Supporting
Statement
for
Information
Collection
Request
Certification
and
Averaging,
Banking,
and
Trading
Program
for
Non­
road
Spark­
ignition
Engines
At
or
Below
19
Kilowatts
40
CFR
90
February
2001
Engine
Programs
Group
Certification
&
Compliance
Division
Office
of
Transportation
and
Air
Quality
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
­
2­
1.
Identification
of
the
Information
Collection
1
(
a)
Title
and
Number
of
the
Information
Collection
Application
for
Engine
exhaust
emission
Certification
and
Averaging,
Banking,
and
Trading
for
New
Nonroad
spark­
ignition
(
SI)
Engines
at
or
below
19
kilowatts.
(
OMB
#
2060­
0338)

1(
b)
Short
Characterization
This
request
is
a
renewal
of
an
existing
ICR
(
OMB#
2060­
0338)
which
covers
applications
for
engine
emission
certification
and
the
Averaging,
Banking,
and
Trading
(
ABT)
Program
by
manufacturers
of
SI
nonroad
engines.
The
information
to
be
collected
consists
of
descriptions
of
engine
emission
control
systems,
test
results
and
sales
information.
This
data
is
reviewed
to
verify
that
necessary
tests
have
been
performed
and
the
manufacturers'
product
lines
meet
emission
standards.
ABT
credits
for
an
engine
family
are
calculated
based
on
the
emission
values
achieved
during
certification
testing.
Manufacturers
electing
to
participate
in
the
ABT
are
required
to
submit
information
regarding
the
calculation,
actual
generation
and
usage
of
credits
in
the
certification
application,
and
final
report.
These
reports
are
used
for
certification
and
enforcement
purposes.
Manufacturers
will
also
maintain
records
for
eight
years
on
the
engine
families
included
in
the
program.
The
information
collection
requested
in
this
supporting
statement
applies
to
both
non­
handheld
engines
and
handheld
engines.
Both
categories
are
jointly
referred
to
as
"
nonroad
SI
engines"
throughout
this
statement.

It
has
been
estimated
that
a
total
of
54
manufacturers
will
respond
to
this
collection
with
an
approximate
cost
of
$
5,675,508.00.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
collection
Under
Title
II
of
the
Clean
Air
Act,
(
42
USC
7521
et
seq.),
EPA
is
charged
with
issuing
certificates
of
conformity
for
those
vehicles
and
engines
that
comply
with
applicable
emission
standards.
Such
certificates
must
be
issued
before
vehicles
or
engines
are
legally
introduced
into
commerce.
To
ensure
compliance
with
these
statutes,
EPA
reviews
product
information
and
manufacturers'
test
results;
EPA
also
tests
some
vehicles
and
engines
to
confirm
manufacturers'
results.

EPA's
emission
certification
programs
are
statutorily
mandated;
the
agency
does
not
have
discretion
to
cease
these
functions.
Under
Section
206(
a)
of
the
CAA
(
42
USC
7521):

The
Administrator
shall
test,
or
require
to
be
tested
in
such
manner
as
he
deems
appropriate,
any
new
motor
vehicle
or
new
motor
vehicle
engine
submitted
by
a
manufacturer
to
determine
whether
such
vehicle
or
engine
conforms
with
the
regulations
prescribed
under
§
202
of
this
Act.
If
such
vehicle
or
engine
conforms
to
such
regulations,
the
Administrator
shall
issue
a
certificate
of
conformity
upon
such
terms,
and
for
such
period
(
not
in
excess
of
one
year)
as
he
may
prescribe.

EPA
also
conducts,
under
40
CFR
90.201,
an
Averaging,
Banking,
and
Trading
program.
This
program
is
one
of
many
regulatory
features
designed
to
enhance
the
compliance
flexibility
for
and
reduce
the
burden
on
the
affected
engine
manufacturers,
without
compromising
the
expected
emissions
benefit
derived
from
­
3­
these
emissions
standards.

2(
b)
Practical
Utility/
Users
of
the
Data
EPA
uses
certification
information
to
verify
that
the
proper
engines
have
been
selected
and
that
the
necessary
testing
has
been
performed
to
assure
that
each
engine
complies
with
emission
standards.
Once
the
engines
have
been
manufactured,
EPA
uses
the
information
to
support
various
enforcement
actions
including
assembly
line
audits
and
in­
use
compliance
testing.
The
Averaging,
Banking
and
Trading
Program
allows
manufacturers
to
generate
emission
credits.
Under
averaging,
a
manufacturer
could
certify
one
or
more
engine
families
within
its
product
line
at
levels
above
the
emission
standard,
provided
the
increased
emissions
are
offset
by
emission
reductions
from
one
or
more
families
certified
below
the
standard.

The
information
will
be
received
and
used
by
the
Engine
Programs
Group
(
EPG),
Certification
and
Compliance
Division,
Office
of
Transportation
and
Air
Quality,
Office
of
Air
and
Radiation.
Non­
confidential
portions
of
the
information
submitted
to
EPG
are
also
used
by
importers,
engine
users,
and
environmental
groups.

3.
Nonduplication,
Consultations
and
Other
Collection
Criteria
3(
a)
Nonduplication
The
information
requested
under
this
ICR
is
required
by
statute.
Because
of
its
specialized
nature,
and
the
fact
that
the
certification
data
must
be
submitted
to
EPA
prior
to
the
start
of
production,
the
information
collected
is
not
available
from
any
other
source.
Participation
in
the
ABT
program
is
voluntary.
Information
requested
under
the
ABT
programBsuch
as
actual
sales
volumeB
is
usually
confidential
in
nature;
therefore,
it
is
not
available
from
other
sources.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
This
ICR
package
is
a
renewal
of
an
existing
ICR.
Public
notice
of
this
ICR
was
given
on
December
11,
2000
(
65
FR
77373);
no
comments
were
received.

3(
c)
Consultations
EPA
consulted
the
following
manufacturers
regarding
this
information
collection
burden.

Contact:
Mr.
Allan
Smitz
Company:
Briggs
and
Stratton
Phone:
414­
259­
5589
Contact:
Mr.
Bob
Alsip
Company:
Suzuki
Phone:
714­
996­
7040
Contact:
John
Fischer
Company:
Fuji
Robin
Phone:
630­
350­
8200
Contact:
Dick
Schoessow
Company:
Kohler
Engine
company
Phone:
920­
565­
3381
­
4­
Contact:
Dave
Corey
Company:
Kawasaki
Phone:
949­
776­
0400
3(
d)
Effects
of
Less
Frequent
Collection
Major
product
changes
typically
occur
at
the
start
of
a
model
year
and
these
new
products
need
to
be
certified
every
year.
For
these
reasons,
a
collection
frequency
of
less
than
a
model
year
is
not
possible
for
the
certification
program.
Manufacturers
are
required
to
submit
an
end­
of
the
year
report
and
a
final
report
for
their
ABT
program.
EPA
believes
that
a
lower
reporting
frequency
would
not
allow
accurate
monitoring
of
the
ABT
program.

3(
e)
General
Guidelines
According
to
40
CFR
90.209
certification
and
ABT
related
records
must
be
maintained
for
eight
years.
However,
"
records
may
be
retained
as
hard
copy
or
reduced
to
microfilm,
ADP
film,
etc.,
depending
on
the
manufacturer's
record
retention
procedure,
provided
that
in
every
case
all
the
information
contained
in
the
hard
copy
is
retained."

Manufacturers
are
required
to
submit
confidential
business
information
such
as
sales
projections
and
certain
sensitive
technical
descriptions
(
Please
see
section
4(
b)(
i)
for
reference).
This
information
is
kept
confidential
in
accordance
with
the
Freedom
of
Information
Act,
EPA
regulations
at
40
CFR
Part
2,
and
class
determinations
issued
by
EPA's
Office
of
General
Counsel.
Also,
non­
proprietary
information
submitted
by
manufacturers
is
held
as
confidential
until
the
specific
vehicle
or
engine
to
which
it
pertains
is
available
for
purchase.

3(
f)
Confidentiality
Manufacturers
are
allowed
to
assert
a
claim
of
confidentiality
over
information
provided
to
EPA.
Confidentiality
is
provided
in
accordance
with
the
Freedom
of
Information
Act
and
EPA
regulations
at
40
CFR
Part
2.
For
further
detail,
refer
to
section
3(
e).

3(
g)
Sensitive
Questions
No
sensitive
questions
are
asked
in
this
information
collection.

4.
Respondents
and
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
are
manufacturers
or
importers
of
nonroad
SI
engines
at
or
below
19
kW.
The
following
Standard
Industrial
Classification
codes
are
associated
with
this
information
collection:

3519
Internal
Combustion
Engines,
Not
Elsewhere
Classified
3523
Farm
Machinery
and
Equipment
3531
Construction
Machinery
and
Equipment
4(
b)
Information
Requested
All
manufacturers
must
describe
their
product(
s).
This
information
is
­
5­
organized
by
"
engine
family"
groups
expected
to
have
similar
emission
characteristics.
Manufacturers
must
also
retain
records.
The
burden
for
a
given
engine
family
may
be
reduced
after
the
model's
first
production
year,
because
data
from
previous
years
can
be
carried
over
when
no
significant
changes
have
occurred.
This
is
called
a
carry­
over
application.

(
i)
Data
Items
Tables
A
and
B
list
data
items
that
manufacturers
must
submit
in
their
certification
applications
and
ABT
reports.
Tables
C
and
D
outline
recordkeeping
requirements.

Table
A
Data
Items
Requested
for
Certification
Information
Item
Regs
Statement
of
compliance
90.114(
d)

Engine
design
90.116(
d)

Engine
displacement
90.116(
b)

Engine
family
description
90.116(
b)

Useful
life
90.105
Projected
sales
90.115(
d)(
2)

Deterioration
factors
90.104(
h)

Certification
procedure
90.116
Table
B
Data
Items
Requested
for
ABT
Intent
to
include
this
specific
engine
family
in
the
ABT
program
90.208(
a)

Declaration
that
participation
in
this
program
will
not
cause
the
applicable
emission
standard
to
be
exceeded
(
have
negative
credit
balance)
90.208(
a)

Family
emission
limit
90.208(
a)(
2)

Projected
applicable
production
volumes
for
the
model
year
90.208(
a)(
3)

Values
required
to
calculate
credits
90.208(
a)(
4)

Projected
number
of
credits
generated/
used
90.208(
a)(
5)

If
credits
are
generated,
the
designated
use
of
the
credits
involved
or
if
credits
are
used,
the
source
of
those
credits
90.208(
a)(
5)(
i)

Table
C
Recordkeeping
Requirements
B
Certification
Program
­
6­
General
records
Application
copy
90.121(
1)

History
of
engine
90.121(
3)

Description
of
emission
tests
90.121(
iii)

Emission
data
90.121(
b)

Table
D
Recordkeeping
Requirements
B
Banking
and
Trading
Program
EPA
engine
family
90.209(
a)(
1)

FEL
90.209(
a)(
2)

Power
rating
90.209(
a)(
3)

Purchaser
and
destination
90.209(
a)(
5)

Actual
quarterly
and
cumulative
applicable
production/
sales
volume
90.209(
b)(
2)

Value
required
to
calculate
credits
90.209(
b)(
3)

Resulting
type
and
number
of
credits
generated/
required
90.209(
b)(
4)

How
and
where
credit
surpluses
are
dispersed
90.209(
b)(
5)

How
and
through
what
means
credit
deficits
are
met
90.209(
b)(
6)

(
ii)
Respondent
Activities
The
type
of
activities
a
manufacturer
would
do
to
certify
an
engine
family
are
as
follows:

$
review
the
regulations
and
the
guidance
document
$
develop
engine
family
groups
$
test
engines
for
compliance
with
emission
standards
$
develop
deterioration
factors
$
gather
emission
data
$
submit
the
Application
for
Certification
$
retain
and
maintain
records,
and
submit
them
upon
Administrator's
request
$
submit
an
annual
production
report
Those
manufacturers
electing
to
participate
in
the
AB&
T
program
will
carry
out
the
following
activities:

$
Pre­
certification
Activities:

$
Familiarization
with
the
ABT
program
provisions
­
7­
$
Determine
which
engine
families
will
participate
in
ABT.

$
Project
applicable
production
volumes
for
the
model
year
for
all
engine
families.

$
Submit
ABT
information
with
the
certification
application
$
Monitor
production
volumes
and
engine
sales
$
Develop
and
submit
end­
of­
year
reports
$
Develop
and
submit
final
reports
$
Store,
file,
and
maintain
information
required
to
be
maintained
5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA's
emission
certification
activity
is
spent
reviewing
applications
and
verifying
that
the
correct
engines
have
been
tested
and
that
the
engines
pass
the
standards.
A
significant
portion
of
EPA's
ABT
activity
is
spent
reviewing
end
of
the
year
ABT
reports
from
the
manufacturer.
These
reports
are
reviewed
for
accuracy
and
entered
into
a
database.

5(
b)
Collection
Methodology
and
Management
EPA
currently
makes
extensive
use
of
computers
in
evaluating
information
from
engine
manufacturers.
Most
manufacturers
use
the
electronic
format
provided
by
EPA
to
submit
their
reports.
Once
the
diskette
or
email
containing
the
report
is
received,
the
application
is
entered
into
the
Database
and
reviewed
for
completeness.
If
the
manufacturer
chooses
to
submit
the
application
in
hard
copy,
then
EPA
manually
enters
the
information
in
our
database.

5(
c)
Small
Entity
Flexibility
A
small
volume
manufacturer
whose
production
of
equipment
subject
to
regulation
doesn't
exceed
10,000
engines
that
will
be
installed
in
nonhandheld
equipment
or
25,000
engines
that
will
be
installed
in
handheld
equipment
are
exempt
from
Phase
2
certification
requirements,
depending
on
the
class,
for
up
to
eight
years
after
the
applicable
date
of
implementation.
These
engines
may
continue
to
meet
less
stringent
Phase
1
standards
in
effect
since
1997.
ABT
requirements
do
not
apply
to
Phase
1
engines.
The
handheld
and
nonhandheld
criteria
are
outlined
in
90.103(
a)(
2).
Under
the
ABT
program
included
in
this
ICR,
the
information
being
requested
is
considered
to
be
the
minimum
needed
to
effectively
conduct
and
maintain
integrity
of
the
required
program.
Further
measures
to
simplify
reporting
for
small
businesses
do
not
appear
prudent
or
necessary.

5(
d)
Collection
Schedule
Certification
information
must
be
submitted
annually
for
each
model
year.
The
ABT
program
requires
two
diffent
collections
per
year:
one
report
90
days
after
the
end
of
the
model
year
and
a
second
report
270
days
after
the
end
of
the
model
year.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Refer
to
Table
1
&
2
for
details.

6(
a)
Estimating
Respondent
Burden
­
8­
Burden
estimates
were
taken
from
a
survey
of
seven
small
nonroad
sparkignition
engine
manufacturers.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Burden
Hours
The
estimated
cost
for
labor
is
$
75
per
hour
for
engineers/
technicians
and
$
38
per
hour
for
clerical
support.
In
deriving
these
costs,
EPA
used
cost
estimates
provided
in
consultations
with
the
industry.
The
labor
cost
rate
provided
by
the
Bureau
of
Labor
Statistics
($
35.75/
hour
and
$
17.15/
hour
respectively)
was
not
used.
This
is
an
average
for
all
manufacturing
industries
that
do
not
reflect
the
actual
cost
for
the
engine
manufacturing
industry,
which
is
much
higher
($
75.00/
hour
and
$
38.00/
hour).

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
Capital
costs
are
associated
with
setting
up
an
emissions
testing
laboratory.
Operation
and
Maintenance
costs
associated
with
programs
covered
by
this
information
collection
include
costs
to
maintain
the
emissions
testing
laboratory
such
as
test
gases,
and
diskettes,
photocopying
and
postage
expenses.
Diskettes
and
email
are
used
by
manufacturers
to
submit
their
electronic
reports.

(
iii)
Capital/
Start
Up
Costs
Capital
costs
are
associated
with
setting
up
an
emissions
test
laboratory
which
entails
buying
gas
analyzers,
control
equipment,
and
an
engine
dynamometer.
There
were
no
new
capital
and
start­
up
costs
associated
with
the
renewal
of
this
ICR.

(
iv)
Annualizing
capital
costs
The
annualized
capital
costs
associated
with
this
ICR
are
the
costs
to
maintain
an
emission
laboratory
with
fuel
and
calibration
gases.

6(
c)
Estimating
Agency
Burden
Government
cost
is
based
on
GS­
13
salary
for
professional
engineers
($
26.82/
hr)
and
on
GS­
7
salary
for
clerical
support
($
12.71).
The
hourly
rates
were
obtained
from
the
Office
of
Personal
Management.
(
Refer
to
Table
3
&
4
)

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
EPA
receives
about
460
nonroad
small
SI
certification
applications
from
54
manufacturers
each
year.
Out
of
the
460
applications,
approximately
82%
(
380)
are
carry­
over
engine
family
applications,
and
only
17%
are
new
family
applications
(
80).
In
addition,
manufacturers
submit
about
193
running
changes
to
the
applications.
On
average,
each
manufacturer
submits:

$
1.5
applications
for
new
families
(
no
carry
overs)

$
7.0
carry
over
applications
$
3.5
running
changes
$
12.0
submissions
in
total
(
new
applications,
carry
overs,
and
running
changes
combined.

Applications
are
approximately
equally
divided
between
nonhandheld
and
handheld
category
of
engines.
­
9­
Handheld
criteria
is
defined
at
90.103(
a)(
2).
If
a
piece
of
equipment
does
not
meet
the
criteria
at
90.103(
a)(
2),
then
the
engine
which
goes
with
it
is
considered
non­
handheld.
It
is
expected
that
all
54
manufacturers
will
participate
in
the
AB&
T
program,
which
will
require
108
reports.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
Table
5
Total
Estimated
Respondent
Burden
And
Cost
Summary
Program
Number
of
Respon
Number
of
Activities
Total
Hours
Per
Year
Total
Labor
Cost
Per
Year
Total
Annual
Capital
Costs
Total
Annual
O&
M
Costs
Nonroad
cert
54
8
36,747
2,435,346.00
0
3,240,162.00
Nonroad
ABT
54
7
10,989
824,175.00
0
0.00
(
ii)
The
Agency
Tally
Table
6
Total
Estimated
Agency
Burden
And
Cost
Summary
Program
Number
of
Respon
Number
of
Activities
Total
Hours
Per
Year
Total
Labor
Cost
Per
Year
Total
Annual
Capital
Costs
Total
Annual
O&
M
Costs
Cert
54
8
1767
47,391
0
0
ABT
54
4
78.4
2,103
0
0
6(
f)
Reasons
for
change
in
burden
Table
7
Change
in
Burden
Program
Previous
ICR
(
Hrs)
Current
ICR
(
hrs)
Change
Category
­
10­
Certification
48,335
36,747
­
11,588
adjustment
ABT
5,650
10,989
5,339
adjustment
The
burden
hours
associated
with
the
certification
program
have
decreased
because
EPA
is
performing
ongoing
streamlining
activities
such
as
electronic
submission
process
that
simplifies
the
application
process.
Also,
the
number
of
carry­
over
applications
which
take
less
time
to
submit
was
underestimated
on
the
previous
ICR.
However,
the
cost
of
the
certification
program
has
increased
from
$
3,177,223
to
$
5,675,508
because
the
previous
ICR
did
not
account
for
the
Operation
and
Maintenance
costs
associated
with
maintaining
an
emissions
testing
laboratory.
The
ABT
program
burden
has
changed
because
more
accurate
survey
numbers
have
been
used
for
this
ICR
renewal.

6(
g)
Burden
Statement
The
total
burden
associated
with
the
ABT
and
certification
programs
combined
is
47,736
hours
annually,
an
average
of
884
hours
annually
per
respondent.
These
estimates
include
time
to
review
applicable
regulations
and
guidance
documents,
generate
and
gather
the
necessary
information,
submit
applications
and
reports,
and
maintain
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
Director,
Collection
Strategies
Division,
Office
of
Environmental
Information
(
OEI),
U.
S.
Environmental
Protection
Agency,
(
Mail
Code
2822),
1200
Pennsylvania
Ave.
NW,
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
1695.07and
OMB
control
number
2060­
0338
in
any
correspondence.
