­
1­
Supporting
Statement
for
Information
Collection
Request
Motor
Vehicle
Emission
and
Fuel
Economy
Compliance;
Light
Duty
Vehicles,
Light
Duty
Trucks,
Motorcycles
and
Recreational
Vehicles
EPA
ICR
0783.47
DRAFT
JULY
2004
(
Based
on
March
2001
submission)

Certification
and
Compliance
Division
Office
of
Transportation
and
Air
Quality
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
­
2­
Part
A
SUBMISSION
Section
1:
Identification
of
the
Information
Collection
1(
a)
Title
and
Number
of
the
Information
Collection
Motor
Vehicle
Emission
and
Fuel
Economy
Compliance;
Light
Duty
Vehicles,
Light
Duty
Trucks,
Motorcycles
and
Recreational
Vehicles.
EPA
ICR
number
0783.47,
OMB
control
number
2060­
0104.

1(
b)
Short
Characterization/
Abstract
Beginning
with
the
1968
model
year,
the
Federal
Government
has
regulated
air
pollution
emitted
by
motor
vehicles.
While
light
vehicles
(
passenger
cars
and
light
trucks)
were
the
first
to
be
regulated,
other
classes
(
e.
g.
motorcycles
and
recreational
vehicles)
were
subsequently
included.
The
first
phase
of
regulation
consisted
of
prototype
certification;
manufacturers
demonstrated
that
a
particular
design
met
applicable
requirements
and
they
received
a
"
certificate"
(
license)
allowing
that
design
to
be
sold.
EPA
expanded
the
compliance
program
to
include
assembly
line
and
in­
use
testing.
Vehicles
failing
to
meet
requirements
in­
use
would
be
subject
to
recall
and
repair
by
the
manufacturer.
During
these
three
decades
of
emission
control,
considerable
progress
has
been
made
in
reducing
vehicular
air
pollution.
A
new
passenger
car
today
will
emit
much
less
than
one
tenth
the
exhaust
pollution
of
its
uncontrolled
predecessor.

During
the
1973
oil
embargo,
there
was
a
need
for
improved
automotive
fuel
economy
information.
EPA
was
able
to
fulfill
part
of
this
need
using
information
collected
during
its
emission
testing
program.
(
To
determine
the
mass
of
pollution
emitted,
the
quantity
and
composition
of
a
vehicle's
exhaust
must
be
determined.
Using
that
information,
the
quantity
of
fuel
consumed
can
be
calculated.)
This
limited
information
was
expanded
by
adding
a
"
highway"
driving
schedule
and
by
implementing
a
voluntary
program
whereby
vehicle
manufacturers
tested
and
submitted
information
on
a
more
complete
spectrum
of
their
product
line.
(
Because
the
emission
certification
program
emphasized
"
worst
case"
vehicles,
it
might
not
accurately
reflect
a
manufacturers
entire
product
line.
Hence
the
need
for
additional
information.)
Congress
subsequently
enacted
legislation
mandating
fuel
economy
labeling,
establishing
average
fuel
economy
standards
and
imposing
Gas
Guzzler
Taxes.
Those
activities
all
rely
on
information
generated
under
EPA's
emission
compliance
and
fuel
economy
programs.

This
ICR
covers
EPA's
combined
emission
compliance
and
fuel
economy
programs.
Not
only
do
these
programs
share
a
common
test
procedure,
they
also
rely,
in
large
part,
on
the
same
information
and
are
administered
by
the
same
staff.
Developing
separate
estimates
would
not
be
practicable
due
to
this
integration.

This
ICR
covers
the
application
(
and
supporting
test
results)
submitted
by
vehicle
manufacturers
prior
­
3­
to
production
as
well
as
various
reports
and
information
during
production.
It
also
covers
a
much
more
limited
amount
of
information
required
when
EPA
conducts
surveillance
testing
on
in­
use
vehicles.
In
addition,
manufacturers
are
required
to
submit
fuel
economy
reports
for
vehicles
covered
under
the
Energy
Conservation
and
Policy
Act.
EPA's
processing
of
this
information
is
conducted
by
the
Certification
and
Compliance
Division,
Office
of
Transportation
and
Air
Quality,
Office
of
Air
and
Radiation.

Information
collected
consists
of
descriptions
of
motor
vehicles
(
with
emphasis
on
emission
control
systems),
test
results,
defect
reports
and
sales
information.
This
data
is
reviewed
to
verify
that
necessary
tests
have
been
performed,
the
manufacturer's
product
line
meets
emission
standards
and
fuel
economy
reports
are
accurate.
This
information
is
used
by
EPA
as
well
as
the
Internal
Revenue
Service
(
gas
guzzler
taxes),
Department
of
Energy
(
Fuel
Economy
Guides)
and
the
Department
of
Transportation
(
Corporate
Average
Fuel
Economy
standards).
Descriptive
information
is
submitted
on
optical
disc
(
smaller
manufacturers
may
use
paper
submissions);
it
is
made
available
to
interested
parties
upon
request.
Test
results
are
typically
submitted
in
an
"
electronic"
format
for
inclusion
in
EPA's
computer
database.
Fuel
economy
ratings
and
emission
test
information
is
available
on
the
Internet.

Approximately
153
passenger
car,
light
truck,
motorcycle
and
recreational
vehicle
manufacturers
will
submit
applications
each
year
to
certify
their
products.
The
motor
vehicle
emission
and
fuel
economy
compliance
programs
will
impose
a
cost
of
about
$
65.1
million
annually
on
the
regulated
industries.

Section
2:
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
Under
Title
II
of
the
Clean
Air
Act,
(
42
U.
S.
C.
7521
et
seq.),
EPA
is
charged
with
issuing
certificates
of
conformity
for
motor
vehicle
designs
which
comply
with
applicable
emission
standards.
A
manufacturer
must
have
a
certificate
before
vehicles
may
be
legally
introduced
into
commerce.
Similar
provisions
in
the
Energy
Policy
Conservation
Act
(
codified
as
Title
III
of
the
Motor
Vehicle
Information
and
Cost
Savings
Act,
15
U.
S.
C.
2001
et.
seq.)
require
fuel
economy
ratings
to
be
determined
and
vehicles
to
be
labeled.
To
ensure
compliance
with
these
statutes,
EPA
reviews
product
information
and
manufacturer
test
results;
EPA
also
tests
some
vehicles
to
confirm
manufacturer
results.
Information
is
also
shared
with
other
agencies;
Internal
Revenue
Service
for
Gas
Guzzler
Taxes
and
the
Department
of
Transportation
for
Corporate
Average
Fuel
Economy
(
CAFE)
requirements.

EPA's
emission
compliance
and
fuel
economy
programs
are
statutorily
mandated;
the
Agency
does
not
have
discretion
to
cease
these
functions.
Under
Section
206(
a)
of
the
Clean
Air
Act
(
42
U.
S.
C.
­
4­
7525)
"
.
.
.
The
Administrator
shall
test
.
.
.
any
new
motor
vehicle
.
.
.
submitted
by
a
manufacturer
.
.
.
If
such
vehicle
.
.
.
conforms
.
.
.
the
Administrator
shall
issue
a
certificate
of
conformity
.
"
EPA
uses
the
information
supplied
by
the
manufacturer
to
verify
that
the
proper
test
vehicles
have
been
selected
and
that
the
necessary
testing
has
been
performed
to
assure
that
each
vehicle
design
complies
with
emission
standards.
This
information
and
the
test
results,
are
subsequently
used
by
EPA
to
target
assembly
line
and
recall
testing.
(
"
If
the
Administrator
determines
that
a
substantial
number
of
any
class
or
category
of
vehicles
.
.
.
do
not
conform
...
when
in
actual
use
.
.
.
he
shall
immediately
notify
the
manufacturer
.
.
.
of
such
nonconformity
.
.
.")
Similarly,
the
Energy
Policy
and
Conservation
Act
requires
that
"
.
.
.
.
Average
fuel
economy
.
.
.
shall
be
calculated
by
the
EPA
Administrator
.
.
.
"
15
U.
S.
C.
2003.
Automobile
manufacturers
are
required
to
affix
fuel
economy
labels
"
as
determined
in
accordance
with
rules
of
the
EPA
Administrator,"
15
U.
S.
C.
2006.
While
EPA
has
delegated
a
substantial
portion
of
the
process
of
calculating
fuel
economy
labels
to
the
manufacturers,
the
test
results
on
which
such
labels
are
based
are
subject
to
EPA
confirmatory
testing.
Such
confirmation
testing
assures
that
results
from
different
manufacturers
can
be
accurately
used
for
comparison.

EPA
reviews
the
information
submitted
to
determine
that
required
testing
has
been
appropriately
conducted
and
that
the
vehicles
or
engines
have
demonstrated
compliance
with
emission
standards.
A
similar
review
is
made
for
fuel
economy.
Once
vehicles
have
been
produced,
EPA
uses
the
information
to
support
various
enforcement
actions
including
assembly
line
audits
and
in­
use
compliance
testing.
In
addition,
fuel
economy
reports
are
prepared
by
EPA
for
the
Departments
of
Energy,
Transportation,
and
Treasury.
Those
reports
rely
on
information
gained
via
EPA's
emission
and
fuel
economy
compliance
programs.
Some
information
is
also
used
by
various
state
and
local
governments
in
running
their
vehicle
Inspection
and
Maintenance
(
I/
M)
programs.

Relevant
portions
of
the
above
statutes
can
be
found
in
Attachment
I.
The
regulations
dealing
with
motor
vehicle
emission
control
and
fuel
economy
can
be
found
in
40
CFR
Parts
85,
86
and
600.
The
regulations
are
not
attached
to
this
statement
due
to
their
length
and
general
technical
nature.

2(
b)
Practical
Utility/
Users
of
the
Data
Motor
vehicle
manufacturers
must
submit
an
application
for
emission
certification
prior
to
production.
The
application
describes
the
major
aspects
of
the
proposed
product
line
and
technical
details
of
the
emission
control
systems.
The
application
and
supporting
test
results
are
reviewed
and,
if
appropriate,
a
certificate
of
conformity
is
issued.
EPA
will
conduct
a
limited
number
of
confirmatory
tests
at
its
laboratory
to
verify
the
manufacturer's
results.
The
decision
to
require
a
confirmatory
test
is
dependent
on
many
factors,
including
the
manufacturer's
past
performance
on
previous
confirmatory
tests
and
the
degree
of
similarity
to
previously
tested
vehicles
and
engines.
­
5­
An
initial
step
in
the
certification
process
is
to
divide
a
manufacturer's
product
line
into
groups
of
vehicle
designs
which
are
expected
to
have
similar
emission
control
characteristics.
For
each
group
a
deterioration
factor
is
established
either
by
testing,
or
by
"
carrying
over"
a
factor
from
a
previously
certified
similar
group.
Results
from
low
mileage
test
vehicles
(
worst
case
selections
from
"
test
groups")
are
adjusted
by
the
deterioration
factor
to
determine
a
"
useful
life"
emission
level.

Information
gathered
for
purposes
of
emission
certification
is
also
used
by
EPA
in
the
fuel
economy
program
(
15
U.
S.
C.
2000,
et
seq)
as
well
as
the
assembly
line
emission
testing
(
42
U.
S.
C.
7525)
and
emission
recall
programs
(
42
U.
S.
C.
7541).
Some
of
the
product
information
used
to
verify
emission
compliance
is
also
used,
in
conjunction
with
projected
sales,
to
establish
fuel
economy
ratings.
Assembly
line
and
recall
testing
are
targeted,
in
part,
using
certification
test
results
and
product
descriptions
in
the
application.
Past
performance
of
similar
vehicles
is
also
an
important
factor
in
selecting
vehicle
classes
for
assembly
line
and
recall
testing.
For
example,
when
a
particular
vehicle
type
is
discovered
to
exceed
emission
standards
the
manufacturer's
application
is
reviewed
to
determine
the
cause
of
the
failure.
(
Typically,
application
part
specifications
are
much
more
detailed
than
those
in
the
service
literature.)
Once
a
cause
is
established,
other
vehicle
types
with
the
same
(
or
similar)
parts
can
also
be
considered
for
enforcement
action.

Section
3:
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3
(
a)
Nonduplication
Efforts
have
been
made
to
eliminate
duplication
in
this
information
collection.
The
fuel
economy
and
emission
compliance
programs
have
been
highly
integrated
to
precisely
for
this
reason;
the
same
information
serves
two
purposes.
In
addition,
information
collected
during
the
certification
phase
is
then
subsequently
used
for
assembly
line
testing
and
recall.
Because
of
its
specialized
nature
and
the
fact
that
product
plans
and
emission
performance
information
must
be
submitted
to
EPA
prior
to
the
start
of
production,
it
is
not
available
from
any
source
other
than
the
manufacturer.

3
(
b)
Public
Notice
Prior
to
ICR
Submission
to
OMB
EPA
solicited
public
comment
by
means
of
a
Federal
Register
Notice
published
on
2004
July
XX,
69
Federal
Register
XXXXX;
a
copy
can
be
found
in
Attachment
III.

3
(
c)
Consultations
­
6­
In
preparing
the
previous
ICR
submission,
EPA
consulted
with
the
following
individuals
working
in
the
regulated
industry:

Individual
Firm
Telephone
Brian
Gill
American
Honda
(
310)
783­
3414
Randy
Harvey
General
Motors
(
248)
685­
6976
Bob
Holycross
Ford
(
313)
594­
0738
Jerry
Steffy
Harley
Davidson
(
414)
616­
1101
These
individuals
have
experience
with
various
aspects
of
EPA's
current
programs.
Their
comments
have
been
reflected
in
the
burden
estimates
discussed
below.
EPA
wishes
to
thank
them
and
their
colleagues
for
their
assistance
in
preparing
this
report.

3(
d)
Effects
of
Less
Frequent
Collection
As
required
by
the
Clean
Air
Act
(
42
USC
7525(
a)),
emission
and
fuel
economy
information
is
submitted
on
a
yearly
basis
coinciding
with
the
manufacturer's
"
model
year."
EPA
allows
applicants
to
define
their
own
"
model
year",
thus
granting
some
flexibility
in
this
regard.
Major
product
changes
typically
occur
at
the
start
of
a
model
year.
For
these
reasons,
a
collection
frequency
longer
than
a
model
year
is
not
possible.
However,
when
a
vehicle
design
is
"
carried
over"
to
a
subsequent
model
year,
the
amount
on
new
information
required
is
substantially
reduced.

3
(
e)
General
Guidelines
Manufacturers
are
required
to
keep
some
records
for
periods
longer
than
three
years.
This
requirement
stems
from
the
statutory
requirement
that
manufacturer
warrant
some
items
for
periods
longer
than
3
years.
Manufacturers
must
also
recall
vehicle
classes
failing
to
meet
emission
standards
during
their
useful
life;
typically
5
to
11
years
depending
on
vehicle
type.
In
order
satisfy
these
obligations,
manufacturers
must
retain
product
information,
with
particular
emphasis
on
the
emission
control
systems.
This
information
is
vital
in
assuring
that
repairs
and
replacement
parts
properly.
Accurate
product
information
is
also
required
so
that
recall
campaigns
can
be
directed
at
the
appropriate
vehicles.
EPA
believes
that
this
recordkeeping
requirement
does
not
impose
an
unreasonable
burden
given
the
warranty
and
recall
obligations.
In
fact,
manufacturers
would
probably
retain
this
information
to
support
their
normal
business
of
supplying
replacement
parts.

This
information
collection
activity
complies
with
the
remaining
guidelines
in
5
CFR
1320.5
­
7­
3
(
f)
Confidentiality
Information
submitted
by
manufacturers
is
held
as
confidential
until
the
specific
vehicle
to
which
it
pertains
is
available
for
purchase.
After
vehicles
are
available,
most
information
associated
with
the
manufacturer/
importer's
application
is
available
to
the
public.
Under
section
208
of
the
Clean
Air
Act
(
42
USC
7542
(
c)
)
all
information,
other
than
trade
secret
processes
or
methods,
must
be
publically
available.
This
proprietary
information
is
granted
confidentiality
in
accordance
with
the
Freedom
of
Information
Act,
EPA
regulations
at
40
CFR
Part
2,
and
class
determinations
issued
by
EPA's
Office
of
General
Counsel.

3(
g)
Sensitive
Questions
No
sensitive
questions
are
asked
in
this
information
collection.
This
collection
complies
with
the
Privacy
Act
and
OMB
Circular
A­
108.

Section
4.
Respondents
and
Information
Requested
4(
a)
Respondents/
SIC
Codes
The
respondents
are
motor
vehicle
and
motorcycle
manufacturers,
SIC
codes
3711
and
3751.

(
b)
Information
Requested
(
i)
Data
items
Manufacturers
are
required
to
submit
descriptions
of
their
planned
product
line,
including
detailed
descriptions
of
the
emission
control
system,
and
test
data.
This
information
is
organized
into
various
groups
with
similar
emission
or
fuel
economy
characteristics.
Manufacturers
supply
test
data
to
verify
that
their
products
will
comply
with
the
emission
standards,
test
data
is
also
used
to
establish
fuel
economy
ratings.
Manufacturers
also
supply
information
to
support
recall
and
assembly
line
testing,
They
are
also
required
to
notify
EPA
of
in­
use
defects
experienced
by
their
vehicles.
Given
the
diversity
of
vehicles
produced
and
the
complicated
nature
of
the
regulations,
in
certain
instances,
manufacturers
may
also
find
it
advantageous
to
request
variances
from
standard
EPA
procedures.

A
list
of
detailed
information
requirements
and
their
corresponding
regulation
citation
appears
in
Attachment
II.
­
8­
(
ii)
Respondent
Activities
The
emission
and
fuel
economy
compliance
programs
are,
of
necessity,
quite
complex
given
the
diversity
of
products
available.
These
programs
have
evolved
over
the
past
three
decades
to
balance
testing
and
reporting
burdens
against
the
risk
of
unnecessary
air
pollution
and
inaccurate
fuel
economy
information.
While
there
is
no
"
typical"
respondent,
all
manufacturers
must
describe
their
product
and
supply
test
data
to
verify
compliance.
EPA
will
conduct
a
limited
number
"
confirmatory
tests"
to
audit
manufacturer
results,
this
requires
test
vehicles
be
shipped
to
EPA's
laboratory.
Manufacturers
must
also
retain
records.
These
tasks
are
repeated
for
each
model
year,
typically
previous
data
and
information
can
be
"
carried
over"
when
no
significant
changes
have
occurred.
If,
during
the
course
of
a
model
year
a
product
change
is
made
("
running
change"),
EPA
must
be
notified.
Under
some
circumstances
additional
test
data
may
be
required.

During
production
various
reports
must
be
submitted;
and,
after
a
given
model
year
production
has
ended,
a
final
report
must
be
submitted.
Manufacturers
must
also
submit
reports
concerning
defects
that
are
discovered,
they
may
also
be
requested
to
review
various
aspects
of
in­
use
testing
that
EPA
may
elect
to
conduct.
Manufacturers
are
also
required
to
conduct
in­
use
testing;
In­
Use
Verification
Program
(
IUVP).

Section
5:
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
A
significant
portion
of
EPA's
emission
and
fuel
economy
compliance
activity
is
spent
reviewing
applications
to
verify
that
the
correct
vehicle
tests
have
been
conducted.
A
part
of
this
process
involves
determining
if
"
carry
over"
of
data
from
a
previous
model
year
is
appropriate
or
if
new
testing
will
be
required.
EPA
will
also
select
a
number
of
tests
for
confirmation
at
EPA's
own
laboratory.
Selections
for
confirmatory
testing
are
based
on
a
combination
of
random
selection
and
other
factors
including
past
performance
on
other
confirmatory
tests.

EPA
prepares
an
annual
report
of
emission
test
results
and
reviews
annual
fuel
economy
reports
submitted
by
the
manufacturers.
EPA
also
conducts
a
limited
number
of
in­
use
tests
for
various
reasons,
one
of
the
most
significant
as
surveillance
for
potential
recalls.

5(
b)
Collection
Methodology
and
Management
­
9­
EPA
currently
makes
extensive
use
of
computers
in
collecting
information
from
vehicle
manufacturers.
Essentially
all
routine
information
(
test
results
and
vehicle
descriptions)
is
electronically
transmitted
directly
from
the
manufacturers.
Remaining
information,
including
diagrams
and
narrative
descriptions,
is
submitted
on
optical
disc.
(
Some
smaller
manufacturers
rely
on
paper
submissions.)

All
information
received
by
EPA
is
subject
to
audit.
Data
submitted
electronically
is
automatically
screened;
test
results
which
are
close
to
emission
standards
are
reviewed
in
more
detail.
Narrative
descriptions
of
the
proposed
product
line
are
checked
to
verify
that
the
appropriate
vehicles
have
been
tested.
(
The
emission
and
fuel
economy
programs
rely
on
a
combination
of
"
worst
case"
and
representative
data
to
accomplish
their
goals.)
Except
for
projected
sales
and
a
very
limited
amount
of
proprietary
product
information
(
typically
catalyst
formulations),
all
information
is
available
to
the
public
as
soon
as
the
vehicle
is
offered
for
sale.
Emission
and
fuel
economy
data
is
available
on
the
Internet,
other
information
is
available
upon
request.

5(
c)
Small
Entity
Flexibility
EPA
established
special
procedures
for
small­
volume
manufacturers;
i.
e.
those
whose
total
sales
are
less
than
10,000
units
per
year.
These
special
procedures
allow
the
small­
volume
manufacturer
to
submit
a
simplified
application
for
certification
as
compared
to
the
applications
submitted
by
larger
volume
manufacturers.
These
manufacturers
also
have
reduced
testing
and
reporting
requirements.
Further,
by
the
very
nature
of
there
size,
small
volume
manufacturers
typically
have
very
limited
product
lines.
This
characteristic
both
reduces
the
amount
of
information
which
must
be
submitted
and
also
simplifies
the
process
of
selecting
the
correct
test
vehicle(
s).

5(
d)
Collection
Schedule
Information
must
be
submitted
for
each
"
model
year"
that
a
manufacturer
intends
to
build
(
or
import)
vehicles.
A
"
model
year"
is
usually
about
one
calendar
year
long;
it
typically
begins
prior
to
January
1st
of
the
calendar
year.
If
a
product
is
unchanged
between
model
years,
much
of
the
information
can
be
"
carried
over."
The
collection
frequency
and
burden
are
determined
to
a
large
extent
by
the
manufacturer's
marketing
and
product
plans.
However,
as
required
by
law,
some
submission
is
required
for
each
model
year's
production.

Section
6.
Estimating
the
Burden
and
Cost
of
the
Collection
6(
a)
Estimating
Respondent
Burden
­
10­
The
burden
estimates
below
are
based,
in
part,
on
those
developed
several
years
ago
as
part
of
the
Compliance
Assurance
Program
(
CAP
2000)
project.
(
CAP
2000
was
designed
to
reduce
the
amount
of
testing
EPA
required
prior
to
production;
in
return
manufacturers
were
required
to
conduct
testing
on
"
in­
use"
vehicles.)
The
CAP
2000
burden
estimates
were
established
after
a
number
of
meetings
with
the
regulated
industry.

Since
these
burden
estimates
are
intended,
in
part,
as
a
management
tool,
they
are
structured
to
reflect
data
that
can
be
easily
retrieved.
Recent
changes
in
how
EPA
process
data
(
coinciding
with
the
implementation
of
CAP
2000)
necessitate
changes
in
how
burden
is
estimated.
For
example,
EPA
no
longer
tracks
the
number
of
individual
vehicle
tests
which
are
used
to
generate
certification
and
fuel
economy
data.
Instead,
it
is
assumed
that
each
test
group
will
have
an
average
of
6
tests
per
year
over
the
life
of
the
test
group;
new
test
groups
will
have
more
testing,
those
that
are
carried
over
less.
Motorcycle
engine
families
are
assumed
to
have
one
half
test
per
year
due
to
extensive
carry­
over
of
previous
data
and
the
lack
of
fuel
economy
regulations.
The
remaining
activity
levels
are
based
on
2001
model
year
data,
the
latest
available.

In
revising
the
previous
burden
estimates,
a
number
of
individuals
in
the
regulated
industry
were
consulted.;
see
section
3(
c).
These
individuals,
and
their
colleagues,
provided
significant
insight
from
an
industry
perspective;
their
assistance
in
this
endeavor
is
most
appreciated.
In
trying
to
test
the
accuracy
of
the
previous
burden
factors,
they
were
asked
the
following
question:
"
If
EPA
were
to
cease
to
exist,
but
your
firm
were
still
mandated
to
meet
all
substantive
requirements,
e.
g.
emission
standards
and
fuel
economy,
how
much
labor
could
be
saved?"
(
This
question
is
believed
to
succinctly
define
the
burden
the
Paperwork
Reduction
Act,
and
this
ICR,
addresses.)
The
response
to
this
question
was
compared
to
the
burdened
predicted
by
using
information
from
EPA's
database
and
the
CAP
2000
burden
factors.

One
conclusion
became
readily
apparent:
Predicted
motorcycle
burdens
were
too
high.
EPA's
data
simply
indicates
how
many
motorcycle
engine
families
are
certified
(
or
licensed)
as
complying
with
emission
standards;
it
does
not
distinguish
between
"
new"
and
"
previously
certified."
There
is
far
less
burden
associated
with
"
carrying
over"
a
previously
certified
design
(
or
one
with
minor
changes)
than
with
meeting
requirements
for
a
new
vehicle.
As
it
turns
out,
the
underlying
motorcycle
design
has
a
significant
life
even
if
styling
and
other
factors
have
significant
changes.
After
consultations
with
the
industry,
the
burden
has
been
adjusted
to
reflect
an
average
four
to
five
year
design
life.

For
passenger
car
and
light
truck
manufacturers,
conclusions
about
the
accuracy
of
EPA's
burden
estimates
were
not
consistent.
One
industry
representative
indicated
that
estimating
how
much
would
be
saved
"
if
EPA
disappeared"
was
not
easy,
the
estimate
covered
a
range
of
1:
2;
i.
e.
his
high
limit
was
twice
the
lower.
(
In
this
case
the
EPA
prediction
was
in
the
middle
of
the
range.)
Another
manufacturer
stated
that
"
not
much"
would
be
saved
in
the
absence
of
EPA
required
submissions;
thus
EPA's
burden
estimate
would
be
significantly
higher
than
any
potential
savings.
Finally,
another
manufacturer
estimated
savings
much
greater
than
EPA's
prediction.
Finally
tally:
three
different
industry
opinions
with
EPA
estimate
in
the
middle.
­
11­
In
discussing
this
matter
further,
several
explanations
were
offered.
As
been
pointed
out
earlier,
estimating
the
paperwork
burden
for
a
complicated,
long
standing
program
can
be
difficult.
In
some
instances,
the
manufacturers
(
or
EPA)
may
adapt
processes
to
reflect
what
the
other
party
needs/
has.
(
While
it
may
no
longer
be
true,
a
number
of
years
ago
one
manufacturer
structured
its
application
to
EPA
so
that
it
could
be
used
internally
to
define
the
vehicles
its
assembly
plants
were
authorized
to
produce.)
The
distinctions
between
"
product
development",
"
regulatory
compliance"
and
"
reporting
burden"
can
become
blurred.
Similar
activities,
at
different
manufacturers,
might
be
classified
differently.
For
example,
compliance
with
statutory
fuel
economy
standards
requires
much
the
same
testing
and
product
information
as
preparing
the
annual
report
to
EPA;
how
should
that
effort
be
classified?

Another
factor
is
the
level
of
"
comfort"
that
a
particular
organization
requires.
If
compliance
is
highly
regarded
(
to
avoid
potential
future
issues),
one
firm
may
spend
more
resources
and
have
a
higher
burden
than
its
competitors.
(
It
probably
would
not
be
accurate
to
assume
that
a
firm
with
a
cautious
approach
to
compliance
would
suddenly
change
its
philosophy
even
if
EPA
no
longer
required
paperwork
submissions.)
Some
manufacturer's
have
a
separate
internal
group
that
duplicates
some
EPA's
functions
regarding
their
"
development"
organization.
Other
manufacturers
use
an
"
integrated"
approach
in
which
development
flows
into
regulatory
compliance.
The
choice
in
how
a
particular
firm
reacts
to
the
same
requirements
depends
on
organizational
philosophy.
One
comment
received
indicated
that
if
EPA
disappeared,
staff
associated
with
that
burden
might
be
shifted
to
product
"
verification".

One
other
point
was
made
during
discussions
with
the
regulated
industry:
Even
without
an
EPA
presence,
very
little
­
if
any
­
burden
reduction
would
occur
unless
the
California
Air
Resources
Board
also
reduced
its
burden.
While
California
has
always
run
its
own
vehicle
air
pollution
control
program,
other
states
have
recently
been
permitted
to
adopt
its
standards
and
procedures.
(
EPA,
the
manufacturers
and
states
established
a
voluntary
National
Low
Emitting
Vehicle
standard
to
reduce
the
complexity
of
a
patchwork
of
state
standards.)
Again,
attributing
burden
is
not
a
clear
cut
process.

In
light
of
the
forgoing,
EPA
believe
that
the
original
projections
developed
several
years
ago
are
still
valid
and
represent
as
good
an
estimate
as
is
possible.
As
discussed
in
section
5(
c),
EPA
has
established
special
procedures
for
small
volume
manufacturers,
the
reduced
burden
factors
are
set
forth
in
the
table
below.
Applying
those
factors
to
the
model
year
2001
activity
levels
yields
the
following
burden
estimate:

LIGHT
DUTY
AND
MOTORCYCLE
INDUSTRY
BURDEN
Activity
#/
Year
Burden/
Total
Activity
Test
groups
Light
duty
­
Large
Manufacturer
300
980
294,000
­
12­
Light
duty
­
Small
Manufacturer
40
375
15,000
Motorcycle
engine
family
185
200
37,000
Evaporative
Families
Light
duty
­
Large
Manufacturer
120
375
45,000
Light
duty
­
Small
Manufacturer
40
65
2,600
Vehicles
Emission/
Fuel
economy/
motorcycle
1,800
10
18,000
In­
use
3100
2
6,200
Tests
Emission/
Fuel
economy/
motorcycle
2,000
In­
use
3,100
5,100
12
61,200
Fuel
economy
Labels
1,050
5
5,250
Car
lines
600
8
4,800
Assembly
line
tests
0
120
0
Record
storage
Large
manufacturers
25
1,000
25,000
Recreational
vehicles
28,118
TOTAL
542,118
The
table
above
includes
an
item
for
assembly
line
testing
but
with
no
activity.
EPA
does
not
intend
on
using
this
enforcement
tool
except
in
very
unusual
circumstances
which
are
unlikely
to
occur.
About
the
only
time
an
assembly
line
test
would
be
productive
would
be
if
EPA
had
other
information
indicating
that
a
particular
manufacturer
had
very
poor
quality
control;
this
would
probably
only
occur
for
a
new
small
volume
manufacturer/
importer.
(
With
new
vehicles
the
catalyst
is
extremely
active,
unless
there
is
an
extreme
problem
all
vehicles
would
likely
meet
emission
standards.)
EPA
estimates
that
the
4
emission
tests
and
management
overhead
would
consume
approximately
120
hours.
­
13­
6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
labor
costs.

The
estimated
cost
for
labor
is
$
100
per
hour
for
engineers/
technicians.
EPA
used
cost
estimates
provided
in
consultations
with
the
industry.
The
labor
cost
rates
provided
by
the
Bureau
of
Labor
Statistics
were
not
used;
those
rates
are
an
average
for
all
manufacturing
industries
and
do
not
reflect
the
higher
costs
for
the
engine
and
motor
vehicle
industries.

Using
an
estimated
average
cost
of
$
100/
hr
(
including
overhead),
annual
respondent
cost
is
approximately
$
54.2
million.
The
labor
required
has
not
been
broken
down
into
various
classifications
(
secretarial,
technician,
senior
management)
for
two
reasons.
First,
an
industry
survey
in
the
early
1980'
s
did
not
obtain
such
information;
EPA
has
no
basis
to
make
finer
distinctions.
Second,
most
of
the
labor
required
is
supplied
by
skilled
engineers
and
technicians;
additional
classification
would
not
yield
useful
information.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
The
major
operating
expense
for
the
regulated
industry
is
vehicle
mileage
accumulation.
(
In­
use
vehicles
will
not
require
additional
mileage
accumulation.)
EPA
estimates
that
these
test
vehicles
accumulate
approximately
4
million
miles.
Assuming
an
average
cost
of
$
0.30
per
mile,
the
total
cost
is
about
$
1.2
million.

To
perform
the
required
testing
a
combination
of
"
environmental"
and
standard
test
cells
are
required.
(
A
portion
of
the
testing
must
be
done
at
cold
and
warm
temperatures
to
verify
that
emission
controls
remain
effective.)
Approximately
650
light­
duty
emission
tests
will
require
an
environmental
test
cell;
the
remaining
light­
duty
and
motorcycle
tests
(
approx
4500/
yr)
can
be
performed
in
standard
cells.
Environmental
cells
cost
$
8
million
each
and
have
a
capacity
of
300
tests/
year;
standard
cells
cost
$
4
million
with
a
capacity
of
750
tests/
year.
Consequently,
this
testing
will
require
2.2
environmental
and
6
standard
test
cells
with
a
total
cost
of
$
41.6
million.
With
a
ten
year
life
and
an
7%
interest
rate,
this
yields
an
annualized
cost
of
approximately
$
5.9
million.

Recreational
vehicle
manufacturers
have
an
annualized
cost
of
$
3.789
million.

(
iii)
Start­
up
Costs
­
14­
As
this
is
an
on­
going
collection,
there
are
no
start­
up
costs.

6(
c)
Estimating
Agency
Burden
The
emission
and
fuel
economy
compliance
programs
are
administered
by
EPA's
Certification
and
Compliance
Division.
Approximately
29
full
time
employee
equivalents
are
directly
involved
in
the
emission
and
fuel
economy
programs;
their
cost
is
approximately
$
2.9
million,
including
benefits
but
not
overhead.
Overhead
percentage
for
the
entire
division
is
approximately
45
yielding
an
estimated
total
agency
cost
of
$
4.2
million.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
From
the
above
discussion
the
following
total
burden
and
cost
estimates
can
be
calculated.
(
Due
to
the
diverse
nature
of
the
motor
vehicle
industry,
there
is
no
typical
or
average
respondent.
Respondents
can
be
large
manufacturers
with
many
products
such
as
General
Motors;
they
can
also
be
small
importers
of
a
few
specialized
motorcycles
per
year.)

6(
e)
Bottom
Line
Burden
Hours
and
Cost
(
i)
Respondent
Tally
INDUSTRY
RESPONDENTS
153
BURDEN
HOURS
542,118
LABOR
COST
$
54.2
million
OPERATING
COST
$
1.2
million
C
A
P
I
T
A
L
I
Z
E
D
C
0
S
T
$
9.7
million
(
ii)
Agency
tally
EPA
­
15­
EMPLOYEES
29
COST
$
4.2
million
6(
f)
Reasons
for
change
in
burden
Any
slight
change
in
estimated
burden
is
probably
not
significant;
i.
e.
the
process
is
incapable
of
making
an
estimate
with
that
precision.
To
the
extent
that
there
has
been
any
actual
change
it
should
be
attributed
to
"
adjustment";
EPA
has
not
made
any
program
changes
(
other
than
approved
rulemakings)
since
the
previous
ICR
renewal..

6(
g)
Burden
Statement
The
table
in
Section
6(
a)
presents
the
total
estimated
burden
for
the
motorcycle
and
light­
duty
emission
and
fuel
economy
compliance
programs;
approximately
542,118
hours/
year.
Annual
operating
and
capitalized
costs
are
approximately
$
1.2
million
and
$
9.7
million
respectively.
Because
the
universe
of
vehicle
manufacturers
is
quite
diverse,
there
is
no
"
typical"
respondent.
However,
the
burden
estimates
for
the
various
individual
activities
in
section
6(
a)
can
be
used
to
estimate
the
burden
for
a
particular
respondent.
These
estimates
include
time
to
review
applicable
regulations
and
guidance
documents,
generate
and
gather
the
necessary
information
and
submit
documents.

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.
The
OMB
control
numbers
for
EPA's
regulations
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Send
comments
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
through
the
use
of
automated
collection
techniques
to
the
Susan
Auby,
U.
S.
Environmental
Protection
Agency,
Collection
Strategies
Division
(
Mail
Code
2822),
1200
Pennsylvania
Avenue,
N.
W.,
Washington,
DC
20460­
0001;
and
to
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget
(
OMB),
Attention:
Desk
Officer
for
EPA,
725
17thStreet,
N.
W.,
Washington,
DC
20503.
Include
the
EPA
ICR
number
0783.42
and
OMB
control
number
2060­
0104
in
any
correspondence.
­
16­
­
17­
Attachment
I
Legal
Authority
&
Regulatory
Citations
Energy
Policy
and
Conservation
Act
15
U.
S.
C.
2003
Calculation
of
average
fuel
economy
(
a)
Method
of
calculation.

"(
1)
Average
fuel
economy
for
purposes
of
section
2002
(
a)
and
(
c)
of
this
title
shall
be
calculated
by
the
EPA
Administrator..."

(
d)
Testing
and
calculation
procedures.

"(
1)
Fuel
economy
for
any
model
type
shall
be
measured,
and
average
fuel
economy
of
a
manufacturer
shall
be
calculated
in
accordance
with
testing
calculation
procedures
established
by
EPA
Administrator,
by
rule..."

15
U.
S.
C.
2005.
Information
and
reports
(
c)
Tests,
reports,
etc.,
which
may
be
required
of
manufacturers.

"(
1)
Every
manufacturer
shall
establish
and
maintain
such
records,
make
such
reports,
conduct
such
tests,
and
provide
such
items
and
information
as
the
Secretary
or
EPA
Administrator
may,
by
rule,
reasonably
require
to
enable
the
Secretary
or
the
EPA
Administrator
to
carry
out
their
duties
under
this
subchapter
and
under
any
rules
prescribed
pursuant
to
this
subchapter..."

15
U.
S.
C.
2006.
Labeling
(
a)
Label
required
on
automobile;
contents.

"(
1)
Except
as
otherwise
provided
in
paragraph
(
2),
each
manufacturer
shall
cause
to
be
affixed,
and
each
dealer
shall
cause
to
be
maintained,
on
each
automobile
manufactured
in
any
model
year
after
1976,
in
a
prominent
place,
a
label
...

(
3)
The
form
and
content
of
the
labels
required
under
paragraphs
(
1)
and
(
2),
and
the
manner
in
which
such
labels
shall
be
affixed,
shall
be
prescribed
by
the
EPA
Administrator
by
rule..."
­
18­
Clean
Air
Act
42
U.
S.
C.
7525.
Motor
Vehicle
and
Motor
Vehicle
Engine
Compliance
Testing
and
Certification
(
a)
Testing
and
issuance
of
certificate
of
conformity.

"(
1)
The
Administrator
shall
test,
or
require
to
be
tested
in
such
manner
as
he
deems
appropriate,
any
new
motor
vehicle
or
new
motor
vehicle
engine
submitted
by
a
manufacturer
to
determine
whether
such
vehicle
or
engine
conforms
with
regulations
prescribed
under
section
7521
of
this
title.
If
such
vehicle
or
engine
conforms
to
such
regulations,
the
Administrator
shall
issue
a
certificate
of
conformity
upon
such
terms,
and
for
such
period
(
not
in
excess
of
one
year)
as
he
may
prescribe...

45
U.
S.
C.
7542.
Records
and
Reports
(
a)
Manufacturers
responsibility.

"
Every
manufacturer
shall
establish
and
maintain
such
records,
make
such
reports,
and
provide
such
information
as
the
Administrator
may
reasonably
require
to
enable
him
to
determine
whether
such
manufacturer
has
acted
or
is
acting
in
compliance
with
this
part
and
the
regulations
thereunder
and
shall,
upon
request
of
an
officer
or
employee
duly
designated
by
the
Administrator,
permit
such
officer
or
employee
at
reasonable
times
to
have
access
to
and
copy
such
records."

CODE
OF
FEDERAL
REGULATIONS
40
CFR
Part
85:
Control
of
Air
Pollution
from
Mobile
Sources.

40
CFR
Part
86:
Control
of
air
pollution
from
new
and
in­
use
highway
vehicles
and
engines.

40
CFR
Part
600:
Fuel
economy
of
motor
vehicles
­
19­
Attachment
II
Data
Items
List
40
CFR
citation
Description
85.1504
Application
for
conditional
admission,
imported
motor
vehicle
or
engine.

85.1505
Application
for
final
admission,
imported
motor
vehicle
or
engine.

85.1507
Recordkeeping;
vehicle
descriptions
and
compliance
of
imported
vehicles
and
engines.

85.1508
Recordkeeping;
owner
identification,
imported
vehicles
and
engines.

85.1509
Application
for
final
admission
of
conditionally
admitted
imported
motor
vehicles
and
engines.

85.1511
Application
for
exemptions/
exclusions
from
importation
requirements.

85.1512
Application
for
final
admission
of
previously
certified
or
previously
imported
motor
vehicle
or
motor
vehicle
engine.

85.1514
Request
for
confidential
treatment
of
information.

85.1515
Election
to
use
Nox
averaging,
banking
or
trading
provisions,
supporting
information.

85.1705
Application
for
testing
exemption,
motor
vehicle
or
motor
vehicle
engine.

85.1706
Application
pre­
certification
exemption,
motor
vehicle
or
motor
vehicle
engine.

85.1708
Application
for
national
security
exemption,
motor
vehicle
or
motor
vehicle
engine.

85.1712
Application
for
confidential
treatment
of
submitted
information,
applications
for
exemptions/
exclusions.
­
20­
85.1802
Remedial
plan
required,
nonconforming
motor
vehicle
or
motor
vehicle
engine
class.

85.1803
Remedial
plan
contents
and
requirements.

85.1806
Remedial
plan
progress
reports,
recordkeeping
of
owner
notifications.

85.1903
Emission
defect
reports,
motor
vehicles
and
motor
vehicle
engines.

85.1904
Voluntary
emission
recall
report;
motor
vehicle
and
motor
vehicle
engines.

85.1905
Request
to
use
alternate
report
format.

85.1906
Recordkeeping
requirements,
defect
reports.

85.1908
Disclaimer
of
production
warranty
applicability.

85.1909
Request
for
confidential
treatment
of
information.

85.2208
Application
for
alternative
short
test
procedure,
light
duty
vehicle
and
light
duty
truck.

86.107
Gas
chromatograph
records
required
for
evaporative
emission
test.

86.113
Availability
and
use
of
alternate
fuels
in­
use.

86.129
Records
required,
fuel
temperature
profile
determination.

86.142
Records
required,
exhaust
emission
test.

86.155
Records
required,
refueling
test.

86.162
Request
for
alternate
air
conditioning
test
simulations.

86.163
Substantiation
of
alternate
air
conditioning
test
simulation
correlation.

86.412
Submission
of
motorcycle
maintenance
instructions.

86.414
Submission
of
motorcycle
vehicle
identification
numbers,
description
of
numbering
system.

86.415
Submission
of
annual
motorcycle
production
reports.
­
21­
86.416
Application
for
motorcycle
certification.

86.421
Election
to
test
additional
vehicles.

86.423
Submission
of
optional
test
data.

86.427
Motorcycle
emission
testing.

86.428
Request
for
additional
scheduled
motorcycle
maintenance.

86.429
Request
for
unscheduled
motorcycle
test
vehicle
maintenance.

86.431
Motorcycle
test
data
submission
86.432
Election
to
use
optional
method
to
determine
deterioration
factor
86.434
Request
for
additional
testing.

86.435
Election
for
additional
service
accumulation.

86.437
Certification
of
motorcycle
compliance.

86.438
Amendments
to
the
motorcycle
application.

86.439
Amendments
to
the
motorcycle
application;
alternate
method.

86.440
Recordkeeping,
motorcycle
certification.

86.513
Availability
of
alternate
fuels.

86.542
Recordkeeping,
motorcycle
certification
testing.

86.603
Assembly
line
data
86.604
Request
for
reconsideration
on
use
of
EPA
data.

86.605
Recordkeeping,
submission
of
vehicle
production
data.

86.607
Request
for
alternate
procedures,
description
of
production
changes.

86.609
Submission
of
test
results
and
supporting
information.

86.612
Report
on
nonconformance,
corrective
action.
­
22­
86.615
Request
for
confidential
treatment
of
information
submitted.

86.709
Request
to
use
alternate
production
figures.

86.
908
Request
for
fee
waiver/
refund.

86.909
Applicant,
product
identification,
fee
category
86.1003
Assembly
line
data
86.1004
Request
for
reconsideration
on
use
of
EPA
data.

86.1005
Recordkeeping,
submission
of
vehicle
production
data.

86.1007
Request
for
alternate
selection
method.

86.1009
Submission
of
test
results
and
supporting
information.

86.1012
Report
on
nonconformance,
corrective
action.

86.1015
Request
for
confidential
treatment
of
submitted
information.

86.1106
Production
compliance
audit
information,
recordkeeping.

86.1107
Request
for
reconsideration
on
use
of
EPA
data.

86.1108
Maintenance
of
records.

86.1110
Request
for
alternate
test
procedures.

86.1113
Nonconformance
penalty
calculation.

86.1114
Report
on
nonconformance,
corrective
action.

86.1427
Request
for
alternate
short
test
procedure.

86.1442
Short
test
reports.

86.1542
Idle
test
reports.

86.1705
Manufacturer
election
of
NLEV
program.

86.1707
Manufacturer's
decision
to
opt­
out
of
NLEV
program.
­
23­
86.1712
Production
reports,
maintenance
of
records.

86.1721
Identification
and
production
information,
NLEV
vehicles.

86.1723
Emission
data,
NLEV
vehicles.

86.1734
Notification
of
production
vehicle
changes.

86.1805
Petition
for
alternative
useful
life
definition.

86.1806
Request
for
alternative
on
board
diagnostic
system
requirements.

86.1809
submission
of
detailed
calibration
information.

86.1811
Election
of
alternate
standards
and
phas­
in
requirements.

86.1817
Election
of
emission
limits,
submission
of
annual
report.

86.1823
Description
of
durability
demonstration
program.

86.1826
Election
of
assigned
deterioration
factors.

86.1829
Request
for
waivers,
data
substitution.

86.1839
Substantiation
of
data
substitution.

86.1840
request
for
special
test
procedures.

86.1842
Notification
of
production
changes.

86.1843
General
information
requirements.

86.1844
Product
description,
test
data
requirements.

86.1845
In­
use
testing
verification
requirements.

86.1847
Recordkeeping,
in­
us
testing
verification.

86.1862
Nox
averaging
recordkeeping
requirements.

600.005
Recordkeeping,
fuel
economy
data
vehicles.

600.006
Information
requirements,
fuel
economy
data
vehicles.
­
24­
600.007
Fuel
economy
data
requirements,
imported
vehicles.

600.010
Minimum
fuel
economy
data
requirements.

600.113
Fuel
analysis
required.

600.206
Fuel
economy
data
requirements,
dual
fuel
vehicles.
600.207
Model
type
fuel
economy
calculations,
data
requirements.

600.209
Information
requirements,
fuel
economy
label
calculations.

600.306
Fuel
economy
label,
information
requirements.

600.307
Fuel
economy
label,
information
requirements.

600.310
High
altitude
fuel
economy
label,
manufacturer
request.

600.311
Range
of
fuel
economy,
reporting
requirements.

600.312
Reporting
of
label
calculations,
recordkeeping
requirements.

600.313
Submission
of
fuel
economy
information.

600.314
Correction
of
fuel
economy
labels.

600.507
Submission
of
revised
fuel
economy
data.

600.509
Submission
of
voluntary
fuel
economy
data.

600.510
Calculation
of
average
fuel
economy,
adjustments.

600.512
Model
year
report,
submission
required.
