PART A OF THE SUPPORTING STATEMENT

Populations, Usage and Emissions of Diesel Nonroad Equipment 

OMB Control Number 2060-0553

EPA ICR Number 2156.02



1	Identification of the Information Collection tc \l1 "1	Identification
of the Information Collection 

1(a)	Title of the Information Collection tc \l2 "1(a)	Title of the
Information Collection 

The collection is entitled:

Populations, Usage and Emissions of Diesel Nonroad Equipment

1(b)	Short Characterization/Abstract tc \l2 "1(b)	Short
Characterization/Abstract 

In response to recommendations from the National Research Council of the
National Academy of Sciences, EPA is continuing a systematic data
collection designed to improve the methods and tools used by the Agency
to estimate emissions from nonroad equipment. Data to be collected
include populations, usage rates (activity) and ‘in-use” or
“real-world” emission rates.

The collection is a survey, to be conducted by the Office of
Transportation and Air Quality (OTAQ) in the Office of Air and Radiation
(OAR). Development of rapid in-use instrumentation promises to
substantially reduce the cost of emissions measurement for nonroad
equipment. This study will combine rapid in-use measurement capability
with statistical survey design to improve the representation of nonroad
engine populations. The goal is to continue a pilot survey designed to
develop methods and protocols needed to collect data on populations,
activity and in-use emissions of diesel nonroad equipment. Response to
the survey is voluntary.

The target population includes nonroad equipment used by commercial
establishments in the construction and manufacturing sectors. The study
area for this collection will include areas in EPA Regions 5 and 7. To
estimate the prevalence of equipment ownership in the target sectors,
1,500 establishments will be requested to respond to brief interviews
regarding their equipment ownership and use. The total sample size for
instrumented measurement is 100 equipment pieces, with 50 pieces
targeted for emissions and usage measurement, respectively.

Emissions and usage will be measured using portable on-board electronic
instrumentation. Emissions instrumentation will measure carbon dioxide
(CO2) and several air pollutants on an instantaneous basis during normal
operation over a period of one to three days. Air pollutants to be
measured include carbon monoxide (CO), total hydrocarbons (THC), oxides
of nitrogen (NOx) and particulate matter (PM). The usage instrument will
measure engine on/off over a period of approximately one month. 

Data will be collected during normal operation at the respondents’
facilities or work sites.  Following quality-assurance and analysis, the
data will be stored in OTAQ’s Mobile Source Observation Database.  The
information collection will involve 517 respondents per year, requiring
99 hours per year at an annual total cost to those respondents of
$6,716. For the agency, the collection will require 4,455 hours per year
at an annual total cost to the agency of $322,415.

2	Need for and Use of The Collection tc \l1 "2	Need for and Use of The
Collection 

2(a)	Need/Authority for the Collection tc \l2 "2(a)	Need/Authority for
the Collection 

The term ‘nonroad equipment’ describes a very diverse class of
machinery and vehicles that: (1) are powered by internal combustion
engines and (2) are used for purposes other than transportation. Common
examples include crawler dozers, backhoes, tractors, forklifts, cranes,
generators, pumps and lawnmowers.

Nonroad equipment contribute substantially to mobile-source emissions,
with their contribution in relative terms expected to increase as
emissions from highway vehicles are controlled (Kean, Sawyer & Harley
2000). Based on estimates derived from diesel fuel sales published by
the Energy Information Administration (EIA 2001) and estimates from the
NONROAD model, fuel consumption in nonroad equipment accounts for 15-18%
of all distillate fuel supplied to the U.S. market in 2000 (57.2 billion
gallons). In addition, the sectors selected for inclusion in this survey
(construction and manufacturing) are important in terms diesel fuel
consumption and emissions. In the same year, the targeted sectors
accounted for approximately 35% of nonroad diesel fuel consumption,
which corresponds to approximately 8% of all diesel fuel consumed by
mobile sources (44.9 billion gallons) where mobile sources include
highway vehicles, locomotives, marine vessels and nonroad equipment.

An emissions inventory is an estimate of the quantity of a pollutant
emitted to the atmosphere in a given geographic area during a given time
period. For example, an inventory can represent the quantity of carbon
monoxide emitted by various sources in Washtenaw County, Michigan during
the spring of 2004. Within an inventory, emissions are typically
allocated by source category, with sources classified as
“stationary,” “area,” or “mobile.” Stationary sources
include large facilities with identifiable emissions outlets, such as
coal-fired power plants or industrial boilers. Area sources include
activities for which emissions are diffuse. Examples include feedlot
operations, dry cleaners or wildfires. As the name implies, mobile
sources move from place to place. They include highway motor vehicles
(cars and trucks) and nonroad equipment.

	At the request of Congress, the National Academy of Sciences published
a report on EPA’s emissions inventory modeling for mobile sources (NRC
2000). A committee of technical experts was given the primary charge of
conducting a detailed review of the MOBILE model. Nonetheless, the
report bears mention in the context of nonroad equipment inventories
because the committee also took the opportunity to make comments
concerning EPA’s NONROAD  model. Under the heading of “Technical
Issues Associated with the MOBILE Model,” the committee remarked that 

As future Tier 2 vehicle standards and corresponding sulfur-reduction
regulations reduce on-road mobile-source emissions, non-road emissions
will become a larger fraction of the total emissions. The NONROAD model
is extremely data driven, and there are many gaps in the available data.
EPA should place more emphasis on improving both the emissions factors
and activity data in this model. (p. 74)

In the executive summary, the committee emphasized the need for EPA to
design and implement programs to expand and improve the data used to
support emissions inventory estimation for nonroad equipment, and added
that:

The plan should include the population and activity data and real-world
emissions factors for gasoline and diesel engines (p. 13).

The recommendations in the NRC report have influenced the concept and
design of EPA(s new inventory model for highway vehicles, the Motor
Vehicle Emissions Simulator (MOVES). Similarly, this survey is intended
as the first step in a program to respond to recommendations concerning
the quantity and representativeness of the supporting inventory modeling
for nonroad engines.

On the basis of these recommendations, the goal of this collection
effort is to continue pilot work initiated during the previous approval.
 This work is designed to develop methods and protocols to collect data
on populations, activity and in-use emissions of diesel nonroad
equipment.

Emissions measurement by portable instrumentation is becoming
increasingly important, particularly for nonroad engines.  However,
substantial technical challenges remain in acquisition of reliable data.
An important technical issue for portable measurement is the difficulty
in acquiring reliable measurements of engine speed and torque during
operation.  Solving this problem is important because parameters are key
in describing the operational and emissions behavior of diesel engines.

For recently manufactured engines, the electronic control system is a
source of data for these parameters.  To date, we have found that
accessing the CAN is more difficult than anticipated. However, we have
learned that it will be necessary to integrate additional hardware and
software into the instrumentation. This collection proposes to develop
and test methods for acquisition of data streams from the CAN.

Additionally, to measure PM without rapidly overloading the measurement
medium, it is necessary to acquire a sample stream of exhaust that is of
known volume and directly proportional to the total exhaust flow.   

To date, particulate matter has often been measured on an aggregate
basis, meaning that particulate is collected on a medium such as a
filter over a period such as 15-60 minutes.  The mass collected (g) can
then be divided by the time period (hr) to estimate the average emission
rate over the time period measured.  However, methods involving
aggregation do not allow detailed study of particulate emissions in
relation to the specific behavior of the engine during the measurement
period.

To explore the relation between engine behavior and emissions, greater
emphasis is being placed on the measurement of particulate matter on a
continuous basis, meaning that emissions are measured repeatedly over
brief time periods such as seconds to tens of seconds.

Continuous measurement requires the adaptation of new technologies, such
as the instrument proposed for use in this collection, the
quartz-crystal microbalance (QCM).  The QCM contains a quartz crystal
set to vibrate at a known frequency.  During measurement, a sample
stream containing particulate is directed over the crystal. As the
crystal collects particulate, its vibration frequency changes.  A
previously-established calibration between vibration frequency and mass
loading allows translation of changing frequencies to cumulative
loading, and ultimately, to sequential loading.  For the QCM to be
successfully applied, it is critical to draw the proportional sample
flow, as mentioned, and it is essential that the sample flow respond
extremely rapidly to changes in the engines power output.  This
collection proposes to integrate and test these two instruments in the
field, and to evaluate the proportionality of the sample flow.

2(a)(4)	Legislative Basis tc \l3 "2(a)(4)	Legislative Basis 

The legislative basis for this data collection is Section
103(a)(1)(2)(3) of the Clean Air Act, which requires the Administrator
to:

“conduct ... research, investigations, experiments, demonstrations,
surveys, and studies relating to the causes, effects, extent,
prevention, and control of air pollution, ...” and “cooperate with
... pollution control agencies and other appropriate public or private
agencies, institutions, and organizations, and individuals in the
conduct of such activities, ...” and “conduct investigations and
research and make surveys concerning any specific problem of air
pollution in cooperation with any air pollution control agency ...”

In addition, Section 103(b)(1) of the Clean Air Act authorizes the
Administrator to:

(collect and make available, through publications and other appropriate
means, the results of and other information, including appropriate
recommendations by him in connection therewith, pertaining to such
research and other activities.(

The full text of the relevant sections is provided in Appendix A-1.

2(b)	Practical Utility/Users of the Data tc \l2 "2(b)	Practical
Utility/Users of the Data 

The principal users of the data will be EPA technical staff, for
purposes of methods development and quality-assurance of results
obtained.

The results will also guide and inform design of future collections.
Supporting analyses will evaluate the adequacy of the proposed sample
frames. They will investigate the efficiency of stage sampling. The
collection will provide valuable experience in collection of probability
samples of nonroad equipment, and in development of rapport with
respondents. Finally, analysis and evaluation of the initial collection
will enable evaluation of the cost-effectiveness of the design.

In addition, the initial results will guide and inform sample size
analyses. Data collected will provide highly valuable estimates of
variability in key variables, as well as scenarios and expected
differences needed for more refined power analyses. 

3	Nonduplication, Consultations, and Other Collection Criteria tc \l1 "3
Nonduplication, Consultations, and Other Collection Criteria 

3(a)	Nonduplication tc \l2 "3(a)	Nonduplication 

In development of this collection, EPA has attempted to locate sources
of data that would partially or wholly duplicate the information to be
collected. No such duplication was found.

To our knowledge, no other agency conducts portable emissions monitoring
of nonroad equipment during operation in the field. One previous study,
conducted by Environment Canada and the Northeast States for Coordinated
Air Use Management (NESCAUM), collected field emissions data for four
nonroad engines and one on-highway vehicle (Ainslie et al. 1999). While
the data are useful in themselves, they cannot be considered a
representative sample, and EPA’s collection effort must be broader in
scope.

3(b)	Public Notice Required Prior to ICR Submission to OMB tc \l2 "3(b)
Public Notice Required Prior to ICR Submission to OMB 

The initial announcement of the public comment period for the proposed
ICR amendment was placed in the Federal Register on August 9, 2007 (72
FR 44843). One comment was received. This comment was considered when
preparing this ICR. In addition, a second Federal Register Notice will
be published concurrent with submission of this collection to OMB.

3(c)	Consultations tc \l2 "3(c)	Consultations 

Revisions to this collection since the approval of the previous
collection have been developed in consultation with survey research
professionals contracted to conduct sampling and recruitment. The
primary technical contact is :

Robert Santos

Senior Institute Methodologist

The Urban Institute

2100 M Street, NW

Washington, DC  20037

3(d)	Effects of Less Frequent Collection tc \l2 "3(d)	Effects of Less
Frequent Collection 

For each respondent, participation in the survey is a one-time event.
Thus, periodic reporting is not requested or required.

3(e)	General Guidelines tc \l2 "3(e)	General Guidelines 

Commercial establishments participating in this collection will not be
requested to plan, generate, or retain any records or information. 
Participation in the program by each owner is on a voluntary basis. 
Further, this information collection complies with the guidelines in the
Paperwork Reduction Act (5 CFR 1320.5(d)(2)).  Specifically, the
collection does not require the respondents to:

Report information to EPA more often than quarterly;

Prepare a written response to a collection in fewer than 30 days after
receipt;

Submit more than one original document;

Retain any records for more than three years;

Participate in a statistical survey that is not designed to produce data
that can be generalized to the universe of study;

Use a statistical data classification that has not been reviewed and
approved by OMB; and

Submit any information that they may consider to be confidential,
without EPA demonstrating that it has instituted procedures to protect
the information(s confidentiality to the extent permitted by law.

3(f)	Confidentiality tc \l2 "3(f)	Confidentiality 

Data will be collected under a pledge of confidentiality for exclusively
statistical purposes, as defined in the Confidential Information
Protection and Statistical Efficiency Act of 2002 (CIPSEA). Thus, in
accordance with CIPSEA, EPA will not use or disclose survey results in
identifiable form for any non-statistical purpose.

To protect the confidentiality of respondents, the following items
allowing direct identification of individual establishments, whether
obtained from sample frames or though one or more of the survey
instruments, will not be disclosed or directly linked to survey results.
 

Establishment name(s)

Establishment address(es)

Establishment phone number(s)

Establishment contact name(s)

Equipment serial number(s)

Engine serial number(s)

Addresses or locations of respondents’ facilities or work site(s)

Work shifts for selected equipment pieces

The following additional items, whether obtained from the sample frame
or through one or more survey instruments, will be protected from
disclosure as necessary to protect individual respondents from
identification through indirect means. The methods considered for
prevention indirect disclosures are briefly described for each item,
drawing on approaches recommended for the protection of public-use
microdata by the  Federal Committee on Statistical Methodology (FCSM
2004). 

Economic Sector.  This variable is of potential value if differences in
equipment ownership or usage rates are apparent between sectors.
However, detailed reporting of economic sub-sectors may create
disclosure risks in combination with other establishment descriptors or
through the possibility of matching with other publicly available files.
Therefore, if reporting of sector appears to add utility to the file,
the level of reporting detail for economic sector will be restricted to
the 2-digit NAICS level, which is the level proposed for stratification
and analysis for this collection.

Number of Employees.  As a measure of establishment size for mining,
construction and manufacturing establishments, this measure may be very
useful, but its publication could also result in disclosure risks for
some respondents. One option to protect this variable would be coding of
responses, using the same establishment size classes proposed for use in
calculating sampling weights. In addition the proposed size classes
include top-coding at a value of 50 employees, a value low enough to
protect highly visible large establishments. 

Geographic location. Due to the small sizes of respondent pools in many
sampling units, combinations of PSU with establishment-size and
economic-sector variables could lead to disclosure risks for some
respondents. Therefore, due to the potential value of establishment-size
and economic-sector variables, the level of detail in reporting of
geographic locations of respondents within the study area will be
severely limited. For this collection, the only geographic information
to be considered for reporting will be an indication of whether the
respondent resides inside or outside of a Metropolitan Statistical Area.

Number of Equipment Pieces.  As an additional measure of establishment
size, responses for this variable would be treated similarly to those
for the number of employees.

Equipment Type: in the case of highly unique or specialized equipment
types, knowledge of equipment type could give industry experts an
important clue as to the identity of some respondents. Therefore, if
reporting of equipment type were considered to distinguish any
respondents as unique in the population or sample, individual values
would be withheld on a case by case basis. Another option would be to
categorize unique equipment types into a generic (other equipment(
category.

Engine rated power. As the typical size indicator for diesel engines,
the potential presence of very large values, e.g., 2,000 hp, could aid
knowledgeable data users in narrowing down the identity of some
respondents, especially in combination with equipment type. One option
would be to top-code power ratings at a value in the range of 600 to
1,000 hp. However, given the value of power rating in the quality
assurance of emissions measurements, it could be more useful if actual
power ratings were retained and other establishment descriptors were
suppressed to protect respondents. In such cases, EPA would consider
suppression of values for economic-sector, establishment size and
equipment type variables, as necessary to obscure the uniqueness of
particular respondents.

The identifying information listed above will not used for any purpose
other than contacting establishments to solicit or clarify responses, to
arrange site visits, to obtain equipment or engine specifications, or to
calculate sampling weights and non-response weights.  This information
will not be stored with or directly linked to survey results, but in
files stored in secure locations.  A unique respondent ID number will be
used in the database, with the link to the personal information also
stored in secure files. Contractors retained to conduct interviews and
data collection will be bound by confidentiality clauses that hold them
to the same standards to be followed by EPA personnel.

The initial letter sent to respondents will include the following pledge
of confidentiality:

‘The information your establishment provides will be used for
statistical purposes only.  In accordance with the Confidential
Information Protection provisions of Title 5, Subtitle A, Public Law
107-347 and other applicable Federal laws your responses will be kept
confidential and will not be disclosed in identifiable form to anyone
other than employees or agents without your consent.  By law, every EPA
employee as well as every agent, such as interviewers and technicians,
is subject to a jail term, a fine or both if he or she discloses ANY
identifiable information about your establishment.’

3(g)	Sensitive Questions tc \l2 "3(g)	Sensitive Questions 

The questionnaires do not ask any sensitive questions pertaining to
sexual attitudes/behavior or religious beliefs.

4	The Respondents and the Information Requested tc \l1 "4	The
Respondents and the Information Requested 

4(a)	Respondents/NAICS Codes tc \l2 "4(a)	Respondents/NAICS Codes 

As defined in Part B, section 2(a) (Target Population and Coverage,(
respondents to the survey will be commercial establishments in four
economic sectors, listed below and identified with corresponding NAICS
codes. 

Sector	

NAICS Code



Construction	

23



Manufacturing	

31-33



	

These sectors do not comprise the entire universe for the use of nonroad
equipment. Other sectors are of interest with respect to diesel
equipment use, for example, wholesale trade (NAICS 42) and  retail trade
(NAICS 44-45), as well as municipalities and government agencies.
However, we have limited the scope of this collection, to keep effort
commensurate with expected resources. In addition, a limited scope is
consistent with the emphasis that this collection will place on the
development and evaluation of feasible methods for collection of the
targeted information from establishments in different sectors.

4(b)	Information Requested tc \l2 "4(b)	Information Requested 

4(b)(i)	Data Items, Including Recordkeeping Requirements tc \l3 "4(b)(i)
Data Items, Including Recordkeeping Requirements 

Reporting Items. All items that respondents will be requested to report
are listed and described in Part B, Section 3, “Questionnaire
Development.” The survey will employ three instruments, the
“Equipment Ownership Questionnaire,” the “On-site Equipment
Inventory,” and the “Equipment Identification, Description and
Instrumentation Parameters” attached as appendices to Part B of the
Supporting Statement.

Recordkeeping Items. This collection will not request or require
respondents to compile or maintain any records.

4(b)(ii)	 Respondent Activities tc \l3 "4(b)(ii)	 Respondent Activities 

Respondent activities for this data collection include:

respond to Equipment Ownership Questionnaire (by phone interview)

respond to interview portion of On-site Equipment Inventory (by phone or
personal interview)

provide interviewer/technician access to equipment (during site visits)

In this collection, the degree of participation will differ between
establishments in the Establishment sample and those in the Equipment
sample.

5	The Information Collected ( Agency Activities, Collection Methodology,
and Information Management tc \l1 "5	The Information Collected  Agency
Activities, Collection Methodology, and Information Management 

The following sections describe Agency activities related to survey
design, oversight, and analysis, maintenance and distribution of the
information collected.  The primary activities associated with the
actual collection of information will be performed by EPA personnel or
contractors hired by the Agency.

5(a)	Agency Activities tc \l2 "5(a)	Agency Activities 

In conduction of the survey, the agency will perform the following
activities:

-	Develop questionnaires and data forms

-	Administer telephone interviews

-	Travel to and within primary sampling units (PSUs)

-	Administer site visits

-	Quality-assure completed interviews

-	Load interview responses into computer database

-	Quality-assure electronic emissions and activity measurements

-	Load emissions and activity data into computer database

-	Analyze survey results

5(b)	Collection Methodology and Management tc \l2 "5(b)	Collection
Methodology and Management 

The questionnaires to be used for the collection are final versions
developed following experience in several PSUs during the previous
approval period. 

Due to the brevity and simplicity of the questionnaires, we have used
the telephone interview as the primary collection mode for descriptive
information regarding establishments, their operations and equipment
collected during the screening interviews. Making the initial contact by
phone allows interviewers to interact with multiple potential
respondents, in order to identify and make contact with a knowledgeable
respondent.  

Once contact with a knowledgeable person is made, it is simpler and less
burdensome to simply complete the interview at that time. Asking
respondents to respond to a mail or internet questionnaire would
increase burden at that point.

Detailed information regarding equipment specifications will be
collected through direct inspection by trained technicians. In addition,
emissions and activity data will be collected by on-board electronic
instrumentation. The instrumentation is portable, non-intrusive and can
collect data over specified measurement periods with minimal
maintenance. The instrumentation is described further in Part B, Section
4(a), “Collection Methods.”

These approaches bring two significant benefits. First, they reduce
respondent burden in that respondents will not asked to provide detailed
information on specific equipment pieces, nor asked to recall usage
patterns for specific equipment pieces over periods of weeks to a year.
Second, the reliability and objectivity of the information collected
will be improved through consistent application of pre-specified
approaches by knowledgeable technicians.

To ensure data quality for interview information, each interview
response will be reviewed for completeness and internal consistency.
Emissions and activity data collected via instrumentation will be
quality-assured through use of computer algorithms. Time series for key
variables will also be plotted and visually checked on a case-by-case
basis. 

Data will be stored in the “Mobile Source Observation Database,”
(MSOD), an Oracle( database residing on an Agency server. This database
is available to the public on request on CD-ROM, and can also be
accessed from the server via a viewer based on Microsoft Access(. Thus,
users need not be equipped with Oracle software or expertise to access
the database.

5(c)	Small Entity Flexibility tc \l2 "5(c)	Small Entity Flexibility 

As described above, collection methods for the survey have been designed
to keep the burden of participation to a minimum, for both small and
large respondents.  Additionally, participation in the data collection
is voluntary, giving small entities flexibility to decline participation
at their option.

5(d)	Collection Schedule tc \l2 "5(d)	Collection Schedule 

The tentative schedule below assumes that clearance for this collection
will be obtained by March, 2008. For each task, we show the date
targeted for its completion.

Task	

Date to be Completed



Draw samples	

February, 2008



Field PSUs in Region 7	

May, 2008



Field PSUs in Region 5 

	

September, 2011



	





6	Estimating the Burden and Cost of The Collection tc \l1 "6	Estimating
the Burden and Cost of The Collection 

6(a)	Estimating Respondent Burden tc \l2 "6(a)	Estimating Respondent
Burden 

Table A.1 presents initial estimates of burden and cost for respondents
participating in the collection. In large establishments, we assume that
the knowledgeable respondent would often be a staff member such as a
fleet manager or senior mechanic, whereas in smaller establishments, the
knowledgeable respondent is more likely to be an owner or proprietor.
For this collection, we have listed the times for interview response
primarily under the heading of “Managerial.” Estimated times for a
knowledgeable respondent to complete the Ownership and Inventory
interviews and to provide equipment access are 8 minutes, 17 minutes and
25 minutes, respectively. 

6(b)	Respondent Costs tc \l2 "6(b)	Respondent Costs 

Table A.1 presents estimated burden and cost to respondents.

6(b)(i)	Labor Costs tc \l3 "6(b)(i)	Labor Costs 

Labor Costs are based on estimates of “wages and salaries” reported
by the Bureau of Labor Statistics in Employer Cost of Employee
Compensation (BLS, 2007). The values used represent compensation rates
for “Goods Producing Industries,” which include Mining, Construction
and Manufacturing. We translated the BLS worker categories into
corresponding ICR labor categories as follows. “Managerial,
professional and related” workers were designated as “Managerial.”
Correspondingly, “construction and maintenance” workers were
designated as “Technical,” and finally, “sales and office”
workers were designated as “Clerical.” To represent the complete
cost of labor, the total compensation rates have been increased by an
additional 100% to account for respondents’ overhead costs.
Corresponding compensation rates for each category are listed in Table
A.1.

6(b)(ii)	Capital and Operations Costs tc \l3 "6(b)(ii)	Capital and
Operations Costs 

For respondents, participation in this collection will not require any
capital or startup costs, nor will it require operating or maintenance
costs. Thus, no costs in either of these two categories are represented
in Table A.1.



Table A.1  Annual Respondent Burden and Cost1



	

Respondent Activity	

Respondent Time by Labor Category (hr/respondent)	

Subtotal  (hr/respondent)	

Labor Cost ($/respondent)	

No. Respondents	

Total time

 (hr)	

Total Cost

 ($)



	

	

Managerial

($70.92/hr)	

Technical

($40.30/hr)	

Clerical

($36.22/hr)	

	

	

	

	





	

Screening Interview	

0.133	

0.00	

0.00	

0.133	

$9.46	

  500	

66.6	

$4 ,723



	

Follow-up Contacts 	

0.083	

0.05	

0.00	

0.133	

$7.93	

 33	

 4.4	

$262



	

Schedule Site inventory	

0.083	

0.05	

0.00	

0.133	

$7.93	

33	

 4.4	

$262



	

On-site inventory interview	

0.117	

0.05	

0.00	

0.167	

$10.29	

33	

5.5	

$ 340



	Schedule Emissions/activity measurement

	

0.083	

0.03	

0.00	

0.117	

$7.25	

33	

3.85	$240

	Emissions/activity measurement	0.333	0.083	0.00	0.417	$27.00	33	13.75	$
 890



TOTAL	

	

	

	

	



98.5	$6,720



1 Rows and columns may not sum exactly due to independent rounding.



6(c)	Agency Burden and Cost tc \l2 "6(c)	Agency Burden and Cost 

Table A.2 presents Agency burden and cost, with separate estimates
presented for Contractor personnel and Agency staff.

6(c)(i)	Agency Burden tc \l3 "6(c)(i)	Agency Burden 

6(c)(i)(1)	Screening Interviews tc \l4 "6(c)(i)(1)	Establishment Sample 

Table A.2 presents estimated agency labor hours for each activity listed
above in Section 4(a). We have separated labor hours into two
components, those hours to be worked by Agency staff and those to be
worked by contractor personnel. In general, the contractor will conduct
the phone interviews, enter the data and perform initial quality
assurance, following which the contractor will transfer the data to EPA.
Agency personnel will then load the results into an EPA database and
perform quality-assurance and substantive analyses.

For contractor personnel, most of the time represents the conduction of
interviews, follow-up and scheduling. Time for interviews includes 8
minutes for interview completion following a successful contact.  For
agency staff, we assume that three technical people spend two hours per
week in meetings with the contractor, to oversee progress. 

6(c)(i)(2)	Emissions and Activity Measurement tc \l4 "6(c)(i)(2)
Equipment Sample 

Tables A.3 also presents Agency and contractor hours for site
inventories and subsequent field work to be performed under contract.
Thus, recruitment, interviewing and instrumentation will be performed by
contract personnel. EPA staff will play active roles in oversight and
quality assurance, and data analysis.

Contractor labor estimates for field work assume that a field team of
6.3 members can perform emissions measurement on 1.5 equipment pieces
per work week, along with associated activity measurement.  Each work
week is assumed to be 55 hours, and the target number of pieces to be
measured determines the number of weeks that the team will be in the
field.  The product of the number of personnel, the length of the work
week and the length of the field campaign determine the total number of
person-hours contributed by contractors.

Contractor hours for quality assurance and analysis assume that four
contract personnel will contribute 0.25 full-time equivalents to the
project over a period of 25 weeks.  This allocation is equivalent to one
person working full-time on the project over this period.

6(c)(ii)	Agency Costs tc \l3 "6(c)(ii)	Agency Costs 

6(c)(ii)(1)	Labor Costs tc \l4 "6(c)(ii)(1)	Labor Costs 

Contract Labor Costs. Labor Costs for contract personnel are taken from
Employer Costs for Employee Compensation (BLS, 2007). Values used
represent “wages and salaries” for selected worker categories under
the heading of “Service-providing Industries.” We assumed
equivalence between BLS worker categories and ICR Labor categories as
listed below, with their respective hourly compensation rates:

BLS Worker Category	

ICR Labor Category	

Total Compensation ($/hr)



Management, professional and related	

Managerial	

32.35



Management, professional and related	

Technical	

32.35



Sales and Office	

Clerical	

14.59



The labor category “technical” represents an engineer, with academic
training at the Bachelor’s Degree level, also having received
project-specific training in the installation and operation of the
on-board instruments. To represent “fully-loaded” compensation
rates, we increased the total compensation rates by an additional factor
of 100% to represent contractor overhead costs.

Agency Labor Costs.  Labor Costs for EPA staff were taken from the 2007
General Schedule for Civilian Federal Employees. Based on the Schedule,
we have assumed average hourly labor costs of $50.54 for managerial
personnel, $36.36 for technical personnel, and $17.25 for clerical
personnel. These assignments correspond to levels of GS-15, GS-13 and
GS-7, respectively, at step-5 pay rates. We have multiplied the hourly
labor rates by a “benefits multiplier” of 1.6, to represent the
total cost of employment for Federal staff (OEI, 1999).

6(c)(ii)(2)	Capital and Operations Costs tc \l4 "6(c)(ii)(2)	Capital and
Operations Costs 

Screening Interviews. Capital costs represent the cost of purchasing
databases of establishments for the study area to serve as the sample
frame. Given a cost of $0.10 per record, a listing of 25,000
establishments for the study area comes to approximately $2,500. For the
more-detailed supplementary frame, we estimated cost for a 15-county
study area at $4,000 per county for a total cost of approximately
$60,000. 

Operating costs associated with the interviews represent the costs of
supplies and postage for the initial letter to be mailed to respondents.


Emissions and Activity Measurement. We estimate that approximately five
emissions-measurement instruments and approximately 60
activity-measurement units will be used to conduct the data collection.
Because a separate program and budget exist to develop and acquire these
instruments, which are intended for use with multiple projects, we have
assigned no capital or startup costs for the equipment sample. Operating
costs for emissions and activity measurement represent costs for
additional equipment and tools, and for consumables such as batteries
and calibration gases.



Table A.3 Annual Agency Burden and Cost





Information Collection Activity	

Labor Hours Per Respondent2	

Labor Costs ($/Respondent)	

Capital Cost	

O & M

Cost	

No.

Establ.	

Total Time (hr)2	

Total Cost 

($)2



	

EPA	

Contractor	

Total	

EPA	

Cont.	

Total	

($/Respondent)	

	

	





	

Man.	

Tech.	

Cler.	

Man.	

Tech.	

Techn.	

Cler.	

EPA	

Cont.	

	

	

	

	

	

	

	





Administer telephone interviews

0.024	

	

0.014	

0.162



0.004	

0.024	

0.180	

1.40	

11.58	

12.97	

41.50	

0.00	

  500	

102	

 27,210



Quality-assure completed interviews

0.003

0.002	0.024

0.001	0.003	0.027	0.19	1.71	1.90	0.00	0.00	   500	15	  950

Load results into computer database

0.002

0.002	0.024

0.001	0.002	0.027	0.09	1.71	1.81	0.00	0.00	  500	14	  903

Analyze survey results



0.003

0.004	0.048

0.001	0.003	0.053	0.19	3.43	3.62	0.00	0.00	  500	28	 1,806

Conduct site inventories



0.666

2.079	14.38

0.866	0.666	17.33	39	1,095	1,134	0.00	0.00	 33	599	37,774

Conduct emissions measurements

1.332

16.63	115.0

6.930	1.332	138.6	77.50	8,765	8,842	120.00	1,558	17	2330	157,865

Conduct activity measurements

1.332

6.93	47.93

2.889	1.332	57.75	77.50	3,650	3,730	500.00	275.00	17	  984	 71,946

Quality-assure emissions measurements

0.75

0.960	6.65

0.400	0.75	8.00	43.63	505.9	549.5	0.00	0.00	17	  146	 9,150

Quality-assure activity measurements

0.75

0.84	5.810

0.350	0.75	7.00	43.63	442.6	486.3	0.00	0.00	17	  130	 8,096



Load data into database

0.75

0.36	2.490

0.150	0.75	3.00	43.63	189.7	233.4	0.00	0.00	17	   62	 3,885



Analyze results, draft report

0.75

0.240	1.660

0.100	0.75	2.00	43.63	126.5	170.1	0.00	0.00	17	   46	2,832



TOTAL















  4,455	  322,415

1 Rows and columns may not sum exactly due to independent rounding.

2 Labor categories are abbreviated as follows: “Man.,” “Tech.,”
“Techn.,” and “Cler.” Represent “Managerial,”
“Technical,” “Technician,” and “Clerical” personnel,
respectively.

6(d)	Estimating the Respondent Universe and Total Burden tc \l2 "6(d)
Estimating the Respondent Universe and Total Burden 

Table A.1 presents annual burden and costs for respondents, by activity.
The respondent universe is determined by the proposed sample sizes. We
anticipate up to 500 completed interviews, at a total annual burden and
cost to respondents of 67 hours and  $4,723, respectively. For emissions
and activity measurement, we anticipate that 17 establishments will
participate, with the total annual burden and cost to respondents
estimated of 32 hours and $1,993, respectively. See Table A.4, below.

Table A.3 presents total burden and cost for the Agency, by activity.
For the Agency, numbers of respondents, burdens and cost vary interviews
and field work. For screening interviews, the respondent universe is 500
establishments, at an estimated burden and cost to the Agency of 160
hours and $30,867. For emissions and activity measurement, we anticipate
17 establishments at a estimated Agency burden and cost of 4,295 hours
and $291,547. 

6(e)	Bottom Line Burden Hours and Cost Tables tc \l2 "6(e)	Bottom Line
Burden Hours and Cost Tables 

6(e)(i)	Respondent Tally tc \l3 "6(e)(i)	Respondent Tally 

Table A.4 presents total Respondent burden hours and costs. Estimates
are presented separately for the Establishment and Equipment samples.

Table A.4  Total Estimated Annual Respondent Burden and Cost

	





Collection Component	

No. Respondents	

No. Activities	

Total Hours	

Total Labor Cost	

Total Capital Cost	

Total O&M Cost



Screening Interviews	

500	

500	

 67	

$4,723	

$0	

$0



Emissions and Activity Measurements	

17	

  95	

   32	

$ 1993	

$0	

$0



Total	

    517	

 595	

 99	

$6,716	

$0	

$0



	





6(e)(ii)	Agency Tally

 tc \l3 "6(e)(ii)	Agency Tally 

Table A.5below presents total burden and cost to the Agency for the
Establishment and Equipment Samples, and by Respondent Group within the
Equipment Sample.

Table A.5 Total Estimated Annual Agency Burden and Cost

	





Collection Component	

No. Respondents	

No. Activities	

Total Hours	

Total Labor Cost	

Total Capital Cost	

Total O&M Cost



Screening Interviews	

500	

 2,000	

  160	

$ 10,138	

$20,729	

$    0



Emissions and Activity measurement	

 17	

  120	

 4,295	

$271,060	

$10,323	

$10,164



Total	

  517	

 2,120	

4,455	

  $281,198	

$31,052	

$ 10,164







6(f)	Reasons for Change in Burden tc \l2 "6(f)	Reasons for Change in
Burden 

There is a reduction in burden due to program changes from the previous
ICR. First, we propose to contact fewer respondents overall.  Second,
the burden for each respondent has decreased.  Current estimates are
based on experience acquired during the previous approval, and show that
estimates in the previous submission were overestimated.

6(g)	Burden Statements tc \l2 "6(g)	Burden Statements 

The public reporting and recordkeeping burden for this collection of
information is estimated to average 8 minutes per response for
respondents participating only in screening interviews, and 20 minutes
per response for respondents also participating in emissions and usage
measurement.  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.

To 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,
EPA has established a public docket for this ICR under Docket ID No.
EPA-HQ-OAR-2003-0225, which is available for public viewing at the Air
and Radiation Docket in the EPA Docket Center (EPA/DC), EPA West, Room
3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center
Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through
Friday, excluding legal holidays.  The telephone number for the Reading
Room is (202) 566-1744, and the telephone number for the Air and
Radiation Docket is (202) 566-1742.  An electronic version of the public
docket is available at www.regulations.gov.  This site can be used to
submit or view public comments, access the index listing of the contents
of the public docket, and to access those documents in the public docket
that are available electronically.  When in the system, select
“search,” then key in the Docket ID Number identified above.  Also,
you can send comments 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.  Please include
the EPA Docket ID No. EPA-HQ-OAR-2003-0225 and OMB control number
2060-0553 in any correspondence.

REFERENCES tc \l1 "REFERENCES 

Ainslie, B., G. Rideout, C. Cooper and D. McKinnon. 1999.  The Impact of
Retrofit Exhaust Control Technologies on Emissions from Heavy-Duty
Diesel Construction Equipment. SAE Technical Paper Series 1999-01-0110.

Bureau of Labor Statistics. 2003. Employer Costs for Employee
Compensation-June 2007. USDL: 07-1434. U.S. Department of Labor,
Washington, D.C.

Federal Committee on Statistical Methodology.  2004. Report of
Statistical Disclosure Limitation Methodology.  Subcommittee on
Disclosure Limitation Methodology. Statistical Policy Office, Office of
Information and Regulatory Affairs, Office of Management and Budget.
Statistical Policy Working Paper 22.
http://www.fcsm.gov/working-papers/spwp22.html. May, 2004. 

National Research Council. 2000. Modeling Mobile-Source Emissions.
Committee to Review EPA’s Mobile-Source Emissions Factor (MOBILE)
Model. National Academy Press, Washington D.C.

Office of Environmental Information. 1999.  ICR Handbook: EPA’s Guide
to Writing Information Collection Requests Under the Paperwork Reduction
Act of 1995. Collection Strategies Division, U.S. Environmental
Protection Agency. Washington, D.C.





APPENDIX A-1 tc \l1 "APPENDIX A-2 

Relevant Sections of Statutes

The Statutes relevant to this collection are (103(a) and (103(b) of the
Clean Air Act, listed below:

Sec. 103. (a) The Administrator shall establish a national research and
development program for the prevention and control of air pollution and
as part of such program shall - 

(1) conduct, and promote the coordination and acceleration of, research,
investigations,  experiments, demonstrations, surveys, and studies
relating to the causes, effects (including health and welfare effects),
extent, prevention, and control of air pollution;

(2) encourage, cooperate with, and render technical services and provide
financial assistance to air pollution control agencies and other
appropriate public or private agencies, institutions, and organizations,
and individuals in the conduct of such activities;

(3) conduct investigations and research and make surveys concerning any
specific problem of air pollution in cooperation with any air pollution
control agency with a view to recommending a solution of such problem,
if he is requested to do so by such agency or if, in his judgment, such
problem may affect any community or communities in a State other than
that in which the source of the matter causing or contributing to the
pollution is located;

(4) establish technical advisory committees composed of recognized
experts in various  aspects of air pollution to assist in the
examination and evaluation of research progress and proposals and to
avoid duplication of research; and

(5) conduct and promote coordination and acceleration of training  for
individuals  relating to the causes, effects, extent, prevention, and
control of air pollution.

(b) In carrying out the provisions of the preceding subsection the
Administrator is authorized to - 

(1) collect and make available, through publications and other
appropriate means, the results of and other information, including
appropriate recommendations by him in connection therewith, pertaining
to such research and other activities;

(2) cooperate with other Federal departments and agencies, with air
pollution control agencies, with other public and private agencies,
institutions, and organizations, and with any industries involved, in
the preparation and conduct of such research and other activities;

(3) make grants to air pollution control agencies, to other public or
nonprofit private  agencies, institutions, and organizations, and  to
individuals, for purposes stated in subsection (a)(1) of this section;

(4) contract with public or private agencies, institutions, and
organizations, and with  individuals, without regard to sections 3648
and 3709 of the Revised Statutes (31 U.S.C. 529; 41 U.S.C. 5);

(5) establish and maintain research fellowships, in the Environmental
Protection Agency  and at public or  nonprofit private educational
institutions or research organizations;

(6) collect and disseminate, in cooperation with other Federal
departments and agencies, and with other public or private agencies,
institutions, and organizations having related responsibilities, basic
data on chemical, physical, and biological effects of varying air 
quality and other information pertaining to air pollution and the
prevention and control thereof;

(7) develop effective and practical processes, methods, and prototype
devices for the prevention or control of air pollution; and

(8) construct facilities, provide equipment, and employ staff as
necessary to carry out this Act.

In carrying out the provisions of subsection (a), the Administrator
shall provide training for, and make training grants to, personnel of
air pollution control agencies and other persons with suitable
qualifications and make grants to such agencies, to other public or
nonprofit private agencies, institutions, and organizations for the
purposes stated in subsection (a)(5). Reasonable fees may be charged for
such training provided to persons other than personnel of air pollution 
control agencies but such training shall be provided to such personnel
of air pollution control agencies without charge.

	

 PAGE  2 

	

( PAGE  23 (

