs
for
calibration
and
maintenance
of
equipment.
For
some
of
the
responding
manufacturers,
equipment
is
shared
between
engine
certification,
PLT
and
in­
use
testing.
Where
equipment
is
shared,
a
portion
of
the
cost
was
used
to
represent
the
percent
of
demand
by
the
in­
use
program.
Additionally,
to
facilitate
describing
the
costs
of
this
program,
the
costs
are
again
projected
on
a
per
engine
family
basis.

Prior
to
annualizing
the
average
capital/
start­
up
cost
is
$
112,980
per
engine
family,
and
the
average
O&
M
cost
is
$
24,742
per
engine
family.

(
iv)
Annualized
Capital
Costs
The
average
capital/
start­
up
per
engine
family
is
$
112,980
prior
to
annualizing.
Estimating
an
conservative
equipment
life
of
10
years
(
most
equipment
will
be
used
longer),
the
annualized
net
present
value
(
ANPV)
for
capital
and
start­
up
costs
is
$
16,086
per
engine
family.
15
Hrs
&
Costs
/
Response
Total
Hrs
&
Costs
Technical
Manager
Number
Total
Total
Annual
Agency
Information
Collection
Activity
$
57.69
$
65.38
of
Hours
/
Cost
/
per
hour
per
hour
Respon
Year
Year
Evaluate
and
plan
testing
requirements.
5
2
1
7
$
419.23
Review
information
and
identify
engines
for
testing.
2
1
17
51
$
3,073.08
Inform
manufacturers
of
testing
required.
3
1
10
40
$
2,384.62
Answer
manufacturers
questions.
2
0
10
20
$
1,153.85
Review
submissions
format
and
completeness.
0.5
0
68
34
$
1,961.54
Enter
results
into
the
IMS.
0.5
0
68
34
$
1,961.54
Analyze,
compare
and
file
information
submitted.
1
0
68
68
$
3,923.08
Periodically
request
&
review
additional
information.
2
0
2
4
$
230.77
Periodically
perform
maintenance
or
make
enhancements
to
the
IMS.
10
0
4
40
$
2,307.69
Post
data
from
completed
test
programs
on
the
Internet.
3
0
1
3
$
173.08
Analyze
requests
for
confidentiality.
1
0
2
2
$
115.38
Subtotal
30
4
varies
303
$
17,703.85
6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST
EPA
based
its
burden
estimates
on
the
recent
experience
from
the
marine
in­
use
testing
program.
EPA
uses
no
contractor
assistance
with
the
PLT
program.
Because
the
PLT
program
is
solely
administered
in
Washington,
DC,
the
hourly
wages
for
the
government
are
based
on
2000
GS
pay
schedule
for
Washington,
DC.
Hourly
rates
are
$
53.08
for
technical
staff
and
$
77.79
for
managers.
To
derive
hourly
rates,
EPA
divided
annual
compensation
estimates
by
2,080
which
is
the
number
of
hours
in
the
Federal
work
year.
EPA
then
multiplied
hourly
rates
by
the
standard
government
benefits
multiplication
factor
of
1.6.

Table
6(
c):
Annual
Agency
Burden
and
Cost
The
EPA
burden
and
cost
estimate
shown
above
is
based
on
10
manufacturers
being
required
to
conduct
in­
use
testing.
For
those
manufacturers
a
total
17
engine
families
being
tested
annually
by
the
industry.
The
quarterly
reports
for
those
families
results
in
a
total
of
68
reports
being
reviewed
annually.
Additionally,
a
high
estimate
of
hours
is
specified
for
anticipated
enhancements
to
EPA's
IMS.
These
enhancements
will
primarily
be
toward
speeding
the
process
to
post
information
on
the
Internet.
16
Av.
per
Respondent
Total
Burden
&
Cost
Respon.
Respon.
Respon.
Respon.
Number
Total
Total
In­
use
Marine
Engine
Manufacturer
Information
Collection
Activity
Hours
/
Labor
Cost
Capital
/
O
&
M
of
Hours
/
Cost
Year
Per
Year
Startup
Cost
Cost
Respon.
Year
Per
Year
Read
Instructions
and/
or
Regulations
12.20
$
620.98
10
121.98
$
6,209.78
Plan
Activities
27.20
$
1,258.00
10
272.00
$
12,580.00
Procure
Engines
10.33
$
320.57
10
103.28
$
3,205.74
Ship
Engines
4.46
$
110.77
10
44.63
$
1,107.66
Engine
Maintenance
62.56
$
2,354.08
10
625.60
$
23,540.75
Test
Engines
795.30
$
14,854.65
10
7953.03
$
148,546.53
Review
&
Analyze
Results
38.17
$
1,765.13
10
381.65
$
17,651.31
Enter
Data
in
Spread
Sheets
36.21
$
1,597.33
10
362.10
$
15,973.27
Write
Report(
s)
33.49
$
1,543.95
10
334.90
$
15,439.54
Copy,
File
&
Mail
Information
15.39
$
699.34
10
153.85
$
6,993.38
Train
Personnel
5.21
$
228.57
10
52.06
$
2,285.70
Subtotal
1040.51
$
25,353.37
$
27,346
$
42,062
10
10405.06
$
947,610.69
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Table
6(
d)

Total
Annual
Average
Hourly
Burden
=
Hours/
Respondent
x
#
of
Respondents
=
1,040.5
x
10
=
10,405
hours
per
year
Total
Annual
Average
Cost
=
Cost/
Respondent
x
#
of
Respondents
=
(
Labor
+
Cap/
SU
+
O&
M)
x
#
of
Respondents
=
($
25,353+$
27,346+$
42,062)
x
10
=
$
947,611
per
year
6(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COST
TABLES
(
i)
Respondent
Tally
Total
Annual
Hourly
Burden
=
10,405
hours
Annual
Capital
/
start­
up
Costs
=
$
273,460
Annual
Operating
&
maintenance
costs
=
$
420,620
Total
Annual
Cost
=
$
947,611
17
(
ii)
The
Agency
Tally
Number
of
Respondents
Av.
Number
of
Families
Subject
to
In­
use
Test
Total
Hours
per
Year
Total
Annual
Labor
Cost
EPA
Marine
In­
use
Program
10
17
303
hours
$
17,704
(
iv)
Variations
in
the
Annual
Bottom
Line
No
annual
variations
in
the
respondent
reporting/
recordkeeping
burden
or
cost
over
the
course
of
this
clearance
period
are
expected.

6(
f)
REASONS
FOR
CHANGE
IN
BURDEN
There
are
a
number
of
reasons
for
the
change
in
burden
since
the
last
clearance.
While
the
last
ICR
for
the
Marine
in­
use
program
was
for
the
rule
making,
the
primary
difference
is
that
capital
/
start­
up,
operating
and
maintenance
costs
have
been
included
here.
As
described
above,
because
this
is
a
newly
regulated
industry,
many
of
these
manufacturers
have
added
new
test
equipment,
and
the
additional
cost
will
be
reflected
in
the
early
years
of
this
program
until
additional
efficiencies
can
be
gained,
and
the
equipment
is
used
for
more
purposes.
It
may
be
noted
that
the
industry
burden
estimate
here
is
well
bracketed
by
the
first
year
cost
estimate
and
subsequent
year
estimate
in
the
last
ICR
for
this
program.

For
the
agency
cost,
the
primary
difference
is
the
labor
rates
used
in
this
analysis.
Previously,
clerical
support
was
included,
and
a
much
lower
technical
salary
was
used.
For
this
analysis,
it
was
assumed
technical
staff
would
perform
the
work,
and
a
higher
salary
with
the
cost
of
overhead
was
used.
Additionally,
this
estimates
more
families
will
be
tested
as
the
program
continues
to
increase
up
to
the
anticipated
17
annual
families
being
tested.
Finally,
as
mentioned
above,
additional
time
is
anticipated
over
the
next
few
years
for
making
18
enhancements
to
the
IMS.

6(
g)
BURDEN
STATEMENT
Table
6(
d)
shows
the
projected
average
annual
respondent
burden
for
the
marine
engine
in­
use
program.
For
marine
engine
manufacturers
the
reporting
burden
is
estimated
to
average
1025
hours
per
respondent
per
year.
This
estimate
includes
time
for
reading
regulations
&
guidance,
procuring
and
testing
engines,
analyzing
data,
preparing
and
submitting
reports
to
EPA.
The
recordkeeping
burden
is
estimated
to
average
15
hours
per
respondent
per
year.
This
estimate
includes
time
for
gathering
information,
and
developing
and
maintaining
records.

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.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Sandy
Farmer,
U.
S.
Environmental
Protection
Agency,
Collection
Strategies
Division
(
Mail
Code
2822),
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Include
the
EPA
ICR
number
1726.03
and
OMB
control
number
2060­
0322
in
any
correspondence.
