Supporting
Statement
for
Information
Collection
Request
Retrofit/
Rebuild
Requirements
for
1993
and
Earlier
Model
Year
Urban
Buses
(
Renewal)

EPA
Number
1702.04
OMB
Control
Number
2060­
0302
42
USC
7521
§
219
(
d)
40
CFR
85
Subpart
O
November
2004
Certification
and
Compliance
Division
Office
of
Transportation
and
Air
Quality
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
1
1.
Identification
of
the
Information
Collection
1(
a)
Title
and
Number
of
the
Information
Collection
Retrofit/
Rebuild
Requirements
for
1993
and
Earlier
Model
Year
Urban
Buses
(
40
CFR
part
85,
subpart
O)
(
Renewal),
EPA
ICR
Number
1702.04,
OMB
Control
Number
2060­
0302.

1(
b)
Short
Characterization
Section
219
(
d)
of
the
Clean
Air
Act
(
CAA),
as
amended
in
1990,
requires
that
the
EPA
promulgate
regulations
for
urban
buses
that:
(
a)
operate
in
Metropolitan
Statistical
Areas
(
MSA)
or
consolidated
MSA's
with
a
1980
population
of
750,000
or
more;
(
b)
are
not
subject
to
the
1994
or
later
urban
bus
standards;
and
(
c)
have
their
engines
replaced
or
rebuilt
after
January
1,
1995.
Approximately,
only
40
urban
areas
are
affected.

The
CAA
Amendments
require
the
subject
urban
buses
be
retrofitted
to
comply
with
an
emission
standard
that
reflects
the
best
retrofit
technology
and
maintenance
practices
reasonably
achievable.
40
CFR
part
85,
subpart
O
establish
requirements
for
pre­
1994
model
year
urban
buses
whose
engines
are
rebuilt
or
replaced.
The
program
requires
that
the
particulate
emissions
level
of
the
urban
bus
engines
be
reduced
to
a
level
below
the
engines'
original
particulate
level
through
the
use
of
EPA
certified
retrofit/
rebuild
equipment,
if
necessary
technology
is
available
at
reasonable
cost.
The
program
has
been
phasing
itself
out
as
pre­
1994
urban
buses
are
retired
from
fleets.

Operators
of
the
affected
buses
are
required
to
choose
between
two
compliance
options:
Program
1
sets
PM
emissions
requirements
for
each
urban
bus
engine
in
an
operator's
fleet
which
is
rebuilt
or
replaced;
Program
2
is
a
fleet
averaging
program
that
establishes
specific
annual
target
levels
for
average
PM
emissions
from
urban
buses
in
an
operator's
fleet.

A
key
aspect
of
the
program
is
the
certification
of
retrofit/
rebuild
equipment.
To
meet
either
of
the
two
compliance
options,
operators
of
the
affected
buses
must
use
equipment
which
has
been
certified
by
EPA.
Under
Program
1,
a
transit
operator
must
use
equipment
certified
by
EPA
to
meet
a
0.10
g/
bhp­
hr
PM
standard,
if
such
equipment
is
available
for
a
life
cycle
cost
of
2
$
7,940
or
less
(
in
1992
dollars).
If
such
equipment
is
not
certified,
then
a
transit
operator
must
use
equipment
certified
by
EPA
as
achieving
at
least
a
25
percent
reduction
in
PM,
if
such
equipment
is
available
for
a
life
cycle
cost
of
$
2,000
or
less.
Once
equipment
is
certified
and
available
for
less
than
the
cost
ceiling
for
a
given
engine
model,
program
requirements
are
triggered
for
that
engine
model.
Triggering
program
requirements
hereafter
refers
to
those
activities
which
certify
retrofit/
rebuild
equipment
under
the
lifetime
equipment
cost
ceiling
and
emission
reduction
estimates.
If
such
equipment
is
not
available,
a
transit
operator
must
rebuild
to
the
original
engine
configuration,
or
a
configuration
having
the
same
or
lower
emissions.

Equipment
used
for
Program
2
must
be
certified
to
provide
some
level
of
PM
reduction
that
would
in
turn
be
claimed
by
urban
bus
operators
when
calculating
their
average
fleet
PM
levels
attained
under
the
program.

As
of
September
2000,
nine
retrofit
equipment
manufacturers
certified
twenty
equipment
kits.
EPA
has
received
no
applications
for
retrofit
kit
certifications
since
then.
Since
this
program
applies
only
to
buses
manufactured
on
or
before
1993,
the
need
for
this
kits
have
decreased
sharply
as
most
of
these
buses
have
been
either
retired
or
already
retrofitted.

EPA
does
not
expect
to
receive
any
more
applications
for
certification.
However,
for
the
purpose
of
this
exercise,
it
has
been
estimated
that
during
the
next
three
years
one
retrofit
equipment
manufacturer
and
40
bus
operators
will
respond
to
this
collection
at
an
approximate
cost
of
$
186,148.

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
data
required
by
this
Information
Collection
Request
is
necessary
to
comply
with
Section
219
(
d)
of
the
Clean
Air
Act,
as
amended
in
1990.
The
CAA
requires
that
EPA
set
a
standard
or
technology
requirement
for
pre­
1994
model
year
urban
buses
that
reflects
the
best
retrofit
technology
reasonably
achievable.

It
is
important
to
know,
with
reasonable
certainty,
that
properly
installed,
maintained
and
used
equipment
will
provide
the
emissions
reductions
promised
by
the
equipment
suppliers
over
3
the
warranty
period
at
the
cost
advertised.
The
information
that
EPA
is
collecting
at
the
time
of
certification
is
needed
to
determine:
(
1)
the
emissions
performance
of
retrofit
urban
buses,
(
2)
the
installation
and
maintenance
requirements
of
retrofit
systems,
and
(
3)
the
adequacy
of
the
warranty
provisions
that
will
be
provided
with
the
retrofit
systems.

The
information
requested
may
also
be
used
for
enforcement
purposes.

2(
b)
Practical
Utility/
Users
of
the
Data
The
information
collected
is
used
to
verify
compliance
and
assess
the
emissions
impact
of
retrofit
equipments.
If
compliance
issues
are
identified,
information
submitted
under
the
program
could
be
used
for
enforcement
purposes.

The
information
will
be
received,
reviewed,
and
used
by
the
Engine
Programs
Group
(
EPG),
Certification
and
Compliance
Division,
Office
of
Transportation
and
Air
Quality,
Office
of
Air
and
Radiation.
Non­
confidential
portions
of
the
information
might
be
used
by
end
users,
environmental
groups,
members
of
the
public,
state
and
local
governments
or
other
federal
agencies.

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

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
An
announcement
of
the
public
comment
period
for
this
ICR
renewal
was
published
in
the
Federal
Register
(
69
FR
43411)
on
July
20,
2004.
No
comments
were
received.
4
3(
c)
Consultations
EPA
consulted
less
that
ten
past
respondents
regarding
this
information
collection
burden.

Contact:
Mr.
Kevin
Hallstrom
Company:
Engelhard
Corporation
Phone:
(
732)
205
­
6489
Contact:
Mr.
Marty
Lassen
Company:
Johnson
Matthey
Corporation
Phone:
(
610)
971­
3105
3(
d)
Effects
of
Less
Frequent
Collection
There
is
no
required
collection
schedule.
Manufacturers
may
submit
their
applications
for
certification
as
they
wish.
Urban
bus
operators
are
only
required
to
submit
information
upon
request
by
EPA.
The
agency
does
not
have
a
set
schedule
and
generally
only
requests
information
during
audits.

3(
e)
General
Guidelines
According
to
85.1404(
a)
urban
bus
operators
must
maintain
records
"
until
the
five
year
anniversary
of
a
rebuild
or
until
the
engine
is
rebuilt
again,
whichever
occurs
first."
Retrofit
equipment
manufacturers
must
maintain
records
for
five
years
from
the
date
of
certification.
Both
requirements
stem
from
warranty
requirements
set
forth
at
85.1409.

3(
f)
Confidentiality
Manufacturers
are
allowed
to
assert
a
claim
of
confidentiality
over
information
provided
to
EPA.
Confidentiality
is
provided
in
accordance
with
the
Freedom
of
Information
Act
and
EPA
regulations
at
40
CFR
Part
2.

3(
g)
Sensitive
Questions
No
sensitive
questions
are
asked
in
this
information
collection.
5
4.
Respondents
and
Information
Requested
4(
a)
Respondents/
NAICS
Codes
Respondents
are
manufacturers
of
engine
retrofit
equipment
and
bus
operators
within
the
following
North
American
Industry
Classification
System
codes:

336399
All
Other
Motor
Vehicle
Parts
Manufacturing
485113
Bus
and
Other
Motor
Vehicle
Transit
Systems
4(
b)
Information
Requested
(
i)
Data
Items
Retrofit
Equipment
Manufacturers
1.
Intent
to
Certify
EPA
requirements
for
submitting
a
notification
of
an
intent
to
certify
retrofit/
rebuild
equipment
are
found
in
40
CFR
85.1407(
a)
and
include
the
following
items:

(
1)
Identification
of
the
candidate
retrofit/
rebuild
equipment
including
a
list
of
parts
and
part
numbers;

(
2)
Identification
of
the
engine
family(
s)
for
which
the
equipment
will
be
sold
to
meet
program
requirements
and
specific
engine
configuration
characteristics;

(
3)
Results
and
documentation
of
tests
and
testing
procedures
used
by
the
certifier
to
show
compliance
with
the
program's
emissions
requirements.
(
It
is
acceptable
to
submit
test
data
gathered
previously,
possibly
as
part
of
a
new
engine
certification
program,
if
the
testing
was
performed
on
an
engine
configuration
identical
to
the
configuration
of
the
retrofit
engine.
If
the
equipment
can
be
used
on
more
than
one
engine
configuration
without
changes
to
the
equipment
that
could
affect
the
emission
reduction
capabilities
of
the
equipment,
the
manufacturer
is
required
only
to
conduct
testing
on
the
worst
case
engine
(
i.
e.
the
engine
configuration
with
the
highest
engine­
out
particulate
emissions
level).
In
such
cases,
EPA
6
reserves
the
right
to
request
additional
information
supporting
a
claim
that
the
efficiency
of
the
retrofit
equipment
does
not
vary
significantly
among
engine
families.)

(
4)
A
description
of
the
test
engine(
s)
and
rationale
that
supports
the
appropriateness
of
its
use;

(
5)
A
copy
of
the
written
instructions
for
proper
maintenance
and
use
of
the
equipment,
including
a
list
of
the
scheduled
maintenance
required
over
the
in­
use
compliance
period
and
when
that
maintenance
should
be
performed;

(
6)
A
copy
of
the
warranty
language
to
be
provided
to
the
urban
bus
operator;

(
7)
A
statement
of
commitment
and
willingness
to
comply
with
all
relevant
terms
and
conditions
of
the
program;
and
(
8)
A
statement
that
use
of
the
equipment
will
not
cause
a
substantial
increase
in
urban
bus
emissions
in
any
normal
driving
not
represented
during
certification
testing.

2.
Cost
Information
The
additional
information
necessary
to
determine
the
life
cycle
cost
of
the
equipment
is
found
in
CFR
85.1403(
b)(
ii)
and
includes:

(
1)
The
maximum
price
charged
to
an
urban
bus
operator
for
equipment,
excluding
reasonable
shipping
and
handling
and
taxes;

(
2)
A
detailed
breakout
of
the
total
number
of
hours
necessary
to
install
the
equipment
and
number
of
hours
necessary
to
install
the
equipment
incremental
to
a
standard
rebuild;

(
3)
The
percent
change
in
fuel
economy
for
retrofit
equipment
not
requiring
the
use
of
a
fuel
other
than
diesel
fuel,
as
determined
over
the
heavy­
duty
engine
federal
test
procedure
or
an
approved
alternative
test
procedure;

(
4)
The
fuel
economy
of
the
retrofit
engine,
for
retrofit
equipment
requiring
the
use
of
an
alternative
fuel,
based
on
testing
performed
over
an
approved
test
procedure,
including
all
test
data
supporting
the
reported
fuel
economy.
Additionally,
the
manufacturer
must
submit
the
unit
maximum
price
of
the
alternative
fuel,
relative
to
the
price
of
diesel
fuel,
that
will
be
charged
to
any
affected
urban
bus
operator;
7
(
5)
For
equipment
requiring
a
fuel
additive,
the
amount
of
additive
required
per
gallon
of
fuel
and
the
unit
maximum
price
of
the
fuel
additive
that
will
be
charged
to
all
affected
urban
bus
operators;
and
(
6)
A
list
of
scheduled
maintenance
for
the
retrofit
equipment
including
the
cost
of
the
parts
that
must
be
replaced
as
part
of
scheduled
maintenance
over
the
in­
use
compliance
period.

Because
fuel
costs
and
additive
costs
may
vary
regionally,
the
manufacturer
may
wish
to
certify
equipment
as
a
trigger
for
program
requirements
for
only
the
urban
bus
operators
located
in
areas
where
fuel
costs
are
such
that
the
life
cycle
cost
ceiling
can
be
met.
In
such
cases,
the
manufacturer
is
not
required
to
report
the
fuel
cost
at
time
of
certification.
Also,
the
manufacturer
is
not
required
to
report
the
equipment
costs
(
item
number
1
in
the
previous
paragraph),
as
the
manufacturer
may
wish
to
vary
the
price
charged
for
the
equipment
in
order
to
stay
below
the
cost
ceiling.
In
such
cases,
EPA
does
require,
when
an
offer
has
been
made
to
an
urban
bus
operator,
that
the
manufacturer
report
to
EPA
the
name
of
the
urban
bus
operator
and
the
prices
for
fuel
and
equipment
being
offered
to
that
operator.
All
other
items
listed
above
must
be
reported
at
time
of
certification.

3.
Record
Keeping
Responsibilities
for
Retrofit
Equipment
Manufacturer
Equipment
manufacturer
must
maintain
and
retain
for
a
period
of
five
years
records
regarding
the
manufacturing
and
testing
of
retrofit
equipment.
This
information
must
be
adequately
organized
and
indexed,
and
made
available
to
the
EPA
upon
written
request.
The
record
keeping
requirements
for
retrofit
equipment
manufacturers
are
found
in
40
CFR
85.1412(
a)(
1)
and
include
the
following
items:

(
1)
Detailed
production
drawings
showing
all
dimensions,
tolerances,
performance
requirements
and
material
specifications
and
any
other
information
necessary
to
completely
describe
the
equipment;

(
2)
All
data
obtained
during
testing
of
the
equipment
and
subsequent
analyses
based
on
that
data,
including
the
mileage
and
the
vehicle
or
engine
configuration
determinants;
8
(
3)
All
information
used
in
determining
those
vehicles
or
engines
for
which
the
equipment
is
represented
as
being
equivalent
from
an
emissions
standpoint
to
the
original
equipment
being
replaced;

(
4)
A
description
of
the
quality
control
plan
used
to
monitor
production
and
assure
compliance
of
the
equipment
with
the
applicable
certification
requirements;

(
5)
All
data
taken
in
implementing
the
quality
control
plan,
and
any
subsequent
analyses
of
that
data;
and
(
6)
All
in­
service
data,
analyses
performed
by
the
equipment
manufacturer
and
correspondence
with
vendors,
distributors,
consumers,
retail
outlets
or
engine
manufacturers
regarding
any
design,
production
or
in­
service
problems
associated
with
25
or
more
pieces
of
any
certified
equipment.

4.
To
contest
a
decertification
ruling:

(
1)
In
the
event
that
the
Agency
makes
a
preliminary
determination
that
certain
equipment
must
be
decertified,
equipment
manufacturers,
or
other
interested
parties,
must
submit
written
presentations
stating
so
with
justification,
within
15
days.
Equipment
manufacturers
may
also
submit
an
intent
to
reply
in
conjunction
with
a
request
for
additional
time
to
submit
their
presentations.

(
2)
Equipment
manufacturers
may
appeal
an
Agency
decision
to
revoke
equipment
certification
by
filing
a
petition
for
appeal
to
the
Agency
within
20
days.
Written
presentations
are
required,
unless
EPA
opts
to
allow
oral
presentations.

Urban
Bus
Operators
1.
Record
Keeping
Responsibilities
for
Urban
Bus
Operators
Urban
bus
operators
must
maintain
records
concerning
activities
associated
with
retrofitting/
rebuilding
pre­
1993
urban
buses.
EPA
believes
that
the
operators
already
keep
this
type
of
information
as
part
of
their
normal
course
of
business
and
thus
no
additional
burden
is
anticipated
due
to
this
requirement.
The
record
keeping
requirements
for
urban
bus
operators
are
found
in
40
CFR
85.1404
and
include
the
following
information:
9
(
1)
Rebuild/
Retrofit
equipment
purchased.

(
2)
Engine
rebuilds
and
replacements.

(
3)
In
cases
where
clean
diesel
fuel
are
used
for
this
program,
bus
operators
are
required
to
maintain
records
of
such
fuel
purchases.

(
4)
Operators
must
affix
certification
labels
supplied
with
the
equipment
to
applicable
retrofit/
rebuilt
engines.

(
5)
Maintain
evidence
showing
that
the
urban
buses
are
in
compliance
with
the
requirement
of
either
the
first
or
second
option
of
the
retrofit/
rebuild
program.

2.
Submission
of
Information
Upon
request,
urban
bus
operators
must
submit
the
following
information:

(
1)
A
summary
of
the
pre­
1994
urban
buses
and
their
engines
in
the
fleet,
including
the
rebuild
history
of
each
engine
in
the
active
fleet
and
a
listing
of
those
urban
buses
which
have
been
retired
since
the
last
submission;

(
2)
Identification
of
those
urban
buses
with
engines
that
have
undergone
an
engine
rebuild
or
engine
replacement
since
the
last
submission
and
identify
the
rebuild
equipment
used;
and
(
3)
For
operators
using
Option
2,
a
demonstration
that
the
average
annual
fleet
target
level
for
particulate
matter
has
been
met.

(
ii)
Respondent
Activities
A.
Retrofit
Equipment
Manufacturer
°
Read
the
regulatory
provisions
to
determine
certification
requirements.
°
Plan
activities
necessary
for
the
certification
process.
°
Conduct
emissions
testing
if
necessary.
°
Prepare
and
submit
application
for
certification.
10
°
Prepare
and
submit
running
changes,
if
any.
°
Keep
records
°
Provide
information
to
EPA
upon
request
B.
Urban
Bus
Operators
°
Review
regulations
°
Choose
best
retrofit
alternative
°
Retrofit
engines
°
Keep
records
°
Provide
information
to
EPA
upon
request
5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
The
Agency
reviews
the
notice
of
intent
to
certify
to
determine
whether
all
requirements
have
been
met
and
certification
may
be
granted.
This
process
includes
publication
of
a
summary
of
the
intent
to
certify
in
the
Federal
Register
along
with
announcement
of
the
availability
of
the
document
for
public
review
and
comment.
The
Agency
also
reviews
public
comments
when
determining
the
accuracy
and
completeness
of
the
information
provided
in
the
notice.
If
necessary,
additional
information
may
be
requested
from
the
manufacturer
to
address
public
comments.
After
a
final
decision
has
been
made,
the
Agency
publishes
a
Federal
Register
notice
announcing
that
equipment
has
been
certified.

EPA
also
examines
the
records
of
urban
bus
operators,
inspects
retrofitted
urban
buses
during
audits,
and
reviews
the
summary
information
submitted
to
ensure
compliance
with
program
requirements.

5(
b)
Collection
Methodology
and
Management
EPA
does
not
expect
to
receive
any
more
responses
to
this
collection;
however,
if
a
respondent
wishes
to
submit
an
application,
s/
he
can
do
so
either
on
paper
or
in
electronic
format
(
by
e­
mail
or
diskette).
Currently,
EPA
stores
all
11
information
related
to
this
collection
both
in
hard
copy
and
electronic
format.

5(
c)
Small
Entity
Flexibility
As
explained
above,
there
are
some
cost
considerations
already
built
into
the
program
to
ensure
cost
effectiveness.
Otherwise,
the
information
being
requested
is
considered
to
be
the
minimum
needed
to
effectively
conduct
and
maintain
their
integrity.
Further
measures
to
simplify
reporting
for
small
businesses
do
not
appear
prudent
or
necessary.

5(
d)
Collection
Schedule
The
notice
of
intent
to
certify
is
a
one­
time
submission
for
each
retrofit/
rebuild
kit
made
at
the
convenience
of
the
manufacturer.
Bus
operators
need
only
submit
information
if
requested
by
EPA
during
an
audit.
EPG
has
not
conducted
audits
under
this
program
during
the
last
several
years
and
is
not
planning
to
conduct
any
during
the
next
three
years.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
Refer
to
Tables
1
and
2
for
details
6(
a)
Estimating
Respondent
Burden
Burden
estimates
were
taken
from
the
previous
ICR
and
adjusted
to
reflect
comments
from
fewer
than
10
respondents
consulted
by
EPA.

All
burden
estimates,
including
those
associated
with
onetime
preparations
were
annualized.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
To
estimate
labor
costs,
EPA
used
the
Bureau
of
Labor
Statistics'
National
Industry­
specific
Occupational
Wage
Estimates
(
May
2003)
for
the
Engine
and
Turbines
Industry
(
SIC
12
351)
and
increased
by
a
factor
of
2.1
to
account
for
benefits
and
overhead.
The
specific
rates
used
are
listed
below.
These
are
mean
hourly
rates.

Table
3
Labor
Costs
Estimates
Occupation
SOC
Code
Number
Mean
Hourly
Rate
(
BLS)
110%

Mechanical
Engineers
17­
2141
$
30.61
$
64.28
Engineering
Managers
11­
9041
$
46.17
$
96.96
Lawyers
23­
1011
$
51.83
$
108.84
Secretaries,
Except
Legal,
Medical
and
Executive
43­
6014
$
14.79
$
31.06
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)
Costs
Operation
and
maintenance
costs
include
testing
expenses,
phone
calls,
photocopying,
postage
expenses
and
diskettes.
Diskettes
may
be
used
by
manufacturers
and
bus
operators
to
keep
their
records.

No
capital
costs
are
associated
with
participation
in
this
program.

(
iii)
Capital/
Start­
up
vs.
Operating
and
Maintenance
Costs
There
are
no
capital
or
start­
up
costs
associated
with
this
ICR.
O&
M
costs
are
discussed
in
section
6(
b)(
ii).
13
(
iv)
Annualizing
capital
costs
There
are
no
capital
costs
associated
with
this
ICR.

6(
c)
Estimating
Agency
Burden
Table
4
explain
EPA's
overall
burden
associated
with
the
programs
contained
in
this
information
collection.

Table
5
summarizes
EPA's
labor
costs
associated
with
this
information
collection.
These
costs
are
based
on
2004
hourly
wage
rates
obtained
from
the
Office
of
Personnel
Management
and
adjusted
by
a
factor
of
1.6
to
account
for
benefits
and
overhead.

Table
5
Agency
Labor
Costs
Occupation
Hourly
Rate
160%

Environmental
Protection
Specialist
(
GS­
13/
3)
$
38.01
$
60.82
Lawyers
(
GS­
13/
7)
$
41.46
$
66.34
O&
M
costs
include
phone
calls,
faxes,
postage,
and
diskettes
to
store
information.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
EPA
does
not
expect
to
receive
anymore
applications
for
certification.
The
last
application
was
received
in
2000.
This
is
due
to
the
fact
that
since
the
regulation
applies
only
to
1993
and
earlier
urban
bus
engines
within
specific
urban
areas,
the
affected
bus
population
has
decreased
each
year
as
older
buses
are
retired.
However,
for
the
purpose
of
this
exercise,
EPA
has
based
cost
estimates
on
having
one
manufacturer
certify
14
equipment
under
the
most
expensive
alternative
(
proving
that
the
equipment
meets
life
cycle
cost
limits)
within
the
next
three
years.
All
costs
have
been
annualized.

The
regulations
provide
costs
limits
for
equipment
used
under
Program
1
(
see
section
1(
b)
for
details)
in
1992
dollars.
The
costs
used
have
been
updated
to
2004
dollars
using
the
Consumer
Price
Index
as
provided
by
the
Bureau
of
Labor
Statistics.

Table
6
Cost
Limits
Established
by
85.1403(
b)

1992
dollars
Equivalent
in
2004
dollars
$
7,940
$
10,656
$
2,000
$
2,684
Although
EPA
does
not
currently
have
plans
to
perform
audits
under
this
program,
the
cost
of
one
audit
to
a
manufacturer
and
one
audit
to
a
bus
operator
was
included.

6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
Number
of
Respondents:
41
Number
of
Activities:
10
Total
Hours
Per
Year:
1,457
Total
Labor
Cost
Per
Year:
$
74,747
Total
Annual
Capital
Costs:
0
Total
Annual
O&
M
Costs:
$
111,401
Total
Costs:
$
186,148
15
(
ii)
The
Agency
Tally
Number
of
Respondents:
41
Number
of
Activities:
5
Total
Hours
Per
Year:
77
Total
Labor
Cost
Per
Year:
$
1,980
Total
Annual
Capital
Costs:
0
Total
Annual
O&
M
Costs:
$
1,003
Total
Costs:
$
2,983
6(
f)
Reasons
for
change
in
burden
Burden
estimates
have
decreased
by
2,252
hours
(
from
3,709
hours
on
the
previous
ICR
to
1,457
in
this
renewal)
due
to
a
sharp
reduction
in
the
estimated
number
of
respondents.
In
the
previous
ICR,
EPA
estimated
that
159
retrofit
equipment
manufacturers
and
bus
operators
would
respond
to
this
collection.
Experience
during
the
last
three
years
lead
us
to
review
that
estimate
down
to
41,
as
explain
in
previous
sections.
This
reduction
is
due
to
the
fact
that
the
program
has
been
phasing
itself
out
as
pre­
1994
urban
buses
are
retired
from
fleets
or
have
already
been
retrofitted.
Therefore,
this
change
in
burden
is
due
to
an
Adjustment.

6(
g)
Burden
Statement
The
average
annual
burden
associated
with
participation
in
this
information
collection
is
of
129
hours
per
retrofit
equipment
manufacturer
and
33
hours
per
bus
operator.

These
estimates
include
time
to
review
applicable
regulations
and
guidance
documents,
generate
and
gather
the
necessary
information,
submit
applications
and
reports,
and
maintain
records.
16
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
EPA.
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
EPA
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.

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
Number
OAR­
2004­
0089,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
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
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
and
Radiation
Docket
and
Information
Center
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OAR­
2004­
0089
and
OMB
Control
Number
2060­
0302
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
