INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
Information
Requirements
for
Marine
Diesel
Engines
(
Nonroad
Large
SI
Engines
and
Marine
Diesel
Engines)
(
Amendments)
(
Final
Rule)

November
2002
Assessment
and
Standards
Division
Office
of
Transportation
and
Air
Quality
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
Information
Collection
Request
1(
a).
Title
Information
Requirements
for
Nonroad
Large
SI
Engines
and
Marine
Diesel
Engines
ICR
Tracking
Number:
1897.04
1(
b).
Short
Characterization
The
Clean
Air
Act
authorizes
EPA
to
adopt
emission
standards
for
new
nonroad
engines.
We
need
information
to
verify
that
manufacturers
comply
with
emission
standards
 
before
production
begins,
during
production,
and
after
units
have
been
placed
into
service.
In
the
rulemaking
we
require
manufacturers
to
generate
or
retain
information
to
demonstrate
that
engines
comply
with
emission
standards.

Manufacturers
generally
send
us
the
data
they
collected
and
keep
these
records
and
other
pertinent
information.
We
may
request
to
see
any
of
these
records.

We
and
the
regulated
companies
will
use
the
data
exclusively
to
ensure
compliance
with
emission
standards.
Information
such
as
engine
family,
total
numbers
of
engines
built,
and
emission
rates
for
specific
pollutants,
are
examples
of
what
we
require.
This
ICR
is
a
revision
to
the
information
collection
request
already
established
for
marine
diesel
engines
(#
1897.02).

2.
Need
For
and
Use
of
the
Collection
2(
a).
Need/
Authority
for
the
Collection
The
data
we
require
in
this
ICR
is
necessary
to
comply
with
Title
II
of
the
Clean
Air
Act,
as
amended
in
1990.
The
Act
directs
us
to
adopt
regulations
for
nonroad
engines
if
we
determine
those
engines
contribute
significantly
to
air
pollution
in
the
U.
S.
Now
that
we
have
made
this
determination,
the
Act
directs
us
to
set
emission
standards
for
any
category
of
nonroad
engines
that
contributes
to
air
quality
nonattainment
in
two
or
more
areas
in
the
U.
S.
We
can
only
meet
the
requirements
of
the
Act
by
collecting
data
from
the
regulated
industry.
Also,
we
will
only
have
an
effective
program
if
we
know
that
these
engines
maintain
their
certified
emission
level
throughout
their
operating
lives.

2(
b).
Use/
Users
of
the
Data
We
will
oversee
the
certification
process
and
maintain
the
program
database.
We
will
use
the
data
items
to
verify
compliance
with
the
following
requirements
associated
with
the
new
emission
standards.


determine
whether
or
not
a
prototype
engine
may
adequately
represent
an
engine
family.


ensure
compliance
of
production­
line
engines.
1Category
3
marine
diesel
engines
are
those
with
per­
cylinder
displacement
at
or
above
30
liters.

issue
a
recall
to
correct
a
noncompliant
family
of
engines.


confirm
actual
emission
benefits
gained
by
the
program.


ensure
proper
maintenance
and
setting
of
physically
adjustable
parameters.


aid
in
the
production
projections
to
randomly
select
the
engines
which
are
to
undergo
testing.


determine
whether
a
prototype
or
freshly
manufactured
engine
should
be
issued
a
certificate
of
conformity.


ensure
that
durability
of
emission
controls
is
consistent
with
the
manufacturer's
stated
useful
life.


ensure
control
of
emissions
across
the
range
of
engine
operation
expected
in
the
normal
course
of
its
lifetime
3.
Nonduplication,
Consultations,
and
other
Collection
Criteria
3(
a)
Nonduplication
Emissions
from
the
engines
and
vehicles
subject
to
the
new
emission
standards
have
been
largely
unregulated
in
the
United
States.
Moreover,
state
and
local
governments
are
preempted
from
adopting
emission
standards
for
many
of
the
engines
covered
by
this
rulemaking.
For
this
reason,
the
information
requested
under
this
ICR
is
not
available
from
other
sources.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
We
published
a
proposed
rulemaking
in
the
Federal
Register
on
October
5,
2001
regarding
emission
standards
for
industrial
spark­
ignition
engines
and
recreational
marine
diesel
engines.
In
addition,
we
published
proposed
emission
standards
for
Category
3
marine
diesel
engines
on
May
29,
2002.1
These
proposed
rules
included
invitations
to
comment
on
the
ICR.
We
received
comments
on
several
issues
related
to
information
collection,
sometimes
indirectly.
These
comments
and
our
responses
are
summarized
in
the
following
table.
Table
1
Comments
Related
to
Information
Collection
Commenter
Comment
Response
Large
SI
Industrial
Truck
Association/
Ford
New
dynamometers
for
running
transient
duty
cycle
will
be
expensive.
Test
will
be
hard
to
run.
Benefits
of
the
new
cycle
may
not
be
worth
the
cost.
Emission
modeling
shows
substantial
benefits
resulting
from
the
new
cycle.
Capital
costs
incorporated
into
cost
analysis,
which
shows
that
cost
per
engine
and
cost
per
ton
are
favorable.

Wisconsin/
Ford
Evaporative
controls
should
not
be
part
of
certification,
since
engine
manufacturers
don't
control
fuel
tank
design.
Evaporative
controls
are
not
justified
because
of
the
limited
number
of
gasoline
engine
sales.
Commenters
supported
design­
based
requirements.
Impact
analysis
shows
that
evaporative
controls
are
clearly
justified.
Final
rule
includes
design­
based
certification
to
minimize
costs
and
implementation
issues
for
engine
manufacturers.

Caterpillar
Manufacturer
in­
use
testing
is
not
appropriate,
since
engine
manufacturer
does
not
control
engine
after
sale.
Also,
smallvolume
families
should
be
exempt
from
inuse
testing
requirements.
The
Clean
Air
Act
clearly
assigns
engine
manufacturers
the
responsibility
to
meet
standards
throughout
the
useful
life
and
authorizes
testing
to
verify
this.
The
regulations
provide
for
alternative
compliance
demonstration
for
small­
volume
families.

Engine
Manufacturers
Association
Production­
line
testing
is
burdensome
and
unjustified.
Selective
enforcement
audits
are
a
preferred
way
of
establishing
compliance
for
production
engines.
Production­
line
testing
provides
much
better
assurance
of
compliance
than
selective
enforcement
auditing.
Special
provisions
allow
for
decreased
testing
burden,
either
for
a
lower­
cost
alternative
procedure,
or
as
a
reward
for
consistently
good
test
results.

Recreational
Marine
Diesel
Engine
Manufacturers
Association
Emission
standards
should
be
harmonized
with
those
under
consideration
in
Europe
to
avoid
increasing
compliance
burden.
The
emission
standards
in
the
final
rule
are
consistent
with
the
Clean
Air
Act.
Manufacturers
meeting
EPA
standards
can
easily
meet
less
stringent
international
standards.

Cummins
Identifying
the
worst­
case
engine
configuration
in
an
engine
family
is
overly
burdensome.
Manufacturers
are
responsible
to
use
"
good
engineering
judgment"
in
selecting
the
worstcase
engine.
This
is
consistent
with
their
ongoing
liability
for
meeting
the
emission
standards
for
all
engine
configurations.

Engine
Manufacturers
Association
Manufacturers
should
not
be
required
to
install
a
sample
port
in
the
exhaust
system,
since
that
part
of
the
engine
is
typically
installed
by
another
company
(
usually
the
boat
builder).
The
regulations
specify
that
the
manufacturers
may
meet
this
requirement
by
including
emission­
related
installation
instructions
with
their
engines.
Boat
builders
would
then
be
required
to
follow
these
instructions.
Commenter
Comment
Response
Engine
Manufacturers
Association
Production­
line
testing
is
burdensome
and
unjustified.
Selective
enforcement
audits
are
a
preferred
way
of
establishing
compliance
for
production
engines.
Production­
line
testing
provides
much
better
assurance
of
compliance
than
selective
enforcement
auditing.
Special
provisions
allow
for
decreased
testing
burden,
either
for
a
lower­
cost
alternative
procedure,
or
as
a
reward
for
consistently
good
test
results.

Category
3
Marine
Diesel
Wartsila,
MAN
B&
W,
et
al
EPA
emission
standards
should
not
depart
from
the
internationally
negotiated
standards.
Separate
U.
S.
standards
would
be
very
costly
and
disruptive
to
international
commerce.
In
this
rulemaking,
we
are
incorporating
the
internationally
negotiated
standards.
We
intend
to
revisit
these
questions
in
a
future
rulemaking.

Euromot,
Wartsila
The
certification
requirements
should
follow
the
documentation
procedures
in
the
Annex
VI
NOx
Technical
Code.
The
final
rule
aligns
in
almost
all
respects
with
the
NOx
Technical
Code.
The
few
exceptions,
such
as
useful
life
and
warranty
requirements,
come
directly
from
the
Clean
Air
Act.

Euromot,
Wartsila,
MAN
B&
W,
Caterpillar
Onboard
NOx
monitoring
would
be
unreliable
and
burdensome.
We
disagree
with
the
commenters,
but
are
not
adopting
onboard
NOx
monitoring.
We
will
reconsider
this
in
any
future
rulemaking
in
which
we
consider
the
use
of
advanced
emission­
control
technologies.
3(
c)
Consultations
We
have
met
with
companies
that
will
be
subject
to
the
new
emission
standards.
These
contacts
are
summarized
in
Table
2.

Table
2
Industry
Contacts
Regarding
Information
Collection
Date
Contact
Large
SI
March
2000
Jim
Hudzinski,
et
al,
Ford
Power
Products
248­
945­
4412
April
2000
Brad
Garner,
et
al,
Impco
Technologies
810­
264­
1200
April
6,
2000
Bill
Studzinski,
et
al,
Wis­
Con
Total
Power
901­
369­
4029
April
26,
2000
Meeting
with
engine
manufacturers
June
27,
2000
Meeting
with
engine
manufacturers
March
15,
2001
George
Maes,
et
al,
Nissan
Forklift
Corp.
815­
568­
2139
April
17,
2001
Carl
Bryant,
Westebeke
508­
823­
7677
April
24,
2001
Meeting
with
engine
manufacturers
May
30,
2001
Carl
Bryant,
Westebeke
508­
823­
7677
January
15,
2002
George
Maes,
Nissan
815­
568­
2139
April
3,
2002
Josh
Sutherland,
Wisconsin
Motors
888­
591­
6842
April
16,
2002
Bill
Passie
et
al,
Caterpillar
309­
675­
5362
May
21,
2002
Meeting
with
engine
manufacturers
Date
Contact
Recreational
Marine
Diesel
June
21,
2000
Engine
Manufacturers
Association,
Tim
French
(
312)
269­
5670
January
10,
2001
Engine
Manufacturers
Association,
Tim
French
(
312)
269­
5670
March
14,
2001
Mercruiser,
Rolf
Lichtner
(
405)
743­
7540
March
29,
2001
Cummins,
Mike
Brand
(
812)
377­
3752
May
24,
2002
Meeting
with
engine
manufacturers
Category
3
Marine
Diesel
September
6,
2001
Wartsila,
Fred
Danska
(
954)
327­
4868
September
17,
2001
conference
call
with
Caterpillar/
MaK,
Bill
Passie
309­
675­
5362
November
1,
2001
U.
S.
Chamber
of
Shipping,
Kathy
Metcalf
(
202)
775­
4399
December
6,
2001
Euromot,
Hartmut
Mayer
49
69
66
03
1354
December
14,
2001
National
Shipbuilders
Association,
Frank
Losey
(
202)
544­
8170
September
18,
2002
Meeting
with
engine
manufacturers
3(
d)
Effects
of
Less
Frequent
Collection
Annual
reporting
for
certifying
engine
families
is
necessary
to
align
with
the
regulatory
requirement
to
certify
engine
families
every
year.
Quarterly
reporting
of
test
results
from
production­
line
testing
is
necessary
to
allow
adequate
response
to
any
problem
that
may
arise.

3(
e)
General
Guidelines
This
ICR
complies
with
the
general
guidelines,
except
for
the
requirement
to
retain
records
for
an
eightyear
period,
as
described
in
4(
b)(
ii)
below.

3(
f)
Confidentiality
We
hold
information
from
the
engine
manufacturers
as
confidential
until
the
associated
engines
are
available
for
purchase.
Manufacturers
may
submit
proprietary
information,
consisting
generally
of
sales
projections
and
certain
sensitive
technical
descriptions.
We
grant
confidentiality
in
accordance
with
the
Freedom
of
Information
Act,
EPA
regulations
at
40
CFR
part
2,
subpart
B,
and
class
determinations
issued
by
our
Office
of
General
Council.

3(
g)
Sensitive
Questions
We
don't
ask
sensitive
questions.
This
collection
complies
with
The
Privacy
Act
and
OMB
Circular
A­
108.
4.
Respondents
and
Information
Requested
4(
a)
Respondents/
NAICS
and
SIC
Codes
The
respondents
are
generally
involved
in
the
industries
shown
in
Table
3.

Table
3
NAICS
and
SIC
Codes
for
Respondent
Categories
Respondent
Categories
NAICS
Codesa
SIC
Codesb
Manufacturers
of
new
nonroad
SI
engines,
new
marine
engines
333618
3519
Manufacturers
of
farm
equipment
333111
3523
Manufacturers
of
construction
equipment,
recreational
marine
vessels
333112
3531
Manufacturers
of
industrial
trucks
333924
3537
Manufacturers
of
marine
vessels
 
3732
Engine
repair
and
maintenance
811310
7699
aNorth
American
Industry
Classification
System
(
NAICS)
bStandard
Industrial
Classification
(
SIC)
system
code.

4(
b)
Respondents
and
Information
Requested
(
i)
Data
Items
Manufacturers
must
send
us
an
application
for
certification,
including
emission
data
and
other
descriptive
information.
Manufacturers
must
also
send
us
reports
of
production­
line
or
other
emission
testing.

(
ii).
Respondent
Activities
Companies
retain
records
as
hard
copy
and
may
also
reduce
the
information
to
microfilm,
computer
disks,
etc.
We
require
very
little
submission
of
information
to
process
applications
for
certification.
This
reduces
the
resource
burden,
both
for
the
industry
and
for
us.
However,
because
we
don't
have
the
information
on
file,
we
depend
on
manufacturers
to
retain
the
records
to
allow
us
to
verify
compliance
throughout
the
useful
life
of
the
engines.
Eight
years
is
sufficient
time
for
most
engines.
Any
investigation
of
in­
use
engines
generally
does
not
start
until
three
or
more
years
after
the
manufacturer
completes
the
application
for
certification.

The
manufacturer
also
submits
all
emission
testing
results
generated
from
in­
use
testing
within
three
months
after
testing
is
complete
(
Large
SI
engines
only).

Companies
that
rebuild
regulated
engines
need
to
keep
records
of
their
maintenance
practices.
This
is
consistent
with
their
normal
business
practice.
Individuals
who
maintain
or
rebuild
their
own
engines
are
not
required
to
keep
records.
This
also
applies
to
owners
and
operators
of
commercial
marine
vessels
with
Category
3
engines,
where
onboard
mechanics
do
significant
maintenance
and
adjustment
of
the
engines.

In
addition,
we
require
operators
of
vessels
powered
by
Category
3
engines
to
keep
records
showing
their
position
when
servicing
the
engines.
This
information
is
readily
available
and
is,
to
a
large
extent,
already
routinely
recorded
by
operators
as
part
of
normal
procedures.
Also,
owners
of
marine
vessels
with
Category
3
engines
must
send
minimal
annual
notification
to
EPA
to
show
that
engine
maintenance
and
adjustments
have
not
caused
engines
to
be
noncompliant.
All
reports,
submissions,
notifications,
and
requests
for
approval
must
be
addressed
to:
Manager,
Engine
Programs
Group
(
6405­
J),
U.
S.
Environmental
Protection
Agency,
1200
Pennsylvania
Ave.,
Washington,
DC
20460.
Respondents
must
submit
information
in
an
approved
EPA
information
format.

5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5
(
a)
Agency
Activities
Our
certification
and
tracking
process
involves
reviewing
applications
and
emission
data
from
engine
and
vehicle
manufacturers.
From
this
data,
we
issue
certificates
of
conformity,
and
may
confirm
that
production
and
in­
use
engines
continue
to
comply
with
standards.
We
may
also
select
families
to
be
tested
in
a
given
production
year
and
require
additional
testing,
based
on
an
analysis
of
the
submitted
data.

5
(
b)
Collection
Methodology
and
Management
We
currently
use
computers
extensively
to
collect
information
from
vehicle
manufacturers.
Based
on
this
approach
as
a
model,
much
routine
information
(
test
results,
projections)
can
be
electronically
transmitted
directly
from
the
manufacturers
to
our
computer
database.
We
expect
to
publish
this
information
on
our
website
once
certified
engines
go
into
production
(
www.
epa.
gov/
otaq/).

5
(
c)
Small­
Entity
Flexibility
We
have
a
variety
of
provisions
to
ease
the
compliance
burden
on
small
businesses.
Small­
volume
manufacturers
can
generally
combine
their
products
into
a
single
engine
family
or
use
design­
based
certification
to
reduce
testing
efforts.
Testing
rates
for
the
production­
line
testing
program
decrease
or
are
waived
for
smallvolume
manufacturers.
For
in­
use
testing
of
Large
SI
engines,
the
testing
rate
is
smaller
for
companies
with
fewer
engine
families.

5(
d)
Collection
Schedule
The
principal
reporting
requirements
are
associated
with
certification
to
the
emission
standards,
which
begin
to
apply
according
to
the
schedule
shown
below.
Reporting
requirements
therefore
don't
begin
until
the
end
of
the
preceding
year
at
the
earliest.
Annual
reporting
is
based
on
the
beginning
of
the
model
year,
which
can
vary
for
each
manufacturer
and
for
each
engine
family,
as
shown
in
Table
4.
Quarterly
reporting
of
production­
line
testing
results
begins
when
certified
engines
go
into
production.
Table
4
Implementation
Schedule
Engine
Category
Implementation
Date
Large
SI
January
2004
Recreational
marine
diesel
January
2006
Category
3
marine
diesel
January
2004
6.
Estimating
Burden
and
Cost
of
the
Collection
We
estimate
burden
and
cost
estimates
separately
for
two
groups
of
companies.
First,
engine
manufacturers
comply
with
emission
standards
by
submitting
an
application
for
certification,
which
obligates
them
to
do
a
certain
amount
of
testing
to
show
they
comply
with
the
standards.
Second,
companies
that
rebuild
the
regulated
engines
need
to
keep
records
of
their
maintenance
practices,
consistent
with
their
normal
business
practice.
Due
to
industry
and
consumer
practices,
the
recordkeeping
requirements
for
rebuilding
apply
only
to
recreational
marine
diesel
and
Large
SI
engines.
The
following
discussion
develops
burden
and
cost
estimates
for
the
first
three
years
of
the
program.

6
(
a)
Estimating
Respondent
Burden
The
estimates
of
respondent
burden
utilizes
data
from
the
affected
industries
or
commercially
available
databases.
Burden
hours
per
engine
family
are
based
upon
established
hour
amounts
for
engine
families,
as
published
in
the
"
Application
for
Motor
Vehicle
Emission
Certification
and
Fuel
Economy
Labeling"
(
OMB
No.
2060­
0104).

The
burden
for
certification
testing
is
generally
based
on
conducting
two
engine
tests
for
each
engine
family,
then
using
that
test
data
for
several
years.
For
Large
SI
engine
families,
six
tests
per
family
are
expected,
since
engine
families
may
include
separate
tests
on
three
different
fuels.
The
estimated
cost
for
full
certification
testing,
including
durability
demonstration
testing,
is
$
10,000
per
engine
test
(
combining
labor
and
O&
M
expenses).
For
Category
3
marine
diesel
engines,
testing
costs
are
approximately
twice
as
high
to
account
for
the
expenses
related
to
testing
very
big
engines.
The
manufacturer's
application
for
certification
involves
an
extensive
effort
the
first
year,
followed
by
relatively
little
effort
in
subsequent
years.
We
estimate
that
manufacturers
will
conduct
new
certification
testing
every
five
years;
the
costs
have
been
estimated
on
an
annual
average
basis.

In
addition
to
testing,
manufacturers
must
prepare
the
application
for
certification
and
maintain
appropriate
records.
We
have
estimated
the
cost
of
these
combined
activities,
which
include
engineering
and
clerical
effort,
to
be
$
10,000
per
engine
family
per
certification
cycle
(
about
$
20,000
for
Category
3
marine
diesel).
As
with
the
testing
costs,
we
are
presenting
annual
average
costs.

The
burden
for
production­
line
testing
is
based
on
an
industry­
wide
calculation.
For
Large
SI
engines,
testing
is
expected
for
two
engines
from
an
engine
family
for
each
quarter
for
a
total
of
eight
tests
per
year.
For
recreational
marine
diesel
engines,
we
estimate
a
testing
rate
of
one
percent
of
production,
which
would
average
about
five
tests
per
year
for
each
engine
family.
In
general,
production­
line
testing
requirements
don't
apply
to
small­
volume
manufacturers.
Lower
testing
costs
apply
to
production­
line
testing
due
to
the
potential
to
incorporate
testing
into
the
assembly
process
on
the
production
line.
We
estimate
$
5,000
per
test
for
engine
testing.
The
rulemaking
includes
several
provisions
that
will
reduce
the
estimated
costs
for
production­
line
testing,
either
through
simplified
testing
or
reduced
testing
rates.

Large
SI
engines
will
also
be
subject
to
in­
use
testing
requirements.
EPA
may
select
up
to
25
percent
of
a
company's
engine
families
for
testing.
We
estimate
a
total
of
six
engine
tests
for
each
family
subject
to
testing.
Estimated
costs
for
each
test
are
about
$
20,000
to
take
into
account
engine
removal
and
replacement,
transport,
and
testing
over
steady­
state
and
transient
duty
cycles.
Allowing
$
5,000
for
reporting
leads
to
total
costs
of
$
125,000
per
engine
family.
These
costs
would
be
substantially
lower
if
companies
choose
to
pursue
the
flexibility
of
field­
testing
procedures,
which
includes
a
separate
set
of
emission
standards
roughly
equivalent
to
the
duty­
cycle
standards.

Rebuilders,
including
operators
of
marine
vessels
with
Category
3
engines,
must
keep
records
as
needed
to
show
that
rebuilt
engines
continue
to
meet
emission
standards,
consistent
with
the
manufacturer's
original
design.
In
addition,
owners
and
operators
of
marine
vessels
with
Category
3
engines
must
record
information
about
their
location
when
rebuilding
engines
or
making
other
adjustments
and
send
minimal
annual
notification
to
EPA
to
show
that
engine
maintenance
and
adjustments
have
not
caused
engines
to
be
noncompliant.

These
burden
estimates
apply
equally
whether
the
manufacturer
conducts
the
required
activities,
or
if
the
manufacturer
hires
a
third
party
for
some
of
these
activities.

6
(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
Labor
rates
on
a
per­
hour
basis,
are
taken
from
the
Bureau
of
Labor
Statistics
web
site
at
http://
stats.
bls.
gov/
news.
release/
ecec.
t12.
htm
(
accessed
November
24,
2000).
Technical
labor
is
$
42.89/
hr,
managerial
labor
is
$
65.19/
hr,
clerical
labor
is
$
27.11/
hr.
Labor
rates
were
multiplied
by
1.5
to
account
for
fringe
benefits
and
other
overhead
expenses.

(
ii)
Estimating
Operations
and
Maintenance
Costs
Operation
and
maintenance
costs
include
expenses
related
to
engine
testing.
Costs
are
for
laboratory
time,
the
use
of
test
equipment,
engine
parts,
fuel
and
other
supplies,
and
fabrication
of
test
tools
and
fixtures.
Direct
labor
costs
and
operations
and
maintenance
costs
combine
for
the
total
test
costs
described
above.

(
iii)
Capital/
Start­
up
Costs
Companies
required
to
conduct
testing
generally
either
have
testing
facilities
or
are
expected
to
conduct
testing
at
a
contractor's
laboratory.
Thus,
no
capital
or
startup
costs
are
anticipated
for
purchasing
emission
testing
equipment.

(
iv)
Annualizing
Capital
Costs
With
no
estimated
capital
or
start­
up
costs,
there
is
no
need
to
annualize
these
costs.

6
(
c)
Estimating
Agency
Burden
and
Cost
Our
Engine
Programs
Compliance
Group
administers
emission
certification
programs.
This
group
has
approximately
17
full­
time
employees.
We
project
25
hours
per
week
of
staff
time
(
at
$
40
per
hour,
loaded)
to
manage
engine
compliance
programs
related
to
new
emission
standards.
This
comes
to
approximately
1,250
hours
or
$
50,000
per
year
to
oversee
the
requirements
of
the
final
rule.

6
(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
The
following
tables
shows
the
labor
and
other
costs
associated
with
meeting
the
new
requirements
for
each
engine
family.
This
includes
certification
costs,
plus
the
cost
of
any
additional
testing.
Per­
family
costs
are
multiplied
by
the
number
of
engine
families
and
added
to
estimated
capital
costs
(
if
any)
to
arrive
at
an
estimated
total
cost.

In
addition,
we
estimate
that
200
companies
would
be
affected
by
new
requirements
to
keep
records
related
to
rebuilding,
maintaining,
or
adjusting
engines
(
see
Table
8);
these
companies
must
keep
records
of
their
business
practices,
but
they
don't
need
to
design
or
certify
engines
or
measure
emissions.
These
estimates
are
based
on
the
projected
costs
for
each
company
to
meet
the
requirements
of
the
rule.
Table
5
Annual
Respondent
Burden
and
Cost
 
Large
SI
Engine
Manufacturers
Information
Collection
Activity
Average
annual
burden
and
cost
per
family
#
of
Families
Annualized
Capital
&

Startup
cost
Total
Hours
and
Costs
Mgr.
@

$
65/
hr
Tech.
@

$
43/
hr
Cler.
@

$
27/
hr
Hours
per
family
Labor
cost
per
family
O&
M
Cost
Total
Hours/
yr
Total
Cost/
yr
Cert.
application
2
36
6
44
$
1,840
$
0
40
$
0
1,760
$
73,600
Recordkeeping
0.2
2.2
2
4.4
$
162
$
0
40
$
0
176
$
6,464
Cert./
durability
testing
168
168
$
7,224
$
4,776
40
$
174,419
6,720
$
480,000
Prod.
line
testing/
reporting
5
100
10
115
$
4,895
$
35,105
40
$
0
4,600
$
1,600,000
In­
use
testing/
reporting
25
725
35
785
$
33,745
$
91,255
10
$
0
7,850
$
1,250,000
Defect
reporting
2
10
10
22
$
830
$
0
40
$
0
880
$
33,200
Subtotal
Total
O&
M
cost
=
$
2,507,790
 
$
174,419
21,986
$
3,443,264
Table
6
Average
Annual
Respondent
Burden
and
Cost
 
Recreational
Marine
Diesel
Engines
Information
Collection
Activity
Average
annual
burden
and
cost
per
family
#
of
Families
Annualized
Capital
&

Startup
cost
Total
Hours
and
Costs
Mgr.
@

$
65/
hr
Tech.
@

$
43/
hr
Cler.
@

$
27/
hr
Hours
per
family
Labor
cost
per
family
O&
M
Cost
Total
Hours/
yr
Total
Cost/
yr
Cert.
application
2
36
6
44
$
1,840
$
0
38
$
0
1,672
$
69,920
Recordkeeping
0.2
2.2
2
4.4
$
162
$
0
38
$
0
167
$
6,141
Cert./
durability
testing
0
28
0
28
$
1,204
$
2,796
38
$
0
1,064
$
152,000
Prod.
line
testing/
reporting
5
100
10
115
$
4,895
$
20,105
38
$
0
4,370
$
950,000
Subtotal
Total
O&
M
cost
=
$
870,238
 
$
0
7,273
$
1,178,061
13
Table
7
Average
Annual
Respondent
Burden
and
Cost
 
Category
3
Marine
Diesel
Engines
Information
Collection
Activity
Average
annual
burden
and
cost
per
family
#
of
Families
Capital
&

Startup
cost
Total
Hours
and
Costs
Mgr.
@

$
65/
hr
Tech.
@

$
43/
hr
Cler.
@

$
27/
hr
Hours
per
family
Labor
cost
per
family
O&
M
Cost
Total
Hours/
yr
Total
Cost/
yr
Cert.
application
3
80
7
90
$
3,824
$
0
12
$
0
1,080
$
45,888
Recordkeeping
0.2
2.2
2.6
5.0
$
178
$
0
12
$
0
60
$
2,134
Cert./
durability
testing
0
56
0
56
$
2,408
$
5,592
12
$
0
672
$
96,000
Defect
reporting
1
2
2
5
$
205
$
0
12
$
0
60
$
2,460
Subtotal
Total
O&
M
cost
=
$
67,104
 
$
0
1,872
$
146,482
14
Table
8
Annual
Respondent
Burden
and
Cost
 
Rebuilders
Information
Collection
Activity
Mgr.
@

$
65/
hr
Tech.
@

$
43/
hr
Cler.
@

$
27/
hr
Company
hours/
year
Labor
cost
per
year
O&
M
Cost
Capital
cost
Total
Hours
and
Costs
#
of
companies
Total
Hours/
yr
Total
Cost/
yr
Recordkeeping
2
4
6
$
194
$
0
$
0
200
1,200
$
38,800
15
6
(
e)
Bottom­
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
Bottom­
line
burden
and
cost
for
the
first
three
years
of
the
rulemaking
are
shown
in
Table
10.
The
table
shows
industry
totals
and
average
values
for
each
respondent
by
category.
These
estimated
costs
include
startup
expenses
(
for
example,
the
purchase
of
emission
sampling
equipment
and
new
recordkeeping
software).

Table
9
Summary
of
Bottom­
line
Burden
Hours
and
Cost
Affected
Entities
Number
of
Respondents
Industry
Totals
Average
per
Respondent
Annualized
Capital
Costs
Total
O&
M
Costs
per
Year
Total
Hours
per
Year
Total
Costs
per
Year
Total
Hours
per
Year
Total
Costs
per
Year
Large
SI
engine
manufacturers
12
$
174,419
$
2,507,790
21,986
$
3,617,683
1,832
$
301,474
Recreational
marine
diesel
engine
manufacturers
12
$
0
$
870,238
7,273
$
1,178,061
606
$
98,172
Category
3
marine
diesel
engine
manufacturers
6
$
0
$
67,104
1,812
$
144,022
302
$
24,004
Engine
rebuilders
200
$
0
$
0
1,200
$
38,800
6
$
194
Total
230
$
174,419
$
3,445,132
32,271
$
4,978,566
140
$
21,646
(
ii)
Agency
Tally
Our
estimated
burden
is
approximately
1,250
hours
or
per
year
(
or
$
50,000)
to
oversee
the
requirements
of
the
final
rule,
as
described
in
Section
6(
c).

6
(
f)
Burden
Statement
Table
9
presents
the
estimated
annual
respondent
burden
for
the
different
categories
of
companies
affected
by
the
final
rule.
These
estimates
include
time
to
conduct
testing,
prepare
applications,
prepare
and
submit
reports,
and
record
and
keep
required
information.

Burden
means
the
total
time
for,
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
16
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.

Send
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques
to
the
Director,
Collection
Strategies
Division;
U.
S.
Environmental
Agency,
(
mail
code
2822T);
1200
Pennsylvania
Ave.,
N.
W.;
Washington
DC
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Office
for
EPA.
Include
the
ICR
number
in
any
correspondence.
17
Appendix
to
ICR
#
1897.04
Original
ICR
(#
1897.02)
for
marine
diesel
engines;
approved
Oct.
12,
2001
Summary
of
Bottom­
line
Burden
Hours
and
Cost
Affected
Entities
Number
of
Respondents
Total
Hours
per
Year
Total
Costs
per
Year
Manufacturers
and
Marinizers
12
20,280
$
2,453,632
Dressers
20
40
$
1,840
Rebuilders
200
1,200
$
38,800
Total
232
21,520
$
2,494,272
