Supporting
Statement
for
Information
Collection
Request
Transition
Program
for
Equipment
Manufacturers
EPA
Number
1826.02
OMB
Control
Number
2060­
0369
40
CFR
89.102
March
2001
Certification
and
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
Transition
Program
for
Equipment
Manufacturers,
EPA
Number
1826.02,
OMB
Number
2060­
0369.

1(
b)
Short
Characterization
In
August
1998,
EPA
promulgated
new
emissions
standards
(
Tier
I
standards)
for
engines
under
37
kW,
and
tightened
existing
standards
(
Tier
II
standards)
for
engines
above
37
kW.
During
the
rulemaking
process,
some
equipment
manufacturers
expressed
concerns
about
delays
in
notification
from
engine
manufacturers
about
changes
in
engine
design
resulting
from
the
new
regulations.
Changes
in
engine
design
can
create
problems
in
fitting
the
engine
to
the
equipment,
forcing
equipment
manufacturers
to
redesign
their
products.
Consequently,
equipment
manufacturers
would
be
unable
to
sell
the
volume
of
equipment
they
planned
for
until
the
new
equipment
designs
are
available.
In
an
effort
to
address
these
concerns
by
providing
original
equipment
manufacturers
(
OEMs)
with
some
flexibility
in
complying
with
the
regulations,
EPA
created
the
Transition
Program
for
Equipment
Manufacturers
(
TPEM).
Under
the
program,
OEMs
are
allowed
to
use
a
number
of
noncompliant
engines
(
uncertified
engines
rated
below
37
kW
or
Tier
I
engines
rated
at
or
above
37
kW)
in
their
equipment
for
up
to
seven
years
after
the
effective
date
of
the
new
standards.
Post­
manufacture
marinizers
can
also
take
advantage
of
the
provisions
of
this
program.
Participation
in
TPEM
is
voluntary.

Participating
OEMs
and
engine
manufacturers
who
provide
the
noncompliant
engines
to
the
OEMs
are
required
to
keep
records
and
submit
reports
of
their
activities
under
the
program.
This
information
is
collected
and
used
by
the
Engine
Programs
Group
(
EPG),
Certification
and
Compliance
Division
(
CCD),
Office
of
Transportation
and
Air
Quality
(
OTAQ),
Office
of
Air
and
Radiation
(
OAR),
U.
S.
Environmental
Protection
Agency
(
EPA).
The
information
could
also
be
used
by
the
Office
of
Enforcement
and
Compliance
Assurance
and
the
Department
of
Justice
for
enforcement
purposes.
Non­
confidential
business
information
could
be
disclosed
to
importers,
end
users,
trade
associations,
environmental
groups,
and
the
public.
The
information
is
usually
submitted
in
hard
copy,
and
will
be
stored
in
a
database
and
EPG's
files.

It
has
been
estimated
that
a
total
of
548
manufacturers
will
respond
to
this
collection
with
an
approximate
cost
of
$
1,923,792.
3
2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
Pursuant
to
Section
206(
a)
of
the
Clean
Air
Act
(
42
USC
7521),
vehicle
and
engine
manufacturers
may
not
legally
introduce
their
product
into
US
commerce
unless
EPA
has
certified
that
their
vehicles
and
engines
comply
with
applicable
emission
standards.
Section
213(
d)
extends
that
prohibition,
codified
at
40
CFR
89.1003(
a),
to
nonroad
engines.

To
alleviate
the
unintended
impact
of
the
August
1998
emission
regulations
on
OEMs,
EPA
created
TPEM.
The
program
allows
OEMs
to
install
noncompliant
engines
in
their
equipment
for
a
limited
period
of
time
provided
they
comply
with
the
requirements
described
in
this
information
collection.

TPEM
also
provides
protection
for
engine
manufacturers
so
that
they
can
sell
engines
that
do
not
comply
with
current
regulations
to
OEMs
under
the
provisions
of
TPEM.
The
program
is
codified
at
40
CFR
89.102.
A
copy
of
section
89.102
is
attached.
Engine
manufacturers
are
also
required
to
report
the
number
of
engines
they
sold
under
TPEM
and
their
purchasers
annually.
The
purpose
of
these
reports
is
to
independently
verify
the
information
provided
by
OEMs
in
their
reports
and
prevent
misuse
of
the
program.

2(
b)
Practical
Utility/
Users
of
the
Data
The
information
collected
under
TPEM
is
used
to
verify
compliance
and
prevent
abuse
or
misuse
of
the
program.
If
compliance
issues
are
identify,
information
submitted
under
the
program
could
be
used
for
enforcement
purposes.

The
information
is
received
and
used
by
EPG/
CCD/
OTAQ/
OAR.
Non­
confidential
portions
of
the
information
might
be
used
by
importers,
end
users,
environmental
groups,
members
of
the
public,
state
and
local
governments
or
other
federal
agencies
such
as
Customs.

3.
Nonduplication,
Consultations
and
Other
Collection
Criteria
3(
a)
Nonduplication
4
This
program
is
unique
to
EPA.
No
other
program
or
Agency
collects
this
information.
Because
of
its
specialized
(
and
sometimes
confidential)
nature,
the
information
collected
is
not
available
from
any
other
source.
Some
of
the
information
requested
­­
such
as
actual
production
volumes­­
is
claimed
by
manufacturers
as
confidential
business
information
(
CBI);
therefore,
EPA
can
only
obtain
it
from
manufacturers.
Participation
in
the
program
is
voluntary.

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
December
29,
2000
(
65
FR
83004).
No
comments
were
received.
A
copy
of
the
FR
notice
is
attached.

3(
c)
Consultations
EPA
consulted
less
than
ten
past
respondents
regarding
this
information
collection
burden.

Contact:
Mr.
Gary
Gauthun
Company:
Northwest
Products
Phone:
253­
854­
1915
Contact:
Ms.
Lisa
Maeser
Company:
Hardy
Diesels
and
Equipment,
China
Diesel
Imports
Phone:
800­
341­
7027
3(
d)
Effects
of
Less
Frequent
Collection
Except
for
the
engine
manufacturer's
reports,
each
item
of
information
requested
is
collected
only
once.
More
information
could
be
requested
is
deemed
necessary
for
compliance/
enforcement
purposes.
Collecting
that
information
less
frequently
will
mean
not
to
request
information
at
all,
making
it
impossible
to
verify
compliance.

Engine
manufacturers
are
required
to
submit
an
annual
production
report
under
the
requirements
of
the
Certification
Program.
To
avoid
duplication
of
reported
information,
the
5
information
requested
in
this
information
collection
is
submitted
in
those
reports.
It
is
also
easier
for
the
engine
manufacturer
to
gather
the
information
at
the
end
of
the
engine
model
year
rather
than
coming
back
later
to
gather
information
from
different
years
and
production
cycles.

3(
e)
General
Guidelines
This
section
is
not
applicable.
No
Paperwork
Reduction
Act
guideline
is
exceeded.

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.

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

4.
Respondents
and
Information
Requested
4(
a)
Respondents/
NAICS
Codes
Respondents
are
manufacturers
of
nonroad
equipment
and
engines
within
the
following
North
American
Industry
Classification
System
codes:

333618
Other
Engine
Equipment
Manufacturing
333111
Farm
Machinery
and
Equipment
Manufacturing
33312
Construction
Machinery
Manufacturing
4(
b)
Information
Requested
6
TPEM
consists
of
four
main
"
allowances"
or
"
exemptions":

$
Percent­
of­
production
allowance
$
Small
volume
allowance
$
Existing
inventory
allowance
and
replacement
engines
$
Hardship
relief
OEMs
can
claim
only
one
of
the
first
two
allowances
(
percent­
of­
production
or
small
volume)
per
power
category.
They
can
use
the
existing
inventory
allowance
concurrently
with
the
other
three
allowances.
If
an
OEM
is
requesting
hardship
relief,
it
might
be
able
to
use
either
allowance
after
the
hardship
relief
period
is
over,
depending
on
the
agreement
that
the
company
reaches
with
EPA.

OEMs
must
demonstrate
compliance
with
the
provisions
of
the
allowance
they
have
selected
for
each
power
category
by
submitting
the
corresponding
calculations
and
by
keeping
adequate
records
of
all
exempt
equipment.
A
list
of
power
categories
is
attached.

OEMs
electing
to
participate
in
TPEM
must
also
assure,
in
writing,
to
the
engine
manufacturer
supplying
the
noncompliant
engines
that
these
engines
are
going
to
be
used
only
in
accordance
with
the
provisions
of
TPEM.
Engine
manufacturers
need
that
written
assurance
to
protect
themselves
against
the
liabilities
found
in
40
CFR
89.1003.

Some
foreign
OEMs
prefer
to
have
a
representative
in
the
United
States
to
keep
track
of
the
exempt
equipment
imported
for
sale
in
the
US
market
and
to
keep
records.
EPA
allows
those
OEMs
to
designate
a
person
(
or
company)
through
whom
all
of
the
OEM's
exempt
equipment
must
be
imported
to
ensure
that
the
limits
imposed
by
the
allowances
are
not
exceeded.
Once
in
the
country,
the
equipment
can
be
sold
to
any
party.
Manufacturers
electing
to
designate
a
representative
must
sign
a
sole
agent
agreement
with
that
person
or
company
and
notify
EPA
of
their
selection.
A
sample
letter
designating
a
representative
is
attached.

Although
the
regulations
do
not
require
it,
EPA
suggests
that
OEMs
(
or
engine
manufacturers)
attach
a
label
to
the
noncompliant
engines
used
under
the
provisions
of
TPEM.
This
label
identifies
the
engine
as
being
exempt
from
compliance
with
current
EPA
regulations
under
the
provisions
of
TPEM.
OEMs,
7
importers
and
engine
manufacturers
have
welcomed
this
suggestion
as
it
prevents
unnecessary
problems
at
the
time
of
importation.
To
be
legally
imported,
an
engine
needs
to
be
certified
and
labeled
accordingly.
Unlabeled
engines
might
be
retained
by
Customs
until
the
importer
can
proof
that
the
engine
is
certified
(
and
the
label
is
obscured
or
missing)
or
exempt
from
compliance.
By
labeling
the
engine,
OEMs
let
Customs
know
that
the
engine
is
covered
by
TPEM's
provisions
right
away.
Attached
is
a
sample
label.

OEMs
must
keep
records
of
the
production
of
all
pieces
of
equipment
manufactured
under
the
provisions
of
TPEM.
These
records
must
be
kept
until
December
31
of
the
year
after
the
last
year
in
which
any
of
the
allowances
are
used
by
the
company.
OEMs
must
make
these
records
available
to
the
Agency
upon
request.
An
OEM
with
inaccurate
or
inadequate
records
would
be
subject
to
civil
penalties
under
existing
law.

(
i)
Data
Items
8
Table
A
Information
Items
Requested
from
Equipment
Manufacturers
Information
Item
Reference
in
Regulations
Letter
designating
a
representative
Optional
Letter
to
the
engine
manufacturer
89.102(
g)

Calculation
to
verify
compliance
89.102(
e)(
1)

Table
B
Application
for
Hardship
Relief
OEMs
who
feel
that
TPEM
does
not
provide
a
viable
alternative
for
them
to
comply
with
EPA
emissions
regulations
on
a
timely
manner,
and,
as
a
consequence,
will
face
serious
economic
hardship,
can
apply
for
hardship
relief.

Information
Item
Reference
in
Regulations
Statement
that
the
applicant
is
not
also
the
engine
manufacturer
89.102(
f)(
2)

Evidence
showing
that
the
conditions
causing
the
impending
violation
are
substantially
not
the
applicant's
fault
89.102(
f)(
3)

Evidence
showing
that,
if
relief
is
not
granted,
the
applicant
will
face
serious
economic
hardship
89.102(
f)(
4)

Demonstration
that
no
other
allowance
will
help
to
avoid
the
impending
violation
89.102(
f)(
5)
9
Table
C
Information
Items
Requested
from
Engine
Manufacturers
Every
year,
within
30
days
of
the
end
of
the
model
year,
engine
manufacturers
supplying
noncompliant
engines
under
the
provisions
of
TPEM
must
submit
a
report
with
the
following
information:

Information
Item
Reference
in
Regulations
Number
of
engines
produced
by:

Engine
model
89.125(
b)

Purchaser
or
shipping
destination
89.125(
b)

Other
categories
that
EPA
may
require
89.125(
b)

Table
D
Recordkeeping
Requirements
OEMs
must
keep
records
of
all
exempt
equipment.
OEMs
and/
or
their
representatives
must
keep
sufficient
records
to
demonstrate
compliance
until
at
least
two
full
years
after
the
last
year
in
which
the
allowances
are
available
for
each
power
category
(
89.102(
e)(
2)).
These
records
must
be
made
available
to
EPA
upon
request.

Information
Item
Reference
in
Regulations
Equipment
and
engine
model
numbers
89.102(
e)(
2)

Serial
numbers
89.102(
e)(
2)

Dates
of
manufacture
89.102(
e)(
2)

Engine
rated
power
89.102(
e)(
2)

Sufficient
information
to
verify
compliance
89.102(
e)(
2)
10
(
ii)
Respondent
Activities
Activities
carried
out
by
participating
OEMs
are
as
follows:

$
Review
the
regulations;
OEMs
may
contact
EPA
for
further
guidance
$
Select
an
allowance
per
power
category
and
decide
what
equipment
to
exempt
$
Notify
EPA
of
participation
(
optional)

$
Send
a
letter
to
the
engine
manufacturer
$
Count
exempt
equipment
as
it
is
produced
$
Make
corresponding
calculations
to
ensure
compliance
with
the
requirements
of
the
selected
allowance
$
Submit
calculations
and
actual
production
data
to
EPA
$
Retain
and
maintain
records,
and
submit
them
upon
request
In
addition
to
these
activities,
OEMs
who
wish
to
designate
a
representative,
need
to:

$
Sign
a
sole­
agent
agreement
with
their
selectee
$
Send
a
letter
to
EPA
notifying
the
agency
of
their
selection
OEMs
who
wish
to
apply
for
hardship
relief
will:

$
Submit
their
request
in
writing
describing
their
situation,
and
$
Provide
proof
that
they
will
face
serious
economic
hardship
if
relief
is
not
granted
Engine
manufacturers
participating
in
TPEM
as
providers
of
noncompliant
engines:

$
Receive
requests
for
engines
and
supply
them
(
customary
business
practice)

$
Gather
information
about
who
is
requesting
and
purchasing
the
noncompliant
engines
$
Report
to
EPA
their
sales
under
TPEM
by
engine
model
and
purchaser
$
Keep
records
5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
11
5(
a)
Agency
Activities
EPA
spends
a
significant
amount
of
time
answering
questions
and
providing
guidance
to
OEMs,
importers,
engine
manufacturers
and
other
interested
parties
about
the
program.
EPA
reviews
and
stores
the
information
provided
by
OEMs
or
their
representatives,
and
will
process
their
reports
when
they
start
coming
in.
The
information
contained
in
the
reports
will
be
used
to
verify
compliance
and
for
enforcement
purposes,
as
needed.
The
agency
also
conducts
investigations
if
there
is
reason
to
believe
an
OEM
or
its
representative
is
misusing
the
program
or
defaulting
its
requirements.

In
the
near
future,
EPA
will
set
up
a
database
to
store
the
information
received.
EPA
is
also
finalizing
a
fact
sheet
to
provide
further
guidance
to
respondents.

5(
b)
Collection
Methodology
and
Management
Currently,
EPA
receives
information
from
respondents
both
in
electronic
format
and
in
hard
copy.
Letters
designating
a
representative
must
be
sent
in
hard
copy
since
EPA
needs
an
original
signature
for
legal
reasons.
Once
the
database
is
in
place,
EPA
will
store
respondent's
information
both
in
hard
copy
and
electronic
format.

5(
c)
Small
Entity
Flexibility
TPEM
is
particularly
useful
to
small
businesses
as
it
provides
them
with
additional
time
to
comply
with
EPA
emission
regulations.
Actually,
the
format
of
the
program
is
based
on
recommendations
made
by
the
panel
convened
for
the
August
1998
rule
under
the
Small
Business
Regulatory
Enforcement
Fairness
Act
of
1996
(
SBREFA).
The
small
volume
allowance
is
intended
to
address
the
needs
of
small
businesses
with
a
limited
product
line.
The
percent­
of­
production
allowance
requires
OEMs
to
use
certified
engines
in
a
portion
of
their
production.
The
small
volume
allowance
eliminates
that
requirement
and
allows
OEMs
to
exempt
up
to
200
pieces
of
equipment
without
using
certified
engines
at
all.

The
information
being
requested
is
the
minimum
needed
to
maintain
the
integrity
of
the
program.
Further
measures
to
simplify
reporting
for
small
businesses
do
not
appear
prudent
or
necessary.
12
5(
d)
Collection
Schedule
Information
submitted
by
OEMs
is
collected
only
at
the
beginning
and
at
the
end
of
their
participation
in
the
program.
At
the
beginning,
they
notify
EPA
of
their
selection
of
a
representative,
if
applicable,
and/
or
their
participation
in
the
program,
if
they
wish
to.
At
the
end
of
the
program,
they
must
submit
their
calculations
(
no
later
than
December
31
of
the
final
year
in
which
they
use
the
allowances).

Engine
manufacturers,
however,
need
to
submit
their
reports
every
year.

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

6(
a)
Estimating
Respondent
Burden
Burden
estimates
were
taken
from
the
previous
ICR
and
adjusted
to
reflect
comments
from
fewer
than
10
respondents
consulted
by
EPA.

All
burden
estimates,
including
those
associated
with
onetime
preparations
such
as
signing
a
sole­
agent
agreement,
were
annualized.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
To
estimate
labor
costs
for
the
equipment
manufacturing
industry,
EPA
used
the
mean
hourly
wage
estimates
developed
by
the
Bureau
of
Labor
Statistics
(
BLS)
for
the
Industrial
and
Machinery
Equipment
Industry
(
SIC
Major
Group
35).
The
hourly
rates
estimated
by
BLS
for
management
occupations
(
SOC
11­
0000)
is
$
36.04.
The
mean
hourly
rate
for
Production,
Planning
and
Expediting
Clerks
(
SOC
43­
5061)
is
$
16.26.

To
estimate
labor
costs
for
the
engine
manufacturing
industry,
EPA
used
cost
estimates
provided
in
consultations
with
the
industry
($
75
per
hour
for
managers/
engineers
and
$
38
per
13
hour
for
clerical
support).
The
labor
cost
rate
provided
by
the
Bureau
of
Labor
Statistics
was
not
used
because
this
is
an
average
for
all
manufacturing
industries
that
do
not
reflect
the
actual
cost
for
this
particular
industry,
which
is
much
higher.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)
Costs
Operation
and
maintenance
costs
associated
with
TPEM
include
phone
calls,
photocopying,
postage
expenses
and
diskettes.
Diskettes
may
be
used
by
manufacturers
to
keep
their
records.

No
capital
costs
are
associated
with
participation
in
this
program.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
Costs
There
are
no
capital
or
start­
up
costs
associated
with
this
ICR.
O&
M
costs
are
discussed
in
section
6(
b)(
ii).

(
iv)
Annualizing
capital
costs
There
are
no
capital
costs
associated
with
this
ICR.

6(
c)
Estimating
Agency
Burden
Government
burden
and
cost
(
Table
3)
is
based
on
the
time
devoted
to
the
program
by
a
GS­
12
Environmental
Protection
Specialist
($
25.47/
hr),
and
a
GS­
13
Attorney
($
30.29/
hr).
The
hourly
rates
were
obtained
from
the
Office
of
Personnel
Management.
Burden
associated
with
one­
time
tasks
such
setting
up
a
database
have
been
annualized.

The
time
allocated
to
process
reports
is
minimal
since
none
of
the
allowances
available
at
this
time
will
expire
within
the
next
three
years.
However,
EPA
expects
that
a
few
OEMs
will
end
their
participation
in
the
program
early;
therefore,
28
hours
have
been
allocated
to
process
their
reports,
plus
17
hours
to
process
engine
manufacturers'
reports
(
0.5
hour
per
manufacturer).
14
EPA
estimates
that
it
will
conduct
21
audits
in
the
next
three
years
(
7
per
year)
on
equipment
manufacturers
to
ensure
compliance.
O&
M
costs
for
these
audits
include
an
average
of
$
75
per
company
in
phone
calls,
faxes,
mail
and
other
expenses
and
two
trips
at
a
cost
of
$
650
each,
annualized.

Other
O&
M
costs
include
phone
calls,
faxes,
postage,
diskettes
to
store
information
and
other
expenses
incurred
in
contacting
respondents
and
costs
associated
with
distribution
of
the
fact
sheet
and
other
written
guidance.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Since
OEMs
are
not
required
to
notify
EPA
of
their
participation
in
the
program,
it
is
difficult
to
assess
the
number
of
respondents.
In
the
previous
ICR,
EPA
estimated
that
out
of
a
total
of
640
OEMs,
282
were
eligible
for
the
small
volume
allowance
and
233
for
the
percent
of
production
allowance.
However,
burden
and
cost
calculations
included
only
the
burden
and
cost
of
the
percent
of
production
allowance.
In
this
ICR,
we
are
keeping
the
original
participation
estimates;
however,
we
are
incorporating
burden
estimates
for
all
participating
OEMs
(
515).

Based
on
the
number
of
engine
manufacturers
that
have
contacted
us
requesting
information
about
the
program
and
the
information
we
have
received
from
some
equipment
manufacturers,
EPA
estimates
that
a
total
of
33
engine
manufacturers
are
willing
to
participate
in
the
program.
15
6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
Number
of
Respondents:
548
Number
of
Activities:
13
Total
Hours
Per
Year:
66,647
Total
Labor
Cost
Per
Year:
$
1,917,254
Total
Annual
Capital
Costs:
0
Total
Annual
O&
M
Costs:
$
18,611
Total
Costs:
$
1,935,889
(
ii)
The
Agency
Tally
Number
of
Respondents:
548
Number
of
Activities:
9
Total
Hours
Per
Year:
904
Total
Labor
Cost
Per
Year:
$
23,725
Total
Annual
Capital
Costs:
0
Total
Annual
O&
M
Costs:
$
1,448
Total
Costs:
$
2,562,264
6(
f)
Reasons
for
change
in
burden
Burden
estimates
have
increased
from
9,352
hours
in
the
previous
ICR
(
only
one
hour
was
requested
in
the
OMB­
83i
form)
to
65,223
in
this
renewal
for
several
reasons.
First,
the
previous
ICR
included
the
burden
associated
with
participation
in
the
percent­
of­
production
allowance
only.
In
this
ICR,
EPA
is
incorporating
the
burden
associated
with
the
small
volume
16
allowance
and
hardship
relief.
Pleaser
refer
to
section
6(
d)
for
further
details.
Second,
EPA
has
done
a
better
job
in
accounting
for
the
different
tasks
that
OEMs
need
to
accomplish
to
participate
in
TPEM.
Third,
EPA
has
added
burden
estimates
for
some
voluntary
tasks
that
were
not
in
effect
when
the
previous
supporting
statement
was
written.

6(
g)
Burden
Statement
The
average
annual
burden
associated
with
participation
in
the
Transition
Program
for
Equipment
Manufacturers
is
of
146
hours
per
equipment
manufacturer
or
post­
manufacture
marinizer
and
72
per
engine
manufacturer.

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,
U.
S.
Environmental
Protection
Agency,
Collection
Strategies
Division
(
Mail
Code
2822),
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
DC
20460­
0001;
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
1826.02
and
OMB
control
number
2060­
0369
in
any
correspondence.
17
Sample
letter
designating
a
representative
ABC
COMPANY
404
Equipment
Manufacturing
Dr.
My
Town,
MY
Country
tel.:
111­
555­
222;
fax:
111­
555­
2223
January
12,
2000
Ms.
Nydia
Yanira
Reyes­
Morales
Engine
Programs
Group
US
Environmental
Protection
Agency
1200
Pennsylvania
Avenue,
NW
Mail
Code
6403J
Washington,
DC
20460
Dear
Ms.
Reyes­
Morales:

We
manufacture
tractors
equipped
with
engines
rated
between
19
kW
and
75
kW.
We
have
designated
XYZ
Importers
to
represent
us
in
the
Transition
Program
for
Equipment
Manufacturers
(
TPEM).
Ms.
Linda
Jones
is
our
contact
at
XYZ
Importers.
She
can
be
contacted
at:

33205
Nonroad
Equipment
Lane
Their
City,
Their
State
12345
phone:
222­
333­
4444
fax:
222­
333­
5555
I
certify
that
XYZ
Importers
is
the
only
entity
I
am
authorizing
under
TPEM
to
introduce
into
US
Commerce
ABC
Company's
equipment
using
engines
rated
between
19
kW
and
37
kW.
I
understand
that
I
or
my
representative
can
use,
in
any
single
power
category,
either
the
percent­
of­
production
allowance
or
the
small
volume
allowance,
but
not
both.
Also,
if
applicable,
I
can
use
the
existing
inventory/
replacement
engine
allowance.
I
also
understand
that
I
cannot
get
allowances
for
different
factories
under
my
control.
I
also
certify
that
I
have
read
and
understood
the
provisions
of
TPEM
set
forth
in
40
CFR
89.102.

Sincerely,

Marcos
Pérez
Vázquez
President
cc:
Ms.
Linda
Jones
18
Effective
Dates
per
Power
Category
Engine
Power
Category
Tier
Model
Year
Standard
Is
First
Effective
kW
<
8*
1
2000
(
hp
<
11)
2
2005
8

kW
<
19
1
2000
(
11

hp
<
25)
2
2005
19

kW
<
37
1
1999
(
25

hp
<
50)
2
2004
37

kW
<
75
(
50

hp
<
100)
1
1996
2
2004
3
2008
1
1996
75

kW
<
130
2
2003
(
100

hp
<
175)
3
2007
1
1996
130

kW
<
225
2
2003
(
175

hp
<
300)
3
2006
1
1996
225

kW
<
450
2
2001
(
300

hp
<
600)
3
2006
1
1996
450

kW

560
2
2002
(
600

hp

750)
3
2006
>
560
kW
(>
750
hp)
1
2000
2
2006
*

equal
to
or
less
than
>
greater
than
<
less
than
19
Sample
Label
EMISSION
CONTROL
INFORMATION
engine
model:
zzzzz
engine
family:
YABCL23.
ABCDEF
displacement:
23.150
Liters
model
year:
2000
This
nonroad
engine
is
exempt
from
the
requirements
of
40
CFR
Part
89
under
the
provisions
of
the
Transition
Program
for
Equipment
Manufacturers
set
forth
in
40
CFR
89.102.

For
further
information
about
this
ABC
COMPANY
engine,
contact
XXX
Office
at
555­
444­
3333
Made
in
My
Country
AB
C
Company
Trademark
