INFORMATION
COLLECTION
REQUEST
SUPPORTING
STATEMENT
In­
Use
Testing
of
On­
Road
Heavy­
Duty
Diesel
Engines
and
Vehicles
(
Final
Rule)

June
2005
Assessment
and
Standards
Division
Office
of
Transportation
and
Air
Quality
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
1
Information
Collection
Request
1(
a).
Title
Information
Requirements
for
In­
Use
Testing
of
On­
Road
Heavy­
Duty
Diesel
Engines
and
Vehicles
ICR
Tracking
Number:
1684.08
1(
b).
Short
Characterization
The
U.
S.
Environmental
Protection
Agency
(
EPA)
is
establishing
a
manufacturer­
run,
inuse
emissions
testing
program
for
heavy­
duty
diesel
trucks.
This
rule
implements
a
June
2003
settlement
agreement
between
the
Engine
Manufacturers
Association
(
EMA)
and
EPA.
Under
this
in­
use
testing
program,
manufacturers
will
measure
gaseous
and
particulate
exhaust
emissions
from
diesel
engines
using
portable
onboard
emission
measurement
systems.
We
and
the
regulated
companies
will
use
the
data
to
ensure
compliance
with
the
Not­
to­
Exceed
(
NTE)
emission
standards,
and
to
characterize
the
in­
use
emissions
performance
of
these
vehicles.
Information
such
as
engine
family
and
emission
rates
for
specific
pollutants,
are
examples
of
what
we
will
require.
Manufacturers
generally
send
us
the
data
they
collect
and
keep
these
records
and
other
pertinent
information.
We
may
request
to
see
background
detail
on
any
of
these
records.
This
ICR
is
a
revision
to
the
existing
information
collection
approved
under
OMB
control
number
2060­
0287
(
ICR
1684.06).
The
revisions
generally
include
testing
and
reporting
requirements
for
heavy­
duty
diesel
trucks.

2.
Need
For
and
Use
of
the
Collection
2(
a).
Need/
Authority
for
the
Collection
The
data
we
require
in
this
ICR
are
needed
ensure
compliance
with
already
promulgated
emission
standards
under
Title
II
of
the
Clean
Air
Act,
as
amended
in
1990.
In
particular,
the
authority
for
this
program
is
contained
in
sections
202­
208
of
the
Act.
This
program
accomplishes
this
goal
at
a
greatly
reduced
cost
by
using
onboard,
portable
emission
measurement
systems
compared
to
traditional
testing
programs
that
rely
on
laboratory
testing
using
engine
dynamometers.

2(
b).
Use/
Users
of
the
Data
We
will
oversee
the
in­
use
testing
program
and
maintain
the
program
database.
We
will
use
the
data
items
to
verify
compliance
with
the
NTE
emission
standards,
help
assure
compliance
with
other
emission
requirements,
and
characterize
the
in­
use
emissions
performance
of
heavyduty
diesel
trucks
for
emission
inventory
purposes.
Engine
manufacturers
are
expected
to
use
the
2
data
for
compliance
purposes
and
to
aid
in
the
design
of
future
engine
emission
control
technology.

3.
Nonduplication,
Consultations,
and
other
Collection
Criteria
3(
a).
Nonduplication
The
information
being
requested
in
this
ICR
is
unique
to
the
in­
use
testing
program
and
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
to
establish
the
in­
use
testing
program
on
June
10,
2004.
The
proposed
rule
included
invitations
to
comment
on
the
ICR.
We
received
comments
on
several
issues
related
to
information
collection
as
part.
The
most
significant
comments
and
our
responses
are
summarized
in
the
following
table.

Commenter
Comment
Response
EMA
EPA's
proposal
included
a
requirement
to
include
more
data
than
necessary,
and
no
EPA
notification
should
be
required
before
making
certain
vehicle
repairs
or
when
an
owner
refuses
to
take
part
in
the
program.
We
have
reviewed
the
data­
reporting
requirements
and
found
several
items
that
manufacturers
should
record
and
retain,
but
would
not
need
to
report
routinely.
A
substantial
reporting
requirement
remains,
because
EPA's
ability
to
manage
this
program
depends
on
an
ability
to
review
an
extensive
amount
of
information
collected
from
the
manufacturers'
testing
efforts.
We
have
also
made
changes
so
that
manufacturers
do
not
have
to
notify
us
before
making
certain
vehicle
repairs
or
when
an
owner
refuses
to
take
part
in
the
program.

EMA
The
measurement
technology
is
not
ready
for
measuring
PM
emissions.
We
have
delayed
the
start
of
the
program
for
testing
PM
emissions
and
are
undertaking
an
effort
to
work
with
manufacturers
to
quantify
measurement
accuracies.
This
issue
is
discussed
further
in
the
final­
rule
documentation.

3(
c)
Consultations
We
had
many
meetings
with
the
Engine
Manufacturers
Association
(
EMA)
and
several
of
their
member
companies
that
will
be
subject
to
the
new
testing
requirements
as
part
of
the
negotiated
program
outline
and
court
settlement
of
their
lawsuits.
A
number
of
these
meetings
included
discussions
of
the
associated
reporting
and
recordkeeping
requirements.
These
contacts
before
the
proposal
occurred
over
the
period
from
2002
through
mid­
2004.
The
principal
participants
from
EMA
included
Jed
Mandel
and
Tim
French.
These
meetings
continued
after
the
proposal,
with
frequent
exchanges,
discussions,
meetings,
and
phone
calls.
3
3(
d)
Effects
of
Less
Frequent
Collection
We
require
that
manufacturers
report
test
data
30
days
after
the
end
of
each
calendar
quarter
for
each
engine
family
that
was
tested
during
the
calendar
quarter.
This
reporting
frequency
is
necessary
to
allow
an
adequate
response
to
any
problem
that
may
arise
and
to
provide
further
guidance
on
any
additional
testing
that
may
be
required
under
the
program
for
a
specific
engine
family.

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

3(
f)
Confidentiality
Manufacturers
will
submit
a
small
amount
of
confidential
information
under
the
terms
of
the
in­
use
testing
program.
This
is
needed
for
use
to
evaluate
the
testing
data
for
determining
compliance
with
the
emission
standards.

3(
g)
Sensitive
Questions
We
do
not
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
2.

Table
1
NAICS
and
SIC
Codes
for
Respondent
Categories
Respondent
Categories
NAICS
Codesa
SIC
Codesb
New
heavy­
duty
diesel
engine
manufacturers
336112
and
336120
3711
Commercial
Importers
of
Vehicles
and
Vehicle
Components
811112
and
811198
7533
and
7549
aNorth
American
Industry
Classification
System
(
NAICS)
bStandard
Industrial
Classification
(
SIC)
system
code.

4(
b)
Respondents
and
Information
Requested
(
i)
Data
Items
4
For
each
engine
family
tested
under
the
program,
an
engine
manufacturer
must
send
us
emission
data,
whether
the
test
vehicle
or
engine
family
passed
or
failed
the
testing
criteria,
and
other
descriptive
information.
They
must
also
retain
test
data
from
incomplete
tests,
invalid
tests,
and
any
additional
tests
that
were
voluntarily
conducted
on
an
engine
family.
This
information
may
be
submitted
to
us
upon
our
request.
Finally,
manufacturers
my
voluntarily
send
us
a
onetime
test
program
description
identifying
how
they
will
recruit,
screen,
and
test
vehicles
under
the
program.
Manufacturers
must
notify
us
only
if
they
reject
a
prospective
test
vehicle
from
the
program
for
any
reason
other
than
those
specified
in
the
regulations.

(
ii).
Respondent
Activities
Companies
will
retain
most
records
in
electronic
form,
i.
e.,
computer
disks.
Some
information
may
be
retained
as
hard
copy,
but
this
should
be
limited.
This
reduces
the
resource
burden,
both
for
the
industry
and
for
us.
We
will
require
that
the
information
be
kept
for
five
years
after
testing
of
the
engine
family
is
completed.
This
time
is
sufficient
to
conduct
any
investigation
of
a
potential
in­
use
noncompliance
for
an
engine
family
that
may
fail
the
testing
criteria
under
the
program.
Finally,
engine
manufacturers
must
get
our
approval
prior
to
testing
a
vehicle
if
they
want
to
adjust
anything
on
the
engine
which
is
not
considered
to
be
an
adjustable
parameter,
or
if
they
wish
to
perform
maintenance
on
the
engine
related
to
an
onboard
diagnostics
trouble
code
or
malfunction
indicator
light.

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.
This
format
will
be
developed
jointly
by
EPA
and
the
engine
manufacturers.

5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5
(
a)
Agency
Activities
We
will
identify
up
to
25
percent
of
each
manufacturer's
engine
families
for
testing
each
year
(
about
18
families),
review
a
manufacturer's
voluntary
one­
time
test
plan
and
any
subsequent
revisions,
review
any
requests
to
adjust
or
repair
vehicles
prior
to
testing
if
such
adjustments
or
repairs
are
not
allowed
by
the
regulations,
evaluate
test
results,
and
direct
additional
testing
for
any
engine
family
as
specified
in
the
regulations.
Manufacturers
are
required
to
retain
relevant
information
for
five
years
after
the
testing
results
for
an
engine
family
are
submitted
to
EPA.

5
(
b)
Collection
Methodology
and
Management
5
We
currently
use
computers
extensively
to
collect
information
from
vehicle
manufacturers.
Based
on
this
approach
as
a
model,
all
test
data
will
be
electronically
transmitted
directly
from
the
manufacturers
to
our
computer
database.
The
reporting
format
will
be
developed
in
cooperation
with
the
engine
manufacturers.
The
resulting
test
database
will
be
available
to
the
manufacturers
and
public.

5
(
c)
Small­
Entity
Flexibility
No
small
entities
are
regulated
by
the
in­
use
testing
program.

5(
d)
Collection
Schedule
The
reporting
requirements
will
begin
with
the
small­
scale
pilot
program
in
calendar
year
2005.
Manufacturers
will
report
test
results
for
any
engine
family
designated
for
testing
within
30
days
after
the
calendar
year
quarter
in
which
testing
is
completed.

6.
Estimating
Burden
and
Cost
of
the
Collection
The
following
discussion
develops
annual
burden
and
cost
estimates
for
the
program.

6
(
a)
Estimating
Respondent
Burden
The
estimates
of
respondent
burden
are
based
on
our
direct
experience
in
conducting
inuse
testing
of
heavy­
duty
trucks
with
portable
emission
measurement
systems
under
the
1998
consent
decrees
with
manufacturers
who
had
been
found
in
nonconformance
with
EPA
emission
standards,
our
continued
development
of
portable
measurement
systems,
and
our
contract
to
conduct
a
large
scale,
in­
use
testing
pilot
program
in
Kansas
City,
Missouri
for
passenger
cars.
Further,
our
estimates
are
based
on
a
reasonable
representation
of
how
manufacturers
are
likely
to
design
and
conduct
testing
under
the
new
program.
Alternatively,
if
an
engine
manufacturer
decides
to
contract
for
testing
services,
we
expect
the
service
provider
to
similarly
design
and
conduct
the
testing
campaign.

The
key
work
elements
involved
in
the
in­
use
testing
program
are
as
follows:

S
Vehicle
recruiting
and
pre­
screening
of
prospective
test
vehicles
will
be
done
by
telephone
or
other
means
prior
to
the
test
site
visit.

S
All
portable
measurement
systems
will
be
inspected
and
pre­
calibrated
at
the
manufacturer's
facility
prior
to
deployment
in
the
field.

S
Field
testing
will
be
conducted
by
two
people.
One
is
an
engineer
and
the
other
a
qualified
technician.
Both
are
capable
of
installing
and
operating
the
portable
measurement
systems,
screening
vehicles
for
OBD
trouble
codes
and
MIL
indications,
performing
maintenance
on
the
portable
systems,
etc.
The
technician
is
also
capable
of
performing
all
required
inspections
of
the
vehicle's
mechanical,
electrical,
and
emission
6
control
systems;
as
well
as
performing
allowable
maintenance
and
the
setting
of
adjustable
engine
parameters
as
required.

S
The
test
engineer
and
technician
will
coordinate
their
activities
to
optimize
their
productivity.
For
example,
the
engineer
may
acquire
and
enter
a
vehicle's
history
and
vital
statistics
into
an
electronic
database
concurrently
while
the
technician
performs
vehicle
inspection
and
allowable
maintenance.

S
Test
vehicles
for
an
engine
family
are
obtained
from
two
independent
sources,
as
required
by
the
regulation.
It
is
assumed
that
the
sources
are
located
relatively
close
to
each
other
to
minimize
travel
distances
between
test
sites.

S
The
test
sites
are
not
necessarily
in
relatively
close
proximity
to
a
manufacturer's
technical
center,
test
center,
maintenance
facility,
or
other
similar
location
thus
increasing
personnel
travel
and
field
logistics
costs.

S
In
many
cases
test
vehicles
will
depart
and
not
return
to
the
same
location
the
same
day,
necessitating
an
overnight
stay.

S
Field
personnel
have
access
to
the
test
vehicles
and
a
service
location
before
and
after
the
shift
day
as
needed
to
install
and
remove
the
portable
measurement
devices.
Special
arrangements
with
the
vehicle
owner/
operator
may
be
necessary.

S
Three
portable
emission
measurement
systems
will
be
deployed
simultaneously
during
a
test
site
visit
when
possible,
i.
e.,
two
vehicles
will
be
tested
at
the
same
time.

S
All
necessary
tools,
spare
parts,
testing
supplies,
office
supplies,
etc.
will
be
taken
to
or
otherwise
supplied
at
the
site
of
testing
to
avoid
unnecessary
delays.

6
(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
Labor
Costs
are
based
on
estimates
of
"
total
compensation"
reported
by
the
Bureau
of
Labor
Statistics
in
Employer
Cost
of
Employee
Compensation
(
BLS,
2003).
These
values
were
inflated
by
the
2.7
percent
change
in
the
Consumer
Price
Index
between
2003
and
2004
to
estimate
2004
dollars.
The
values
used
represent
compensation
rates
for
"
Goods
Producing
Industries,"
which
include
Mining,
Construction
and
Manufacturing.
Total
compensation
includes
wages
and
salaries,
plus
paid
leave,
supplemental
pay
and
insurance.

We
translated
the
BLS
worker
categories
into
corresponding
ICR
labor
categories
as
follows.
"
Executive,
Administrative
and
Managerial"
workers
were
designated
as
"
Managerial."
Correspondingly,
"
Professional
Speciality
and
Technical"
workers
were
designated
as
"
Technical,"
and
finally,
"
Precision
Production,
Craft,
and
Repair"
workers
were
designated
as
"
Engineer."
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
hourly
compensation
rates
for
each
category
are
as
follows:
Manager,
$
96;
Technical,
$
58;
and
Engineer,
$
64.
7
(
ii)
Estimating
Operations
and
Maintenance
Costs
Operation
and
maintenance
costs
include
expenses
related
to
maintaining
and
calibrating
the
portable
emission
measurement
devices,
travel
to
and
from
the
testing
location,
and
a
vehicle
incentive.

(
iii)
Capital/
Start­
up
Costs
Companies
will
need
to
purchase
portable
emission
measurement
devices
to
conduct
inuse
testing.
We
estimate
that
each
of
the
13
companies
involved
will
purchase
an
average
of
3
portable
units.
Each
unit
is
estimated
to
cost
$
140,000.

(
iv)
Annualizing
Capital
Costs
Capital
costs
are
annualized
using
a
7
percent
discount
rate.
The
result
is
a
recurring
annual
cost
of
$
34,145
per
portable
emissions
measurement
unit,
$
102,435
per
manufacturer,
or
a
total
of
$
1,331,655
for
the
industry.

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
40
hours
of
staff
time
(
at
$
40
per
hour,
loaded)
for
each
engine
family
tested
under
the
new
program.
Based
on
testing
18
engine
families
per
year,
this
comes
to
approximately
720
hours
or
$
28,800
per
year
to
oversee
the
requirements
of
the
final
rule.

6
(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Table
2
shows
the
annualized
capital
cost,
and
annual
labor
and
other
costs
associated
with
meeting
the
new
requirements
for
each
engine
family.
The
engine
family
costs
are
multiplied
by
the
number
of
engine
families
and
added
to
estimated
capital
costs
to
arrive
at
an
estimated
total
annual
cost.
8
Table
2
Annual
Respondent
Burden
and
Cost
 
Heavy­
Duty
On
Highway
Diesel
Engine
Manufacturers
Information
Collection
Activity
Average
annual
burden
and
cost
per
family
#
of
Families
Annualized
Capital
&

Startup
cost
Total
Hours
and
Costs
Manager
Hrs
Engineer
Hrs
Technical
Hrs
Hours
per
family
Labor
Cost
per
Family*
O&
M
Cost
Total
Hours/
yr
Total
Cost/
yr
Portable
Emission
Measurement
Systems
NA
NA
NA
0
NA
NA
NA
$
1,331,665
NA
$
1,331,665
Obtaining
Vehicles
NA
4.8
NA
4.8
$
394
NA
18
NA
86
$
7,092
Vehicle
Incentive
NA
NA
NA
NA
NA
$
984
18
NA
NA
$
17,712
PEMS
Calibration
NA
0.5
1.5
2
$
127
NA
18
NA
36
$
2,286
Travel
NA
NA
NA
NA
NA
$
3,153
18
NA
NA
$
56,754
PEMS
Operating
Fuel,
Etc.
NA
NA
NA
NA
NA
$
722
18
NA
NA
$
12,996
Testing
Labor
NA
59
59
158
$
10,865
NA
18
NA
2,844
$
195,570
Data
Analysis
Reporting,
and
Archiving
1.3
34.7
NA
36
$
2,497
NA
18
NA
648
$
44,946
Total
$
4,859
$
1,331,665
3,614
$
1,669,000
*
Includes
a
general
and
administrative
overhead
charge
of
6.5
percent
and
labor
overtime
pay
at
1.5
times
the
normal
rate
as
appropriate.
9
6
(
e)
Bottom­
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
Bottom­
line
annual
burden
and
cost
for
the
first
three
years
of
the
rulemaking
are
shown
in
Table
3.
The
table
shows
industry
totals
and
average
values
for
each
respondent
by
category.

Table
3
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
Heavy­
Duty
On
Highway
Diesel
Engine
Manufacturers
13
$
1,331,665
$
4,859
3,614
$
1,669,000
278
$
128,385
(
ii)
Agency
Tally
Our
estimated
burden
is
approximately
720
hours
or
$
28,800
to
oversee
the
requirements
of
the
new
program,
as
described
in
Section
6
(
c).

6
(
f)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
278
hours
per
response,
as
shown
in
Table
3.
Also,
the
new
requirements
account
for
about
3,614
total
burden
hours
and
about
$
1.67
million
in
cost
annually.
These
estimates
include
time
to
obtain
test
vehicles,
conduct
testing,
prepare
and
submit
reports,
and
record
and
keep
required
information.
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;
train
personnel
to
be
able
to
respond
to
a
collection
of
information;
search
data
sources;
complete
and
review
the
collection
of
information;
and
transmit
or
otherwise
disclose
the
information.
An
agency
may
not
conduct
or
sponsor,
and
a
person
is
not
required
to
respond
to,
a
collection
of
information
unless
it
displays
a
currently
valid
OMB
control
number.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
part
9
and
48
CFR
chapter
15.
10
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.
OAR­
2004­
0072,
which
is
available
for
public
viewing
at
the
Air
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
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
and
the
Air
Docket
is
(
202)
566­
1744.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
EDOCKET
is
available
for
submitting
or
viewing
public
comments,
accessing
the
index
listing
of
the
contents
of
the
public
docket,
and
accessing
those
documents
in
the
public
docket
that
are
available
electronically.
Once
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.
(
OAR­
2004­
0072)
and
OMB
control
number
2060­
0287
in
any
correspondence.

6
(
g)
Reason
for
Change
in
Burden
We
are
adopting
a
new
in­
use
testing
program
for
heavy­
duty
on
highway
diesel
engines.
This
information
collection
request
updates
the
estimated
burden
to
reflect
the
additional
effort
required
to
meet
the
new
standards
and
consolidates
all
the
various
recordkeeping
and
reporting
items
for
these
engines.

Part
B
of
the
Supporting
Statement
This
section
is
not
applicable.
