ICR
SUPPORTING
STATEMENT
Part
A.

Section
1:
Identification
of
the
Information
Collection
1(
a)
Title
Of
The
Information
Collection
Emission
Defect
Information
Reports
(
DIRs)
and
Voluntary
Emission
Recall
Reports
(
VERRs)
for
manufacturers
of
on­
highway
light­
duty
motor
vehicles
including
lig
ht­
duty
trucks.
Previous
OMB
Control
Number:
2060­
0048.

1(
b)
Short
Characterization/
Abstract
This
is
an
extension
request
for
a
currently
approved
collection,
EPA
IC
R
No.
282.10,
which
is
being
split
into
two
collections.
This
one
is
for
on­
hig
hway,
light­
duty
motor
vehicles
and
is
designated
ICR,
No.
1916.01.
This
chang
e
is
being
made
because
the
previous
ICR
included
other
types
of
engines
and
equ
ipment
covered
by
other
regulations
which
have
a
different
universe
of
responden
ts.
This
will
simplify
the
ICR
and
allow
more
accurate
assessment
of
the
burden
for
this
activity.

Some
manufacturers
of
motor
vehicles
are
required
to
submit
two
differen
t
reports
under
40
CFR
Part
85,
Subpart
T.
These
reports
are
only
required
by
r
egulation
where
certain
conditions
involving
emission
defects
or
voluntary
recal
ls
occur.
The
Agency
projects
the
cost
to
the
public
of
this
ICR
to
be
1256
hou
rs
and
$
85,007.
These
reports
are
required
by
regulation
and
are
submitted
by
v
ehicle
manufacturers
when
it
becomes
aware
of
"
defects"
or
after
it
initiates
a
voluntary
emissions
related
recall.
The
information
is
usually
sent
by
the
manu
facturers
to
the
Agency,
reviewed
for
compliance,
summarized,
and
stored
at
the
Agency's
headquarters.

The
"
defect
information
report"
(
DIR)
contains
data
regarding
the
class
or
engine
family
and
number
of
vehicles
on
which
a
defect
has
been
found,
and
a
description
of
the
defect
and
its
effects
on
vehicle
performance
and
emissions.
The
Agency
uses
the
DIR
to
help
identify
emission­
related
defects
or
classes
of
vehicles
which
may
not
comply
with
federal
emissions
standards.
DIRs
are
summa
rized
for
access
by
Agency
program
personnel
for
planning
and
monitoring
purpose
s
and
to
assist
the
public
in
response
to
inquiries.

The
"
voluntary
emission
recall
report"
(
VERR)
contains
data
on
voluntary
recall
campaigns
conducted
by
manufacturers,
including
the
procedures
used
by
t
he
manufacturers
to
conduct
voluntary
recall
campaigns,
the
identification
of
ve
hicles
or
engines
affected
by
the
campaign,
and
the
repair
to
be
completed
on
re
called
vehicles.
Progress
or
quarterly
updates
of
the
voluntary
recalls
track
t
he
number
of
vehicles
repaired.
The
Agency
uses
the
VERRs
and
progress
reports
to
ensure
that
manufacturers
are
following
acceptable
procedures
when
conducting
recalls
and
to
track
the
progress
and
effectiveness
of
voluntary
recall
campaig
ns.
VERRs
are
summarized
for
access
and
use
by
program
personnel
for
planning
a
nd
monitoring
purposes.
The
summaries
are
also
posted
on
the
Agency's
Internet
web
site
to
assist
the
public.

Section
2:
Need
For
and
Use
of
the
Collection
2(
a)
Need/
Authority
For
The
Collection:

The
Clean
Air
Act
and
applicable
regulations
require
that
new
motor
vehi
cles
must
be
certified
by
EPA
before
they
can
be
sold
in
the
United
States.
In
the
certification
process,
manufacturers
must
demonstrate
that
those
vehicles
be
ing
produced
will
comply
with
the
applicable
emissions
standards
throughout
thei
r
useful
lives.
Although
manufacturers
demonstrate
emission
control
system
dura
bility
before
certification,
EPA's
own
in­
use
testing
has
shown
that
many
vehicl
es
exceed
the
emissions
standards
during
their
useful
lives
for
a
variety
of
rea
sons.
Those
reasons
include
defects
in
materials
or
design
or
other
factors.
W
hen
in­
use
testing
shows
that
a
substantial
number
of
properly
maintained
and
us
ed
vehicles
produced
by
a
manufacturer
do
not
conform
to
emission
standards,
the
manufacturer
is
required
to
recall
the
vehicles.
A
manufacturer
may
also
initi
ate
a
"
voluntary
emissions
recall"
to
remedy
an
emissions
non­
conformity.
Secti
on
208(
a)
of
the
Clean
Air
Act
provides
the
Administrator
with
the
authority
to
require
a
manufacturer
to
"
make
reports
and
provide
information
the
Administrato
r
may
reasonably
require
to
determine
whether
the
manufacturer
or
other
person
h
as
acted
or
is
acting
in
compliance"
with
Parts
A
and
C
of
Title
II
of
the
Clean
Air
Act
and
regulations
thereunder.
Regulations
implementing
such
reporting
re
quirements
have
been
promulgated
in
"
Emission
Defect
Reporting
Requirements,"
40
CFR
""
85.1901­
85.1909.
Copies
of
these
sections
have
been
attached.

2(
b)
Practical
Utility/
Users
Of
The
Data:

Defect
Information
Reports
(
DIRs)
by
the
manufacturers
alert
EPA's
Offic
e
of
Mobile
Sources
(
OMS)
staff
to
the
existence
of
emission­
related
defects
on
certain
classes
of
vehicles
and
engines.
Such
defects
may
lead
to
exceedances
o
f
emission
standards
and
ultimately
to
the
need
for
an
emissions
recall.
OMS
st
aff
use
the
DIRs
to
target
potentially
non­
conforming
classes
for
future
testing
and
to
monitor
compliance
with
the
Clean
Air
Act
and
applicable
regulations.
D
IRs
frequently
lead
to
recalls
(
directly
or
indirectly)
by
the
manufacturers.

Voluntary
Emissions
Recall
Reports
(
VERRs)
by
the
manufacturers
are
used
to
notify
OMS
staff
when
a
manufacturer
initiates
a
recall
campaign.
The
VERRs
and
VERR
progress
update
reports
are
used
by
OMS
staff
to
determine
whether
a
m
anufacturer
is
acting
in
accordance
with
the
Clean
Air
Act
and
to
examine
and
mo
nitor
the
effectiveness
of
the
recall
campaign.
Measures
of
effectiveness
inclu
de
the
procedures
the
manufacturer
is
following
to
notify
the
vehicle
owners
and
provide
timely
repairs,
as
well
as
the
percentage
of
vehicle
owners
that
are
re
sponding
to
recall
notification
and
the
number
of
vehicles
that
are
being
repair
ed.
Review
and
monitoring
of
the
DIRs
and
VERRs
by
OMS
staff
provides
a
deterre
nt
effect
to
help
ensure
compliance
by
the
manufacturers
with
the
Clean
Air
Act
and
the
applicable
regulations.

Section
3:
Non­
duplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Non­
duplication:

There
is
no
other
known
source
for
the
information
contained
in
the
DIRs
and
VERRs.
Collecting
the
information
on
a
case­
by­
case
basis
would
involve
co
nsiderably
more
industry
and
government
resources.
OMS
is
the
only
federal
offi
ce
that
regulates
the
exhaust
emissions
of
motor
vehicles.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB:

A
copy
of
the
Agency's
notice
in
the
Federal
Register
on
May
21,
1999,
s
oliciting
comments
on
the
information
collection
prior
to
submission
to
OMB
is
a
ttached.
No
comments
were
received.

3(
c)
Consultations:

In
updating
this
information
collection
request,
EPA
consulted
with
two
manufacturers,
Volvo
and
Subaru,
which
submit
such
reports.
Other
major
submitt
ers
of
information,
Chrysler
Corporation
and
Ford
Motor
Company
were
consulted
p
reviously
regarding
this
information
collection
activity.
The
consultations
wit
h
the
manufacturers'
representatives
included
burden
hours,
employee
mix
in
the
responses,
and
the
clarity
of
the
requirements.
The
following
industry
represen
tative
were
contacted
for
this
renewal:

Greg
Buffalino,
Volvo
(
201)
768­
7300
John
Rugge,
Subaru
(
609)
488­
8415
Gordon
Masura
and
George
Londy,
Ford
(
313)
322­
9662
Bob
Shaw,
Chrysler
(
313)
576­
5591
3(
d)
Effects
Of
Less
Frequent
Collection:

This
information
is
only
collected
when
certain
circumstances
which
pote
ntially
involve
non­
compliance
with
statutory
and
regulatory
requirements
trigge
r
these
events.
Thus,
manufacturers
are
required
to
provide
it
only
when
potent
ial
violations
exist.
Less
frequent
collection
of
DIRs
and
VERRs
would
allow
po
tential
violations
to
go
undetected.
Follow­
up
progress
reports
on
voluntary
re
calls
are
collected
quarterly
for
six
quarters.
These
progress
reports
or
updat
es
are
used
to
monitor
the
progress
of
a
recall
campaign,
observing
the
promptne
ss
with
which
vehicles
subject
to
the
recall
receive
the
remedial
repair.
Exper
ience
has
shown
that
the
quarterly
reporting
interval
is
generally
the
minimum
i
nterval
for
effective
oversight
of
a
recall
campaign.

3(
e)
General
Guidelines:

The
only
circumstances
under
which
information
may
be
collected
from
one
manufacturer
more
frequently
than
quarterly
would
be
if
new
defects
or
other
fa
ctors
trigger
new
DIRs
or
VERRs.
DIRs
and
VERRs
are
required
by
regulation
to
b
e
submitted
not
more
than
15
days
after
an
emissions­
related
defect
is
found
(
or
in
the
case
of
a
VERR,
within
15
days
after
vehicle
owner
notification)
to
affe
ct
25
or
more
vehicles
of
the
same
model
year
or
engine
family.
If
information
necessary
to
complete
the
written
report
is
not
available
to
the
respondent
with
in
15
days,
the
respondent
may
submit
the
missing
information
when
it
becomes
av
ailable.

This
collection
also
requires
manufacturers
to
retain
records
on
defects
for
five
years
from
the
date
of
manufacture
of
the
vehicle.
Five
years
from
th
e
date
of
manufacture
corresponds
to
the
useful
life
of
vehicles
manufactured
pr
ior
to
implementation
of
the
current
Tier
1
emission
standards,
and
thus,
at
the
time
of
implementation
of
the
regulations
was
in
keeping
with
the
intention
of
the
Clean
Air
Act
(
Act)
that
vehicles
and
engines
conform
to
applicable
emission
standards
throughout
their
useful
lives
which
is
now
10
years
or
100,000
miles,
whichever
comes
first,
according
to
"
202(
d)
of
the
Act.
"
207
of
the
Act
makes
the
vehicle
manufacturers
liable
for
recalls
for
that
same
period
and
requires
defec
t
warranty
coverage
for
8
years/
80,000
miles.
In
most
cases,
the
defect
will
be
discovered
after
the
vehicle
has
been
in
use
for
some
period
of
time,
making
th
e
actual
record
retention
shorter
than
five
years.
Although
the
statutory
("
202(
d
)
of
the
Act)
and
regulatory
useful
life
of
new
light­
duty
passenger
vehicles
is
now
10
years
or
100,000
miles,
whichever
comes
first,
and
thus,
a
justification
could
be
made
to
require
retention
for
10
years,
five
years
is
still
the
regula
tory
requirement
and
a
reasonable
amount
of
time
for
retaining
these
records.

3(
f)
Confidentiality:

Any
claimed
confidential
business
information
that
meets
the
criteria
fo
r
confidential
treatment
in
EPA's
regulations
relating
to
confidential
business
claims
pursuant
to
5
U.
S.
C.
"
552
and
40
CFR
Part
2
will
be
treated
as
such.

3(
g)
Sensitive
Questions:

No
questions
of
a
sensitive
nature
are
asked.

Section
4:
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes:

The
respondents
are
manufacturers
of
motor
vehicles
(
SIC
371).

4(
b)
Information
Requested:

(
i)
Data
items,
including
recordkeeping
requirements
:

(
A)
Reporting
items:
Manufacturers
are
required
to
submit
reports
covering
defects
or
volunta
ry
recalls
for
vehicles
that
are
five
(
5)
years
or
less
old
(
40
CFR
85.1901),
on
ly
when
their
data
indicates
that
a
specific
emission­
related
defect
exists
in
o
r
they
voluntarily
recall
twenty­
five
(
25)
or
more
vehicles
of
the
same
model
ye
ar
which
have
been
sold
to
the
public.
These
reports
are
required
only
once
foll
owing
the
discovery
of
the
defect
or
the
initiation
of
a
voluntary
recall
involv
ing
emissions
related
components.
The
required
information
includes:

For
DIRs
(
40
CFR
85.1903):
The
manufacturer's
corporate
name
85.1903(
c)(
1)
A
description
of
the
defect
85.1903(
c)(
2)
A
description
of
the
class
or
category
of
vehicles
or
engines
85.1903(
c)(
3)
Number
of
vehicle
or
engines
estimated
or
known
to
have
the
defect
and
explanati
on
of
derivation.
85.1903(
c)(
4)(
i)
The
address
of
the
plant(
s)
where
they
were
produced
85.1903(
c)(
4)(
ii)
Evaluation
of
the
emissions
impact
and
any
driveability
problems
it
might
cause
8
5.1903(
c)(
5)
Available
emissions
data
related
to
the
defect
85.1903(
c)(
6)
Indication
of
any
anticipated
manufacturer
follow­
up
85.1903(
c)(
7)

For
VERRs
(
40
CFR
85.1904):
A
description
of
the
class
or
category
of
vehicles
or
engines
being
recalled
8
5.1904(
a)(
1)
A
description
of
the
modifications
or
repairs
made
to
correct
the
defects
8
5.1904(
a)(
2)
A
description
of
the
method
being
used
to
identify
and
contact
the
owners
8
5.1904(
a)(
3)
A
description
of
any
conditions
for
eligibility
for
repair
and
any
reasons
for
t
he
conditions
85.1904(
a)(
4)
A
description
of
the
procedure
to
be
followed
by
the
owner
to
obtain
repairs
and
where
the
repairs
can
be
obtained
85.1904(
a)(
5)
If
repairs
are
not
being
performed
at
dealers,
a
description
of
who
will
perform
the
repairs
and
where
the
defect
will
be
remedied
85.1904(
a)(
6)
Copies
of
the
letters
of
notification
to
be
sent
to
the
vehicle
owners
85.1904(
a
)(
7)
A
description
of
the
system
for
assuring
an
adequate
supply
of
parts
is
availabl
e
for
the
repairs
and
that
they
are
performed
in
a
timely
manner.
85.1904(
a
)(
8)
Copies
of
all
necessary
instructions
to
be
sent
to
the
persons
who
are
to
perfor
m
the
repairs
85.1904(
a)(
9)
A
description
of
the
impact
of
the
proposed
changes
on
fuel
consumption,
driveab
ility,
and
safety
of
the
vehicles
85.1904(
a)(
10)
A
sample
of
any
labels
to
be
applied
to
the
participant
vehicles
identifying
the
recall
being
performed
85.1904(
a)(
11)

VERR
Quarterly
Progress
Reports
(
40
CFR
85.1904).
These
reports
are
to
document
the
progress
of
any
voluntary
recalls
that
the
manufacturer
has
underta
ken.
These
reports
are
required
for
six
quarters
following
the
beginning
of
any
recall
campaign.

Recall
campaign
number
85.1904(
b)(
1)
Date
of
owner
notification
and
completion
85.1904(
b)(
2)
Number
of
vehicles
or
engines
involved
85.1904(
b)(
3)
Number
of
vehicles
known
or
estimated
to
be
affected
by
the
defect
85.1904(
b
)(
4)
Number
of
vehicles
or
engines
brought
in
and
inspected
as
part
of
the
campaign
8
5.1904(
b)(
5)
Number
of
vehicles
found
to
have
the
defect
after
inspection
85.1904(
b)(
6)
Number
of
vehicles
actually
receiving
repair
85.1904(
b)(
7)
Number
of
vehicles
determined
to
be
unavailable
due
to
exportation,
theft,
scrap
ping
or
other
reasons
85.1904(
b)(
8)
Number
of
vehicles
determined
to
be
ineligible
because
of
improper
maintenance
o
r
use
85.1904(
b)(
9)
Copies
of
any
service
bulletins
sent
to
dealers
which
relate
to
the
defect
that
had
not
previously
been
reported
85.1904(
b)(
10)
Copies
of
all
communications
transmitted
to
vehicle
owners
which
relate
to
the
d
efect
to
be
corrected
not
previously
submitted
85.1904(
b)(
11)
Revisions
to
any
of
the
information
previously
submitted
85.1904(
c)
Vehicle
owner
contact
information
upon
request
85.1904(
e)

(
B)
Recordkeeping
requirements:

Pursuant
to
40
CFR
85.1904(
d)
manufacturers
shall
maintain
records
conce
rning
voluntary
emissions
recalls
concerning
owner
notification
including
names
and
addresses
of
owners
that
were
notified,
who
received
remedial
repair
or
insp
ection,
who
was
determined
not
to
be
eligible
because
of
improper
maintenance
or
use.

Pursuant
to
40
CFR
85.1906(
b),
manufacturers
are
required
to
maintain
th
e
records
gathered
to
compile
the
DIRs,
VERRs,
and
the
Quarterly
Progress
report
s
for
not
less
than
five
years
from
the
date
of
manufacture
of
the
vehicles.

(
ii)
Respondent
Activities
A
manufacturer
is
required
to
perform
the
following
activities
if
there
are
emissions
related
defects
and/
or
voluntary
recalls
associated
with
emissions
defects:

Gather
information
and
submit
a
report
concerning
the
defect
whenever,
o
n
the
basis
of
data
obtained
in
accordance
with
procedures
established
to
identi
fy
safety
related
defects
that
a
specific
defect
exists
in
25
or
more
vehicles.
These
reports
are
required
to
be
submitted
within
15
working
days
after
it
is
f
ound.
(
40
CFR
85.1903)

When
a
manufacturer
initiates
a
voluntary
recall
involving
emissions
rel
ated
defective
parts
on
25
or
more
vehicles,
the
manufacturer
is
required
to
gat
her
and
submit
a
report
within
15
working
days
of
the
date
of
owner
notification
.
The
report
is
required
to
describe
the
recall
plan
per
40
CFR
85.1904.

When
a
manufacturer
is
conducting
a
voluntary
emissions
recall,
it
is
re
quired
to
submit
6
quarterly
progress
reports
describing
the
progress
and
succes
s
of
the
recall
campaign.
These
reports
must
be
submitted
no
later
than
25
work
ing
days
after
the
close
of
each
calendar
quarter
after
the
beginning
of
the
rec
all
campaign
pursuant
to
40
CFR
85.1904(
b).

Section
5:
The
Information
Collected­­
Agency
Activites,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
The
Agency
engineers
review
the
information
submitted
by
the
manufacture
rs
to
determine
compliance
with
the
requirements,
completeness
and
emissions
eff
ects.
They
also
verify
the
manufacturers'
justification
or
rationale
for
any
fo
llow­
up
activities
or
recommend
further
compliance
related
activities,
such
as
t
esting
or
further
research
concerning
the
effects
of
the
defects
or
recall
campa
igns.
Any
required
follow­
up
with
the
manufacturers
is
usually
by
telephone
or
letter
if
more
information
is
needed
to
complete
the
evaluation
of
the
manufactu
rers
submission.

Agency
staff
use
the
defect
reports
to
target
potentially
non­
conforming
classes
for
future
testing
and
to
monitor
manufacturers'
compliance
with
the
Cl
ean
Air
Act.
Defect
reports
frequently
lead
to
recalls
by
the
manufacturers.
T
he
progress
reports
are
reviewed
to
determine
whether
a
recall
campaign
is
effec
tive
and
allows
the
agency
to
verify
that
manufacturers
are
meeting
their
obliga
tions
to
recall
defective
vehicles
which
would
otherwise
fail
to
meet
emissions
standards.

This
information
is
reviewed,
summarized,
evaluated
and
stored.
An
elec
tronic
summary
of
all
such
information
is
available
for
review
by
authorized
per
sonnel
for
various
program
planning
and
compliance
activities,
and
complete
copi
es
are
filed
and
stored
for
further
use
when
needed
by
OMS
staff.
The
summary
o
f
voluntary
recalls
is
posted
on
the
Agency's
Internet
web
site
for
the
public.

5(
b)
Collection
Methodology
And
Management
The
information
is
collected
through
a
letter
submitted
by
the
responden
t.
The
respondent
includes
the
required
information
if
their
information
indica
tes
that
they
have
enough
failures
to
trigger
the
required
reports.
During
the
normal
course
of
business,
vehicle
and
engine
manufacturers
would
collect
inform
ation
about
the
frequency
of
problem
areas
or
customer
or
dealer
complaints
that
identify
defects
or
other
problems
with
their
products
using
normal
office
comp
uters
with
some
type
of
standard
software.
There
is
no
specific
requirement
to
do
so,
however,
and
the
information
could
be
collected
manually.
Although
categ
orizing
and
addressing
the
emissions­
related
aspect
of
the
defects
is
an
additio
nal
burden
for
the
manufacturers,
generating
the
reports
to
EPA
which
are
merely
summary
reports
of
such
activities,
represents
a
small
portion
of
the
manufactu
rer
resources
involved
in
monitoring
quality
and
compliance
with
the
emissions
s
tandards
to
reduce
their
liability
for
potential
violations.
While
not
required
,
40
CFR
85.1905
allows
manufacturers
the
flexibility
of
submitting
the
informat
ion
electronically
as
long
as
the
required
information
is
provided.

EPA
reviews,
summarizes,
and
culls
out
certain
information
from
the
repo
rts
to
determine
manufacturer
compliance.
If
manufacturers
are
not
in
complianc
e
they
are
contacted
by
telephone
initially.
If
follow­
up
is
required,
a
letter
may
be
sent
to
the
manufacturer
about
any
potential
noncompliance.
The
reports
are
then
filed
in
internal
file
cabinets.
Information
from
these
reports
is
di
sclosed
under
the
provisions
of
the
Freedom
of
Information
Act.

5(
c)
Small
Entity
Flexibility
This
information
collection
activity
does
not
affect
any
small
businesses
or
ent
ities.

5(
d)
Collection
Schedule
A
DIR
is
required
only
when
the
manufacturer
becomes
aware
that
emission
s­
related
defects
involve
25
or
more
vehicles
of
the
same
model
year.
These
rep
orts
must
be
submitted
not
more
than
15
working
days
after
the
defect
is
found
t
o
involve
that
number
of
vehicles.
A
VERR
is
required
only
when
the
manufacture
r
initiates
a
voluntary
recall
campaign
of
25
or
more
vehicles.
VERRs
must
be
s
ubmitted
not
more
than
15
working
days
after
owner
notification
is
initiated.
S
ix
Quarterly
Progress
Reports
involving
a
voluntary
recall,
must
be
submitted
wh
enever
a
voluntary
recall
campaign
is
initiated.
These
progress
reports
are
to
be
submitted
no
later
than
25
working
days
after
the
close
of
each
calendar
quar
ter
for
six
quarters.

Section
6:
Estimating
the
Burden
and
Cost
of
the
Collection
See
Table
1
below.
TABLE
1
Respondent
Annual
Burden
Hours
&
Costs
Collection
Activity
Management/
Technical
hrs
($
75/
hr)
Clerical/
Admin.
Hrs.($
43/
hr)
Frequency
per
Respondent
Respondent
Hours/
Year
Labor
Co
st/
Respondent
Capital/
Startup
Costs/
Response
O&
M
Cost/
Response
Total
Annual
Costs
($)
per
Respondent
Total
#
of
Respondents
Number
of
Respon
ses
Total
Burden
Hrs/
Yr
Total
Costs/
Yr
Defect
Information
Reports:
Review
Regulations
0.5
0
5.1
2.55
$
191
$
0
$
0
$
191
12
61
30.6
$
2,295
Compile
Data
10
0
5.1
51
$
3,825
$
0
$
0
$
3,825
12
61
612
$
45,900
Prepare
Rept.
2
1
5.1
15.3
$
984
$
0
$
2
$
995
12
61
183.6
$
11,934
Review
Rept.
0.5
0
5.1
2.55
$
191
$
0
$
0
$
191
12
61
30.6
$
2,295
Subtotals
13
1
71.4
$
5,191
$
0
$
2
$
5,203
856.8
$
62,424
Voluntary
Emission
Recall
Reports:
Review
Regulations
0.5
0
3.8
1.9
$
143
$
0
$
0
$
143
6
23
11.4
$
855
Compile
Data
0.5
0
3.8
1.9
$
143
$
0
$
0
$
143
6
23
11.4
$
855
Prepare
Rept.
1
1
3.8
7.6
$
448
$
0
$
2
$
456
6
23
45.6
$
2,736
Review
Rept.
0.5
0
3.8
1.9
$
143
$
0
$
0
$
143
6
23
11.4
$
855
Subtotals
2.5
1
13.3
$
877
$
0
$
2
$
885
79.8
$
5,301
Voluntary
Emission
Recall
Reports
(
Record
Keeping):
Maintain
Owner
Records
0
8
3.8
30.4
$
1,307
$
0
$
20
$
1,383
6
23
182.4
$
8,299
Subtotals
0
8
30.4
$
1,307
$
0
$
20
$
1,383
182.4
$
8,299
Voluntary
Recall
Quarterly
Reports:
Review
Regulations
0.25
0
15.2
3.8
$
285
$
0
$
0
$
285
6
92
22.8
$
1,710
Compile
Data
0.5
0
15.2
7.6
$
570
$
0
$
0
$
570
6
92
45.6
$
3,420
Prepare
Rept.
0
0.5
15.2
7.6
$
327
$
0
$
2
$
357
6
92
45.6
$
2,143
Review
Rept.
0.25
0
15.2
3.8
$
285
$
0
$
0
$
285
6
92
22.8
$
1,710
Subtotals
1
0.5
22.8
$
1,467
$
0
$
2
$
1,497
136.8
$
8,983
Totals
1255.8
$
85,007
Section
6(
a):
Estimating
the
Respondent
Burden
Burden
estimates
were
derive
from
the
original
ICR
and
comments
from
con
sultation
with
fewer
than
9
past
respondents.
Table
1
provides
estimates
of
each
type
of
respondent's
total
annual
burden
hours
and
costs
involved
in
each
activ
ity
and
task
based
on
employee
mix,
subtasks
for
each
type
of
response,
and
aver
age
frequency
of
response.
The
burden
estimates
are
averages
based
on
conversat
ions
with
a
sample
of
respondents.
The
time
to
compile
data
for
DIRs
is
longer,
on
average,
than
VERRs,
because
manufacturers
sometimes
conduct
emissions
tests
to
determine
the
emissions
impact
of
a
defect.
On
the
other
hand,
voluntary
re
calls
often
do
not
involve
emissions
data
because
manufacturers
have
made
the
de
cision
to
recall
on
engineering
judgement
or
pre­
existing
data.

Collection
and
reporting
burden
for
this
collection
of
information
is
es
timated
to
average
14
hours
per
DIR,
3.5
hours
per
VERR,
and
1.5
hours
per
quart
erly
or
progress
report
for
recalls.
Recordkeeping
burden
for
this
activity
is
estimated
to
average
8
hours
per
VERR.
These
estimates
include
time
for
compili
ng,
recording,
and
maintaining
information
in
a
manner
consistent
with
the
appli
cable
regulations.
See
Table
1,
columns
2
and
3.

The
frequency
of
submissions
is
based
on
1996­
1998
calendar
year
submiss
ions.
An
average
of
12
manufacturers
submitted
an
average
of
61
DIRs,
for
an
av
erage
of
5.1
reports
per
respondent
per
year.
An
average
of
6
manufacturers
sub
mitted
an
average
of
23
VERRs,
for
an
average
of
3.8
reports
per
year.
Since
th
ese
two
related
activities
may
or
may
not
have
the
same
respondents,
it
is
assu
med
that
they
could
be
different
and,
thus,
assumed
that
there
will
be
18
respon
dents
per
year
to
these
requirements.

For
on­
highway
motor
vehicle
manufacturers,
6
quarterly
progress
reports
must
also
be
submitted
for
each
VERR
submitted.
Accounting
for
the
submittal
o
f
these
quarterly
reports,
the
frequency
of
quarterly
progress
reports
per
year
is
four
times
the
frequency
of
VERRs
for
each
of
these
types
of
respondents
duri
ng
a
particular
year.

Section
6(
b):
Estimating
the
Respondent
Burden
i)
Estimating
Labor
Costs
The
labor
rates
provided
by
the
Bureau
of
Labor
Statistics
is
$
34.39
for
management/
professional
staff
and
$
16.09
for
clerical
employees.
These
are
ave
rages
for
all
industries
and
do
not
reflect
the
actual
costs
for
manufacturers
o
f
motor
vehicles.
Therefore,
hourly
pay
rates
for
this
ICR
are
based
on
an
aver
age
of
$
75
per
hour
for
professional
management
and
technical
staff
in
the
autom
otive
manufacturing
field
and
$
43
per
hour
for
clerical
and
administrative
staff
.
These
were
based
on
the
previous
ICR
and
adjusted
for
inflation.
These
cost
s
are
assumed
to
include
wages
or
salaries
and
overhead
costs.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
Operation
and
maintenance
costs
associated
with
this
information
collect
ion
include
photocopying,
postage,
computer
disks,
and
paper.
There
are
no
othe
r
capital
costs
to
the
respondents
since
they
would
normally
have
all
the
equipm
ent
necessary
for
responding
to
these
requirements.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
(
O&
M)
Costs
There
are
no
capital
start­
up
costs
associated
with
the
renewal
of
this
ICR.

(
iv)
Annualizing
Capital
Costs
There
are
no
annualized
capital
start­
up
costs
associated
with
this
info
rmation
collection.

Section
6(
c):
Estimating
Agency
Burden
and
Cost
Based
on
the
1999
GS
pay
schedule,
EPA
estimates
an
average
hourly
$
34.3
8
for
engineering/
technical
staff,
and
$
23.90
for
clerical
staff.
To
derive
hou
rly
estimates,
EPA
divided
annual
compensation
estimates
for
a
GS­
9
engineer
and
a
GS­
7
clerk
by
2,080
which
is
the
number
of
hours
in
the
Federal
work
year.
E
PA
then
multiplied
hourly
rates
by
the
standard
government
benefits
multiplicati
on
factor
of
1.6.
Engineers
will
typically
be
responsible
for
all
review
and
su
mmary
work;
administrative
support
will
be
used
for
data
entry
and
filing.
For
the
estimate
it
is
assumed
that
each
DIR
involves
approximately
6
hours
of
engin
eer
time
to
review,
follow­
up
and
summarize.
It
is
also
estimated
that
each
VER
R
and
each
VERR
progress
report
involves
approximately
3
hours
and
 
hours,
respec
tively,
of
review
and
summarization.
For
each
DIR,
it
is
estimated
that
there
i
s
of
an
hour
involved
in
data
entry
and
filing.
It
is
also
assumed
that
each
VERR
and
each
VERR
progress
report
involves
hour
and
1/
6
hour,
respectively,
d
ata
entry
and
filing.

Table
2
Annual
Government
Burden
Collection
Activity
Engineer
Hrs/
Response
@
$
34.38/
hr
Clerical/
Admini
strative
Hrs/
Response
@$
23.90/
hr
Hours/
Response
Number
of
Responses
Total
Hours
Total
Costs
Defect
Information
Reports:
Review
&
Summarize
6
0
6
61
366
$
12,583
Data
Entry
&
File
0
0.66
0.66
61
40.26
$
962
Voluntary
Emission
Recall
Reports:
Review
&
Summarize
3
0
3
23
69
$
2,372
Data
Entry
&
File
0
0.66
0.66
23
15.18
$
363
Voluntary
Emission
Recall
Quarterly
Progress
Reports:
Review
&
Summarize
0.25
0
0.25
92
23
$
791
Data
Entry
&
File
0
0.16
0.16
92
14.72
$
352
Totals
176
528.16
$
17,423
Section
6(
d):
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
the
last
three
years,
there
were
an
average
of
61
DIRs
per
year
submitted
by
an
average
of
12
respondents
per
year.
This
results
in
an
average
of
5.1
DIRs
per
respondent.
There
were
also
an
average
of
23
VERRs
per
year
by
an
average
of
6
respondents
per
year.
This
results
in
an
average
of
3.8
VERRs
per
respondent.
VERR
Quarterly
reports
per
year
would
be
4
times
the
number
of
VERRs.

Total
Respondent
Burden
Hours:
1,255.8
hours
Total
Respondent
Cost:
$
85,007
Section
6(
e):
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
Table
3
Respondent
Tally
Activity
Respondents
Number
of
Activities
Total
Labor
Hours/
Year
Total
Labor
Costs/
Year
Total
Annual
Capital
Costs
Total
Annual
O&
M
Costs
DIRRs
12
61
856.8
$
62,302
0
$
122
VERRs
6
23
79.8
$
5,255
0
$
46
Maintain
Owners
Records
6
23
182.4
$
7,843
0
$
460
VERR
Qtrly
Rpts
6
92
136.8
$
8,801
0
$
184
Total
18
199
1255.8
$
84,201
0
$
812
(
ii)
The
Agency
Tally
Number
of
Respondents:
18
Number
of
Activities:
176
Total
Hours
per
Year:
528
Total
Annual
Labor
Cost
Per
Year:
$
17,423
(
iii)
Variations
In
The
Annual
Bottom
Line
Bottom
line
estimates
for
respondents
and
the
Agency
are
not
expected
to
vary
more
than
25%
from
year
to
year
because
regulatory
standards
and
manufactu
rer
requirements
do
not
change
significantly
from
year
to
year
due
to
the
phasin
g­
in
of
standards.
Manufacturers
regularly
carry­
over
vehicle
system
designs
fr
om
one
year
to
the
next
for
many
different
models
to
keep
their
costs
down.
Def
ects
and
recalls
generally
occur
most
often
in
the
first
year
or
two
of
system
u
se.

Section
6(
f):
Reasons
for
Change
in
Burden
At
first
glance,
there
appears
to
be
significant
changes
to
the
estimate
s
from
the
last
renewal
primarily
because
the
regulations
for
on­
road
heavy­
duty
engines,
large
non­
road
engines
and
small
non­
road
engines
have
been
eliminated
from
this
request
compared
to
the
last
one.
The
request
for
extension
for
thes
e
other
engines
and
equipment
will
be
submitted
separately
to
minimize
the
compl
exity
resulting
from
the
uniqueness
of
those
industries
and
regulations,
and
the
addition
of
other
non­
road
engine
requirements.
Breaking
these
out
into
a
sepa
rate
ICR
also
allows
a
more
accurate
assessment
of
the
burden
since
the
universe
of
respondents
is
different
for
those
manufacturers.

Although
the
current
inventory
for
this
ICR
lists
1800
hours
for
this
ac
tivity,
the
number
of
hours
associated
with
on­
highway
light­
duty
vehicles
is
13
61
hours.

Other
changes
that
significantly
affect
this
request
result
from
the
ave
rage
number
of
DIRs
increasing
significantly
possibly
resulting
from
changes
in
standards
and
technology
used
for
meeting
those
standards.
While
the
number
of
DIRs
has
gone
up,
the
number
of
VERRs
has
gone
down
steadily
over
the
years.
Th
e
number
of
DIRs
would
be
expected
to
tail
off
and
decline
again
as
manufacturer
s
gain
experience
with
the
changes
and
technology.
Furthermore,
those
standards
and
technology
changes
have
probably
contributed
to
the
decline
in
the
number
o
f
VERRs
required.
Other
minor
increases
in
the
burden
estimates
resulted
from
u
pdated
labor
rates
based
on
more
current
information.
The
burden
hours
per
resp
onse
and
the
methodology
for
the
calculations
is
virtually
the
same
as
the
last
estimate.

Section
6(
g):
Burden
Statement
A
respondent's
burden
for
a
DIR
is
estimated
to
be
14
hours
per
report.
This
estimate
includes
the
time
to
review
the
regulations,
compile
the
informat
ion
and
data
for
the
report,
and
prepare,
review
and
submit
the
report.
A
respo
ndent's
burden
for
a
VERR,
the
recordkeeping
requirements,
and
the
quarterly
pro
gress
reports,
are
estimated
to
be
3.5
hours,
8
hours,
and
6
hours,
respectively
.
This
estimate
includes
the
time
to
review
the
regulations,
compile
the
inform
ation
and
data
for
the
reports,
prepare,
review
and
submit
the
reports,
and
deve
lop
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;
dev
elop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
c
ollecting,
validating,
and
verifying
information,
processing
and
maintaining
inf
ormation,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
perso
nnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
di
sclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
n
ot
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
curr
ently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
a
re
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
respond
ent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Director,
OPPE
Regulatory
Information
Division,
U.
S.
Environmental
Protection
Ag
ency
(
2137),
401
M
St.,
S.
W.,
Washington,
D.
C.
20460;
and
to
the
Office
of
Infor
mation
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
and
OMB
control
number
in
any
correspondence.

Part
B.
Not
applicable.
This
is
for
recordkeeping
and
reporting
regarding
defe
cts
and
voluntary
recalls
by
vehicle
and
engine
manufacturers.
Manufacturers
su
bmit
the
prescribed
information
in
all
cases
where
specific
criteria
is
met.
No
samples
or
surveys
are
involved
in
this
activity.

Attachments:
Copy
of
Regulations
Copy
of
1st
Federal
Register
Notice
