INFORMATION
COLLECTION
REQUEST
Marine
Engine
Manufacturers
Production
Line
Testing
Reporting
and
Recordkeeping
Requirements
(
OMB
No.
2060­
0323)

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
Manufacturers'
Production
Line
Testing
Reporting
and
Recordkeeping
Requirements
1(
b)
SHORT
CHARACTERIZATION
/
ABSTRACT
EPA
uses
the
Marine
Engine
Manufacturers'
Production
Line
Testing
Program
information
collection
and
record
keeping
to
monitor
compliance
with
exhaust
emission
standards.
Section
213(
d)
of
the
Clean
Air
Act
as
amended
(
Act)
authorizes
the
Marine
Engine
Manufacturers'
Production
Line
Testing
(
PLT)
Program
which
is
reviewed
by
the
Engine
Programs
Group
(
EPG),
Certification
and
Compliance
Division,
Office
of
Transportation
and
Air
Quality,
Office
of
Air
and
Radiation.

The
PLT
program
is
an
emission
monitoring
program
for
new
production
marine
engines
in
which
manufacturers
are
required
to
test
engines
as
they
leave
the
assembly
line,
without
direct
EPA
oversight.
The
objective
of
the
self­
audit
program
is
that
manufacturers
and
EPA
can
monitor,
with
reasonable
statistical
certainty,
whether
or
not
new
engines
are
in
compliance
with
the
Act.

The
manufacturers'
PLT
program
is
the
main
emission
monitoring
program
for
new
marine
engines.
The
Marine
Engine
Selective
Enforcement
Auditing
Program
is
typically
only
employed
if
EPA
determines
that
the
results
of
the
PLT
program
reveal
noncompliance
or
when
EPA
determines
that
other
evidence
of
suspected
noncompliance
by
the
manufacturer
exists.
SEAs
are
utilized
as
spot­
checks
to
enable
EPA
to
evaluate
testing
practices
used
by
the
manufacturer,
follow­
up
on
concerns
reported
to
EPA
and
address
configurations
not
covered
by
manufacturers
in
their
PLT
program,
if
any.
In
the
first
three
years
of
implementing
the
marine
emission
standards
and
associated
programs,
EPA
has
relied
on
PLT
data
to
monitor
compliance
and
EPA
not
issued
an
SEA
test
order
to
any
marine
engine
manufacturers.

This
information
collection
requires
manufacturers
of
marine
engines
to
generate
and
submit
to
EPA
periodic
reports
from
their
PLT
programs.
EPG
collects
this
information
and
evaluates
it
to
determine
if
production
marine
engines
comply
with
the
Act.
The
PLT
information
collected
includes
production
information,
records
for
test
equipment,
test
data,
and
statistical
analyses
to
determine
compliance
margins.
3
The
results
of
the
PLT
program
are
used
only
by
the
Office
of
Transportation
and
Air
Quality
to
verify
compliance
of
production
engines;
however,
the
exhaust
emission
data
generated
during
PLT
programs
becomes
public
information
after
the
PLT
program
is
concluded.
The
data
and
test
facility
information
from
the
PLT
program
may
be
used
by
the
EPG
to
help
evaluate
a
manufacturer's
future
model
year
Applications
for
Certification,
and
PLT
data
will
also
used
by
the
EPG
to
help
target
potential
future
engines
for
in­
use
testing.

The
information
is
collected
by
the
EPG
and
stored
in
internal
files
and
databases.
Nonconfidential
copies
of
reports
from
manufacturers
listing
PLT
results
are
available
to
the
public
upon
request,
and
will
soon
be
available
through
the
Internet.

Due
to
the
flexibilities
EPA
offers
small
volume
marine
engine
manufacturers
(
i.
e.,
exemptions
from
this
program),
approximately
ten
(
10)
marine
spark­
ignition
(
SI)
engine
manufacturers
are
subject
to
this
program
requirement.

The
EPG
estimates
that
the
annual
cost
to
industry
of
the
Marine
Manufacturers'
Production
Line
Testing
Program
resulting
from
this
information
collection
to
be
$
3,568,865
and
is
divided
between
10
manufacturers
of
spark­
ignition
marine
engines.
This
includes
estimates
for
start­
up,
capital
and
operating
and
maintenance
costs.

2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
NEED/
AUTHORITY
FOR
THE
COLLECTION
This
information
collection
is
needed
by
EPA
to
determine
whether
engine
manufacturers
are
producing
engines
that
meet
the
emission
requirements
of
the
Act.
For
new
marine
engines,
the
EPA
administers
a
two­
stage
emission
testing
program
that
includes:
pre­
production
(
Certification)
and
required
manufacturers'
production
line
testing
(
PLT).

The
PLT
program
verifies
that
prototype
designs
used
in
certification
have
been
successfully
translated
into
mass
produced
engines.
By
detecting
problems
through
the
PLT
program,
while
engines
are
still
in
production,
noncompliance
may
be
corrected
before
engines
are
introduced
into
commerce
or
may
be
corrected
soon
after
production
when
engines
are
most
easily
located.

To
ensure
that
marine
engine
manufacturers'
new
production
marine
engines
conform
with
requirements
of
the
Act
and
emission
standards
applicable
for
the
model
year
in
which
the
marine
engines
are
assembled,
the
U.
S.
Environmental
Protection
Agency
4
(
EPA)
is
authorized
to
conduct
emission
testing
of
new
production
marine
engines
through
the
PLT
program.

Section
213(
d)
of
the
Act
authorizes
EPA
to
subject
nonroad
(
including
marine)
engines
to
sections
206
and
208
of
the
Act.
Section
206(
b)
of
the
Act
authorizes
EPA
to
execute
the
marine
engine
manufacturers'
production
line
emission
testing
program.
Section
208(
a)
of
the
Act
requires
manufacturers
to
establish
and
maintain
records,
make
reports,
perform
tests,
and
provide
information
to
EPA.
Regulations
at
40
CFR
Part
91
include
standards,
test
procedures
as
well
as
PLT
requirements
applicable
to
marine
spark­
ignition
engines.

2(
b)
PRACTICAL
UTILITY
/
USERS
OF
THE
DATA
The
Office
of
Transportation
and
Air
Quality
uses
this
information
collection
to
verify
that
production
marine
engines
meet
Federal
emission
requirements.
PLT
data
helps
verify
that
preproduction
certification
engine
designs
are
translated
into
production.
The
PLT
program
provides
reasonable
statistical
certainty
that
tested
engine
models
meet
emission
standards
when
they
leave
the
assembly
line
and
are
introduced
into
commerce.

PLT
results
are
used
by
EPA
to
enforce
provisions
of
the
Act.
The
Administrator
may
use
PLT
results
as
a
basis
to
suspend
or
revoke
a
Certificate
of
Conformity
for
noncomplying
engines
and
for
a
noncomplying
engine
class.
The
EPG
may
also
use
PLT
results
to
help
evaluate
an
engine
design's
emission
compliance.

PLT
results
are
also
useful
for
the
marine
engine
emission
averaging,
banking
and
trading
program.
Because
marine
engine
manufacturers
may
change
the
applicable
family
emission
limit
(
FEL)
during
the
model
year,
manufacturers
and
EPA
can
monitor
PLT
results
to
monitor
the
compliance
margins
of
families,
and
engine
manufacturers
may
adjust
FELs
to
maximize
credit
generation
and
minimize
credit
use
throughout
the
model
year.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
NONDUPLICATION
The
Office
of
Transportation
and
Air
Quality,
CCD
is
the
only
Federal
office
which
regulates
the
emissions
of
new
production
marine
engines.
Emissions
and
Federal
sales
data
differentiated
by
EPA
engine
classes
are
not
gathered
by
other
agencies,
departments
or
program
offices.

3(
b)
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
ICR
SUBMISSION
TO
OMB
5
On
August
31,
2000,
an
announcement
that
this
ICR
is
up
for
renewal
was
made
in
the
Federal
Register
(
FR).
A
copy
of
this
FR
notice
is
attached.
No
comments
were
submitted
in
response
to
this
notice.

3(
c)
CONSULTATIONS
EPA
consulted
with
four
marine
engine
manufacturers
regarding
the
information
collection
burden
of
this
program.
These
manufacturers
have
experience
with
conducting
the
marine
PLT
program.
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
PLT
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.

SURVEYED
MANUFACTURERS
AND
CONTACTS:

EPA
consulted
with
the
following
four
marine
(
nonroad)
engine
manufacturers
regarding
the
hourly
pay
rates
associated
with
this
type
of
information
collection.
All
of
these
manufacturers
have
experience
with
the
PLT
program
and
have
submitted
data
required
by
40
CFR
Part
91.

Contact
Affiliation
Phone
Number
Michael
Tyrrell
American
Honda
Motor
Co.
Inc.
310­
783­
3419
Thomas
Pugh
Yamaha
Motor
Corporation,
USA
714­
761­
7807
Susan
Bucheger
Mercury
Marine
920­
929­
4978
Lawrence
Keller
OMC
847­
689­
5620
6
3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
The
information
collection
schedules
listed
in
this
document
are
essential
for
enforcement.
Annual
production
information
is
necessary
to
verify
the
quantities
of
engines
in
each
engine
family
for
statistically
predicting
compliance.
Because
of
engine
production
variability,
and
changes
implemented
during
the
model
year,
PLT
data
is
needed
on
a
quarterly
basis
so
the
EPG
can
evaluate
current
production
emission
levels.
If
PLT
data
were
submitted
less
frequently,
the
EPG
would
not
be
able
to
efficiently
direct
its
resources
toward
problem
engine
families
and
would
not
be
able
to
expeditiously
determine
that
production
engines
conform
to
emission
standards.

3(
e)
GENERAL
GUIDELINES
Paperwork
Reduction
Act
Guidelines
One
PLT
information
collection
activity
exceeds
the
guidelines
of
the
Paperwork
Reduction
Act,
which
provides
that
respondents
will
have
a
minimum
of
30
days
to
provide
the
requested
information.

If
PLT
results
indicate
noncompliance,
EPA
requires
that
manufacturers
notify
EPA
within
ten
days.
EPA
needs
this
requirement
to
rapidly
evaluate
PLT
program
conclusions
and
occurrences
during
the
program.
If
a
noncompliance
determination
is
reached,
testing
and
the
statistical
evaluation
would
be
completed,
the
report
to
EPA
would
need
to
be
submitted
within
10
days.
This
requirement
is
necessary
so
EPA
and
the
manufacturer
take
appropriate
action
not
to
introduce
noncomplying
engines
into
commerce.

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.

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
engine
manufacturers
(
SIC
3519).
7
4(
b)
INFORMATION
REQUESTED
(
i)
Data
items
and
recordkeeping
requirements
Report
on
these
Items:
91.509
(
e)
(
1)
Location
and
description
of
test
facility,
(
2)
Total
production
and
sample
size,
(
3)
FEL,
(
4)
Sample
selection
description,
(
5)
Description
of
test
engines,
(
6)
for
each
test,
(
i)
description
of
test
engine
including
(
A)
configuration
&
engine
family
(
B)
Year,
make,
and
build
date,
(
C)
Engine
identification
number,
(
D)
Number
of
hours
of
service
accumulation,
(
ii)
Location
and
description
of
service
accumulation,
(
iii)
Test
number,
date,
test
procedure,
initial
(
before
and
after
rounding)
and
final
test
results
for
all
tests,

(
iv)
Description
of
any
adjustment,
modification,
repair,
preparation,
maintenance,
and/
or
testing
performed
which
will
not
be
performed
on
all
other
production
engines,
(
v)
CumSum
analysis
of
PLT
results
for
each
family,
(
vi)
Other
information
requested
by
the
Administrator,
(
7)
for
each
failed
engine,
a
description
of
the
remedy
and
test
results
for
all
retests,
(
8)
Date
of
the
end
of
the
model
year
production
for
each
engine
family,
and
(
9)
A
signed
statement
and
endorsement.

Recordkeeping
items
­
1
year
record
retention
specified
at
91.504(
b)
91.504(
a)
Establish,
maintain,
and
retain
the
following:
(
1)
General
records.
Description
of
test
equipment.
(
2)
Individual
records.
Records
pertaining
to
each
test:
(
i)
date,
time,
and
location
of
each
test;
(
ii)
number
of
hours
of
service
accumulation
before
and
after
testing;
(
iii)
names
of
supervisory
personnel
involved;
(
iv)
Record
and
description
of
adjustments,
repair,
preparation
or
modification
performed;
(
v)
If
applicable,
dates
of
shipping
and
the
date
the
engine
was
received
at
the
test
facility;
(
vi)
Complete
records
of
all
emission
tests;
(
vii)
Brief
descriptions
of
any
significant
events.
8
(
ii)
Respondent
Activities
PLT
information
collection
requirements
require
manufacturers
to
perform
a
variety
of
activities.
PLT
information
will
require
manufacturers
to
plan
activities,
conduct
tests,
generate
and
submit
reports
to
EPA,
and
maintain
records.
Manufacturers
will
also
periodically
train
personnel
and
review
regulations
and
guidance
to
comply
with
PLT
requirements.

The
information
collection
activities
of
the
marine
engine
PLT
program
include
the
collection
of
projected
quarterly
production
and
annual
sales
data.
EPA
expects
that
marine
engine
manufacturers
produce
projected
annual
sales
estimates
routinely
as
a
part
of
production
planning
and
marketing
strategy.
Projected
annual
production
by
engine
family
must
be
reported
in
the
manufacturer's
application
for
certification.
For
PLT
statistical
requirements,
marine
engine
manufacturers
must
gather
and
monitor
production
information
(
based
on
engine
family)
and
conduct
numbers
of
tests
based
on
production.
Production
information
is
also
reported
to
EPA.

Based
on
production,
manufacturers
will
periodically
select
engines
from
the
assembly
line
and
ship
(
if
emission
test
equipment
is
not
at
the
plant)
the
engine
to
an
emission
test
facility.
Selected
engines
are
typically
inspected
and
service
accumulation
(
engine
operation)
is
performed
to
break­
in
the
engine
prior
to
emission
testing.

Manufacturers
are
required
to
perform
emission
tests
on
engines
and
create
documents
detailing
testing
and
the
results.
Manufacturers
are
required,
under
certification
regulations,
to
maintain
calibration
and
maintenance
documentation
for
test
equipment.
During
PLT
testing,
manufacturers
must
gather
and
provide
some
of
this
information
to
EPA,
and
some
facility
information
must
also
be
retained
for
PLT
requirements.
Before
and
after
each
test,
engine
information
and
results
typically
entered
into
databases
and
results
must
be
analyzed
for
statistical
comparison.
If
engines
fail
to
comply
with
applicable
standards,
additional
testing
must
be
performed.

Finally,
manufacturers
must
write
brief
reports
listing
the
results
of
PLT
testing
and
maintain
records
of
their
PLT
programs.
Manufacturers
must
submit
a
quarterly
report
of
PLT
results
which
includes
testing
information.
If
engines
fail
to
comply
with
standards
during
an
PLT
program,
manufacturers
must
submit
failed
engine
reports.
Manufacturers
must
maintain
PLT
records
for
a
period
of
one
year
after
the
conclusion
of
the
PLT
program
for
that
model
year.
These
records
must
include
test
equipment
as
well
as
test
engine
information.
Manufacturers
may
maintain
these
records
in
any
format.
9
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
AGENCY
ACTIVITIES
The
EPG
performs
the
following
activities
with
information
collected.
1.
Review
&
compare
sales
data,
2.
Check
report
format
&
completeness,
3.
Input
reports
and
data
into
the
information
management
system
(
IMS),
4.
Analyze
and
compare
results
with
standards
and
FELs
5.
File
submitted
information
6.
Periodically
answer
manufacturers
questions
7.
Infrequently
request
and
review
additional
information
8.
From
time
to
time
perform
maintenance
and/
or
make
enhancements
to
the
IMS.
9.
Post
nonconfidential
data
from
completed
test
programs
on
the
Internet.
10.
Infrequently
analyze
requests
for
confidentiality.

5(
b)
Collection
Methodology
and
Management
EPA
uses
the
marine
engine
PLT
program
to
ensure
with
reasonable
statistical
certainty
that
production
engines
meet
the
emission
standards
to
which
their
prototypes
were
certified.
PLT
data
is
submitted
in
electronic
format
for
EPA
and
manufacturer
convenience.
The
format
used
facilitates
easy
incorporation
into
the
engine
IMS
maintained
by
EPG.
Because
this
IMS
links
certification,
PLT
and
in­
use
data
by
engine
family,
data
quality
and
compliance
with
applicable
standards
and
FELs
are
most
rapidly
checked.
In
the
near
future,
EPG
will
be
enhancing
the
IMS
to
more
rapidly
post
emission
data
to
the
Internet.
Currently,
EPG
responds
to
individual
requests
for
data
from
the
IMS.
The
IMS
has
automatic
functions
to
restrict
and
maintain
confidential
information
so
it
is
not
inadvertently
released.

5(
c)
Small
Entity
Flexibility
Not
applicable.
None
of
the
respondents
are
small
entities.

5(
d)
Collection
Schedule
PLT
information
is
generally
reported
quarterly
by
manufacturers.
However,
information
about
failing
engines
or
engine
family
noncompliance
may
be
submitted
at
different
intervals.
The
ongoing
PLT
requirement
is
that
reports
must
be
submitted
within
30
days
of
the
end
of
each
quarter.

EPA
requires
that
manufacturers
notify
EPG
within
two
10
working
days
if
the
results
of
PLT
testing
indicate
noncompliance.
EPA
needs
this
requirement
to
rapidly
evaluate
PLT
program
conclusions
and
occurrences
when
noncomplying
engines
are
being
introduced
into
commerce.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
ESTIMATING
RESPONDENT
BURDEN
Reference
Chart
6(
a)
Marine
spark­
ignition
manufacturers
Chart
6(
a)
provides
an
average
annual
respondent
burden
for
each
information
collection
activity.
This
estimated
is
based
on
average
activity
estimates
provided
by
the
surveyed
manufactures
listed
above.
These
manufacturers
estimated
the
activity
hours
and
costs
of
the
PLT
program
for
an
engine
family.
This
estimate
is
also
based
on
recent
certification
data.
In
the
1999
and
2000
model
years,
a
total
of
approximately
150
engine
families
(
which
could
have
been
subject
to
PLT
requirements)
have
been
certified
each
year
by
10
manufacturers.
Consequently,
the
average
number
of
responses
(
families)
each
year
is
approximately
1.5
per
manufacturer.
11
Annual
Hrs
&
Costs
/
Response
(
engine
family)
Av.
Tot.
Hrs
&
Costs
per
Manufr.

Legal
Technical
Manager
Clerical
Test
Cell
Assembler
Transport
Service
No.
of
Total
Total
Manufacturer
Information
Collection
Activity
$
100.00
$
46.25
$
82.50
$
36.67
$
31.25
$
20.00
$
23.75
$
25.00
Responses
Hours
/
Cost
/

per
hour
per
hour
per
hour
per
hour
per
hour
per
hour
per
hour
per
hour
(
Families)
Year
Year
Gather
/
maintain
sales
data.
1.925
0.25
0.25
8.5
20.61
$
1,009.99
Read
Instructions
&
Regulations
56.55
0.25
8.5
482.80
$
22,406.53
Projecting
Testing
Needs
and
Planning
Test
Schedules
11.075
0.25
0.25
8.5
98.39
$
4,607.09
Engine
Selection
&
Shipping
3.2
0.25
1.25
0.25
0.25
8.5
44.20
$
1,640.50
Engine
Inspection
&
Service
Accumulation
0.5
5.5
8.5
51.00
$
1,657.50
Testing
3
11.75
8.5
125.38
$
4,300.47
Data
Entry
&
Analysis
7.95
0.5
8.5
71.83
$
3,281.18
Report
Writing
&
Submission
0.25
12.3
0.25
0.25
8.5
110.93
$
5,301.17
Gathering
Information
1.425
0.25
8.5
14.24
$
638.12
Training
6.25
0.75
8.5
59.50
$
2,656.25
Recordkeeping
/
Filing
5.3875
0.5
0.25
8.5
52.17
$
2,316.29
Other
tasks
(
test
equipment
calibration,
engine
repair,
etc.)
0.25
92.5
1.25
8.5
799.00
$
24,934.22
Subtotal
0.25
109.8125
1
2
110.75
1.5
0.25
1.5
8.5
1930.03
$
74,749.31
Chart
6(
a)
ANNUAL
RESPONDENT
BURDEN
AND
COST
12
6(
b)
ESTIMATING
RESPONDENT
COSTS
Reference
Chart
6(
a).

(
i)
Estimating
Labor
Cost
As
described
in
section
3(
c),
the
costs
associated
with
the
PLT
program
described
here
are
based
on
estimates
from
marine
engine
manufactures
with
PLT
experience.
The
hourly
pay
rates
shown
in
chart
6(
a)
are
the
average
rates
provided
by
the
manufacturers
with
the
occupations
performing
applicable
activities.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
surveyed
manufactures
provided
capital
/
start­
up,
operating
and
maintenance
cost
figures.
Because
this
is
a
newly
regulated
industry,
over
the
past
few
years
manufacturers
have
constructed
facilities
and
installed
equipment
for
testing
and
reporting
as
required
by
the
PLT
program.

(
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
PLT
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
$
101,963
per
engine
family,
and
the
average
O&
M
cost
is
$
18,673
per
engine
family.

(
iv)
Annualized
Capital
Costs
The
average
capital/
start­
up
per
engine
family
is
$
101,963
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
$
14,517
per
engine
family.
13
Hrs
&
Costs
/
Response
Total
Hrs
&
Costs
per
Family
Technical
Manager
Number
Total
Total
Annual
Agency
Information
Collection
Activity
for
Each
Engine
Family
$
53.08
$
73.79
of
Hours
/
Cost
/
per
hour
per
hour
Respon
Year
Year
Review
&
Compare
Sales
Data
0.25
0
1
0.25
$
13.27
Check
Report
Format
&
Completeness
0.2
0
4
0.8
$
42.47
Input
Reports
&
Data
Into
the
IMS
0.25
0
4
1
$
53.08
Analyze
&
Compare
Results
to
Standards
&
FELs
0.5
0.25
4
3
$
179.95
File
Information
Submitted
0.2
0
4
0.8
$
42.47
Periodically
answer
manufacturers
questions.
0.5
0.25
1
0.75
$
44.99
Infrequently
request
&
review
additional
information.
0.25
0
1
0.25
$
13.27
Periodically
perform
maintenance
or
make
enhancements
to
the
IMS.
1
0
1
1
$
53.08
Post
data
from
completed
test
programs
on
the
Internet.
0.25
0.1
1
0.35
$
20.65
Infrequently
analyze
requests
for
confidentiality.
0.25
0.1
1
0.35
$
20.65
Subtotal
3.65
0.7
22
8.55
$
483.88
6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST
EPA
based
its
burden
estimates
on
experience
from
information
collection
activities
with
the
marine
PLT
program
in
recent
years.
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.
14
Av.
per
Respondent
Total
Burden
&
Cost
Respon.
Respon.
Respon.
Respon.
Number
Total
Total
Manufacturer
Information
Collection
Activity
Hours
/
Labor
Cost
Capital
/
O
&
M
of
Hours
/
Cost
Year
Per
Year
Startup
Cost
Cost
Respon.
Year
Per
Year
Gather
/
maintain
sales
data.
20.61
$
1,009.99
10
206.13
$
10,099.95
Read
Instructions
&
Regulations
482.80
$
22,406.53
10
4828.00
$
224,065.31
Projecting
Testing
Needs
and
Planning
Test
Schedules
98.39
$
4,607.09
10
983.88
$
46,070.89
Engine
Selection
&
Shipping
44.20
$
1,640.50
10
442.00
$
16,405.00
Engine
Inspection
&
Service
Accumulation
51.00
$
1,657.50
10
510.00
$
16,575.00
Testing
125.38
$
4,300.47
10
1253.75
$
43,004.69
Data
Entry
&
Analysis
71.83
$
3,281.18
10
718.25
$
32,811.77
Report
Writing
&
Submission
110.93
$
5,301.17
10
1109.25
$
53,011.67
Gathering
Information
14.24
$
638.12
10
142.38
$
6,381.20
Training
59.50
$
2,656.25
10
595.00
$
26,562.50
Recordkeeping
/
Filing
52.17
$
2,316.29
10
521.69
$
23,162.94
Other
tasks
(
test
equipment
calibration,
engine
repair,
etc.)
799.00
$
24,934.22
10
7990.00
$
249,342.19
Total
1930.03
$
74,749.31
$
123,395
$
158,721
10
19,300.31
$
3,568,643.10
6(
d)
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN
AND
COSTS
Based
on
certification
records
for
1999
and
2000,
EPA
estimates
that
10
marine
engine
manufacturers
may
have
up
to
an
industry
total
of
85
engine
families
subject
to
the
PLT
reporting
and
recordkeeping
requirements.

Table
6(
d)

Total
Annual
Hourly
Burden
=
Hours/
Respondent
x
#
of
Respondents
=
1,930
x
10
=
19,300
hours
per
year
Total
Annual
Cost
=
Cost/
Respondent
x
#
of
Respondents
=
(
Labor
+
Cap/
SU
+
O&
M)
x
#
of
Respondents
=
($
74,749+$
123,395+$
158,721)
x
10
=
$
3,568,865
per
year
6(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COST
TABLES
(
i)
Respondent
Tally
Total
Annual
Hourly
Burden
=
19,300
hours
Annual
Capital
/
start­
up
Costs
=
$
1,233,950
Annual
Operating
&
maintenance
costs
=
$
1,587,210
Total
Annual
Cost
=
$
3,568,865
15
Total
per
Family
Annual
Total
Total
Total
Number
Total
Total
Annual
Agency
Information
Collection
Activity
Hours
/
Cost
/
of
Hours
/
Cost
/
Year
Year
Families
Year
Year
Review
&
Compare
Sales
Data
0.25
$
13.27
85
21.25
$
1,128.02
Check
Report
Format
&
Completeness
0.8
$
42.47
85
68
$
3,609.65
Input
Reports
&
Data
Into
the
IMS
1
$
53.08
85
85
$
4,512.06
Analyze
&
Compare
Results
to
Standards
&
FELs
3
$
179.95
85
255
$
15,296.01
File
Information
Submitted
0.8
$
42.47
85
68
$
3,609.65
Periodically
answer
manufacturers
questions.
0.75
$
44.99
85
63.75
$
3,824.00
Infrequently
request
&
review
additional
information.
0.25
$
13.27
85
21.25
$
1,128.02
Periodically
perform
maintenance
or
make
enhancements
to
the
IMS.
1
$
53.08
85
85
$
4,512.06
Post
data
from
completed
test
programs
on
the
Internet.
0.35
$
20.65
85
29.75
$
1,755.20
Infrequently
analyze
requests
for
confidentiality.
0.35
$
20.65
85
29.75
$
1,755.20
Subtotal
8.55
$
483.88
85
726.75
$
41,129.88
6(
d)(
ii)
The
Agency
Tally
Number
of
Respondents
Av.
Number
of
Families
Subject
to
PLT
Total
Hours
per
Year
Total
Annual
Labor
Cost
EPA
Marine
PLT
Program
10
85
727
hours
$
41,130
(
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
PLT
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
16
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.

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.
Finally,
the
previous
estimate
reflected
the
early
years
of
regulation
with
a
lower
number
of
families
subject
to
PLT.
This
estimate
projects
more
families
requiring
PLT
reporting,
and
consequently
EPA
having
to
spend
more
time
reviewing
the
reports.

6(
g)
BURDEN
STATEMENT
Table
6(
d)
shows
the
projected
average
annual
respondent
burden
for
the
marine
engine
PLT
program.
For
marine
engine
manufacturers
the
reporting
burden
is
estimated
to
average
1857
hours
per
respondent
per
year.
This
estimate
includes
time
for
reading
regulations
&
guidance,
selecting
and
testing
engines,
analyzing
data,
preparing
and
submitting
reports
to
EPA.
The
recordkeeping
burden
is
estimated
to
average
73
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
17
(
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
1725.03
and
OMB
control
number
2060­
0323
in
any
correspondence.
