SUPPORTING
STATEMENT
FOR
INFORMATION
COLLECTION
REQUEST
Vehicle
Service
Information
Web
Site
Audit
EPA
ICR
2181.01
February
2005
Certification
and
Compliance
Division
Office
of
Transportation
and
Air
Quality
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
2
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection
Vehicle
Service
Information
Web
Site
Audit
(
b)
Short
Characterization/
Abstract
Section
202(
m)(
5)
of
the
CAA
directs
EPA
to
promulgate
regulations
requiring
vehicle
manufacturers
to
provide
to:

any
person
engaged
in
the
repairing
or
servicing
of
motor
vehicles
or
motor
vehicle
engines,
and
the
Administrator
for
use
by
any
such
persons,
*
*
*
any
and
all
information
needed
to
make
use
of
the
[
vehicle's]
emission
control
diagnostic
system
*
*
*
and
such
other
information
including
instructions
for
making
emission­
related
diagnoses
and
repairs.

In
order
to
meet
Congress'
intent
that
consumers
have
freedom
of
choice
in
where
to
have
their
vehicles
serviced,
it
is
essential
for
independent
technicians
to
have
access
to
timely
and
accurate
emission­
related
service
and
repair
information.
Industry
estimates
indicate
that
independent
technicians
perform
up
to
80%
of
all
vehicle
service
and
repairs.
Further,
independent
technicians
perform
more
repairs
on
older
vehicles
(
which
are
more
likely
than
newer
vehicles
to
have
higher
emissions)
than
technicians
in
franchised
dealerships.

EPA
finalized
regulations
in
June
of
2003
(
68
FR
38427;
June
27,
2003)
requiring
auto
manufacturers
to
launch
full
text
Web
sites
containing
all
required
service
information
for
1996
and
later
model
years.
In
order
to
assess
the
effectiveness
of
the
web
site
provisions
of
the
regulations,
EPA
believes
that
input
from
independent
technicians
must
be
of
primary
consideration.
As
part
of
our
broader
efforts
to
evaluate
the
OEM
web
sites,
EPA
is
initiating
a
process
to
gather
feedback
directly
from
the
technician
community
on
their
experiences
with
the
web
sites
and
to
communicate
those
findings
directly
to
the
OEMs
and
the
service
industry
as
a
whole.

2.
Need
for
and
Use
of
the
Collection
(
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
requiring
the
manufacturers
of
vehicles
and
engines
to
make
available
emissions­
related
repair
information
to
aftermarket
service
providers.
To
improve
timely
access
to
this
information,
EPA
is
requiring
that
vehicle
and
engine
manufacturers
provide
access
to
the
required
emissions­
related
information
in
full­
text
via
the
World
Wide
Web.
This
includes
enhanced
diagnostic
information
to
equipment
and
tool
companies
and
also
information
that
will
allow
these
companies
to
develop
pass­
through
reprogramming
tools.
To
ensure
compliance
with
these
statutes,
EPA
would
like
to
gather
feedback
directly
from
the
independent
technician
community
on
their
experiences
with
the
web
sites
and
to
communicate
those
findings
3
directly
to
the
OEMs
and
the
service
industry
as
a
whole.

(
b)
Practical
Utility/
Users
of
the
Data
EPA
staff
will
use
this
data
in
conjunction
with
other
internal
analyses
to
assess
the
effectiveness
of
the
service
information
web
sites
that
are
required
by
the
regulations.
In
addition,
this
information
will
be
used
by
the
Agency
to
determine
if
manufacturer
guidance
or
changes
to
the
regulations
are
needed.
Automobile
manufacturers
will
also
gain
valuable
feedback
from
end­
users
on
the
usability
of
their
web
sites.

3.
Non­
duplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
EPA
is
not
requesting
information
that
is
anyway
duplicative
of
other
information
being
requested
the
independent
technicians.

(
b)
Public
Notice
Prior
to
Submission
to
OMB
EPA
has
worked
with
automobile
manufacturers
in
preparation
for
the
project
and
have
their
full
support
on
this
project.
In
addition,
EPA
has
used
a
variety
of
public
avenues
including
presentations
at
industry
meetings,
conventions
and
other
public
forums
to
present
our
plans.
EPA
has
also
worked
with
a
variety
of
aftermarket
industry
associations
as
a
conduit
for
notifying
the
industry
as
a
whole
on
this
project.
EPA
believes
there
is
wide
industry
support
for
this
audit.

EPA
also
published
a
Federal
Register
Notice
on
April
27,
2005
to
solicit
comment
from
the
public
on
this
ICR.
EPA
received
comment
from
the
National
Automobile
Dealers
Association
(
NADA).
NADA
commented
that
EPA
misidentified
the
NAICS
Code
of
the
potential
participants
of
the
survey.
EPA
had
originally
identified
NAICS
Code
8111
which
is
the
general
category
for
automotive
repair
and
maintenance.
NADA
commented
that
EPA
should
include
other
NAICS
codes
including
automobile
dealers
(
NAICS
4411),
automotive
parts,
accessories
and
tire
stores
(
NAICS
4413),
gasoline
stations
(
NAICS
4471),
and
other
transportation
and
vehicle
maintenance
facilities
covered
under
two
digit
code
48.

In
response
to
this
comment,
EPA
believed
that
NAICS
code
8111
was
sufficiently
broad
to
encompass
the
diversity
of
the
automotive
repair
industry
and
we
did
not
intend
to
limit
participation
in
the
audit
by
selecting
this
particular
NAICS
code.
However,
in
order
to
avoid
any
perception
that
participation
will
be
limited,
EPA
believes
it
is
reasonable
to
add
the
NAICS
code
as
outlined
in
the
NADA
comments
and
has
changed
the
supporting
statement
for
this
ICR
accordingly.

NADA
also
commented
on
the
labor
rate
used
by
EPA
to
calculate
the
total
burden
of
this
ICR.
To
calculate
the
total
burden,
EPA
used
$
27/
hour.
NADA
commented
that
this
seemed
unreasonably
low
and
referenced
unidentified
2004
data
that
the
average
customer
labor
rate
for
new
car
dealers
(
NAICS
code
44111)
is
$
75/
hour.
4
In
response
to
this
comment,
the
$
27/
hour
figure
used
by
EPA
comes
from
the
Bureau
of
Labor
Statistics
Civilian
Worker
Cost
Table
which
was
most
recently
updated
on
June
16,
2005
(
http://
stats.
bls.
gov/
news.
release/
ecec.
t02.
htm).
This
table
estimates
the
costs
per
hour
worked
for
employee
compensation
and
costs
as
a
percent
of
total
compensation
for
the
civilian
workforce
by
occupational
and
industry
group.
According
to
this
table,
employee
compensation
for
the
occupational
group
that
represents
installation,
maintenance,
and
repair
workers
is
$
27.59/
hour.
EPA
consistently
uses
information
from
the
this
table
provided
by
the
Bureau
of
Labor
Statistics
to
estimate
ICR
burden
and
therefore
believe
that
this
figure
is
appropriate
to
use
for
this
ICR.

(
c)
Consultations
To
ensure
industry
participation,
EPA
has
developed
a
small
steering
committee
comprised
of
industry
leaders
including
automobile
manufacturers,
tool
companies,
independent
technicians,
aftermarket
associations,
and
other
industry
representatives
to
oversee
the
evaluation
as
it
moves
forward.
In
addition,
EPA
has
contracted
the
services
of
Perrin
Quarles
Associates,
Inc
(
PQA),
an
independent
consulting
firm,
to
help
oversee
the
process.
Among
other
things,
PQQ
will
be
developing
a
public
web
site
(
www.
oemaudit.
com)
dedicated
to
this
process
to
ensure
regulation
communication
with
interested
parties.

(
d)
Effects
of
Less
Frequent
Collection
To
minimize
burden
on
the
respondents,
EPA
is
limiting
the
time
period
of
response
to
approximately
a
12
week
time
frame.
We
believe
this
short
time
period
will
give
EPA
sufficient
information
to
assess
the
effectiveness
of
the
web
sites
while
minimizing
burden
on
the
participants.

(
e)
General
Guidelines
The
information
collected
under
this
action
adheres
to
OMB's
general
guidelines
for
information
collections
with
one
exception.
EPA
is
requesting
that
respondents
report
information
to
the
Agency
more
often
than
quarterly.
As
discussed
above,
EPA
is
requesting
respondents
to
report
to
the
agency
by
filling
out
one
questionnaire
once
every
2
weeks
over
a
12
week
period.
Given
the
hectic
nature
of
independent
repair
shops,
EPA
believes
it
is
necessary
to
establish
bi­
weekly
responses
over
a
short
period
of
time
in
order
to
ensure
the
maximum
amount
of
responses.
Otherwise,
EPA
is
concerned
that
participants
will
not
make
the
time
or
forget
to
respond
if
asked
to
submit
information
on
a
quarterly
basis.
In
addition,
this
is
a
one­
time
project
for
EPA
and
we
would
like
to
complete
the
audits
in
a
time
frame
of
approximately
1
year.

(
f)
Confidentiality
The
information
proposed
to
collected
under
this
ICR
is
not
considered
confidential.
It
is
expected
that
the
questions
to
be
asked
will
be
general
in
nature
regarding
technicians
opinions
and
experience
on
the
web
sites
they
will
evaluate.
Participants
will
only
be
asked
to
provide
their
name,
address,
phone
number
and
e­
mail.
No
other
confidential
or
personal
5
information
will
be
gathered.
A
final
report
compiling
the
results
will
be
made
available
to
the
public
late
in
2005.
The
report
will
not
contain
any
information
about
the
participants
or
any
information
that
would
otherwise
be
considered
confidential.

(
g)
Sensitive
Questions
No
sensitive
questions
are
asked.
The
collection
complies
with
the
Privacy
Act
and
OMB
Circular
A­
108.

4.
The
Respondents
and
the
Information
Requested
(
a)
Respondents/
NAICS
Codes
The
respondents
are
automotive
repair
and
maintenance
providers,
NAICS
code
8111.
This
industry
group
comprises
establishments
involved
in
providing
repair
and
maintenance
services
for
automotive
vehicles,
such
as
passenger
cars,
trucks,
and
vans,
and
all
trailers.
Establishments
in
this
industry
group
employ
mechanics
with
specialized
technical
skills
to
diagnose
and
repair
the
mechanical
and
electrical
systems
for
automotive
vehicles,
repair
automotive
interiors,
and
paint
or
repair
automotive
exteriors.
Respondents
also
include
automobile
dealers
(
NAICS
4411),
automotive
parts,
accessories
and
tire
stores
(
NAICS
4413),
gasoline
stations
(
NAICS
4471),
and
other
transportation
and
vehicle
maintenance
facilities,
covered
under
the
two
digit
code
48.

(
b)
Information
Requested
(
i)
Data
items
A
questionnaire
has
been
developed
in
conjunction
with
the
industry
steering
committee
and
is
attached.
The
questionnaire
is
divided
into
6
segments,
with
a
approximately
70
questions.
Some
of
the
questions
are
of
the
yes/
no
variety
and
some
require
ranking
on
a
scale
of
1­
5.
There
is
also
a
section
for
additional
comments.

Once
the
questionnaires
have
been
returned
at
the
end
of
the
12
week
audit
period,
respondents
will
not
be
requested
to
retain
records
of
any
kind
for
any
period
of
time.

(
ii)
Respondent
Activities
The
information
proposed
to
be
collected
will
be
collected
over
a
three­
month
period
beginning
as
soon
as
the
ICR
is
approved.
It
is
anticipated
that
volunteers
who
participate
in
the
process
will
be
asked
to
fill
out
an
electronic
questionnaire
every
two
weeks
and
return
it
to
the
contractor
electronically
via
the
internet.
It
is
anticipated
that
that
participants
will
spend
approximately
1­
2
hours
per
week
over
the
12
week
period
filling
out
and
returning
the
questionnaire.
EPA
expects
that
minimal
time
will
be
needed
to
review
instructions
nor
are
respondents
being
asked
to
acquire,
install,
or
utilize
any
technologies
other
than
those
6
already
widely
available
in
most
independent
repair
facilities.
There
will
be
some
time
associated
with
searching
the
web
sites
for
service
information,
but
this
activity
currently
occurs
on
a
regular
basis
in
many
facilities
and
respondents
are
only
being
asked
to
fill
out
the
questionnaires
in
response
to
their
existing
routine
information
searches.

To
recruit
volunteers
to
participate
in
the
audit,
EPA
and
the
steering
committee
will
use
industry
web
sites,
newsletters,
conferences,
and
other
means
to
get
as
many
participants
as
possible.
The
steering
committee
has
also
developed
an
auditor
application
which
will
be
made
available
on
the
www.
oemaudit.
com
web
site.

5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
In
coordination
with
the
contractor,
the
Agency
will
review
and
analyze
the
information
collected
and
develop
a
final
report.
Upon
completion
of
the
final
report,
it
will
be
distributed
to
interested
parties.
All
of
the
questionnaires
collected
under
this
activity
will
be
destroyed
a
short
time
after
the
final
report
has
been
issued.
Depending
upon
the
results,
EPA
may
consider
issuing
manufacturer
guidance
or
other
regulatory
changes
in
the
future.

(
b)
Collection
Methodology
and
Management
It
is
expected
that
the
questionnaire
will
be
posted
on
the
www.
oemaudit.
com
web
site
and
will
be
filled
in
electronically
and
returned
electronically
to
the
contractor.
In
turn,
the
contractor
will
compile
the
information
and
create
a
final
report
in
conjunction
with
EPA
staff
that
will
be
made
available
to
the
public
upon
completion.

(
c)
Small
Entity
Flexibility
Small
entity
flexibilities
are
not
needed
for
this
information
collection
activity.
Participation
in
the
audit
is
voluntary
based
on
the
desire
of
technicians
and
shop
owners
to
participate.

(
d)
Collection
Schedule
The
information
proposed
to
be
collected
will
be
collected
over
a
three­
month
period
beginning
approximately
August
1
and
ending
on
October
31.
It
is
anticipated
that
volunteers
who
participate
in
the
process
will
be
asked
to
fill
out
a
short
electronic
questionnaire
every
two
weeks
and
return
it
to
the
contractor
electronically
via
the
internet.
It
is
anticipated
that
that
participants
will
spend
approximately
1­
2
hours
per
week
over
the
12
week
period
filling
out
and
returning
the
questionnaire.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
7
Respondent
burden
has
been
estimated
by
consulting
with
independent
technicians
and
aftermarket
industry
associations
to
get
sense
of
how
much
time
per
week
they
would
expect
to
need
to
fill
in
and
return
the
questionnaire.

(
b)
Estimating
Respondent
Costs
(
i)
Labor
costs
Labor
rates
on
a
per
hour
basis
are
estimated
as
$
27/
hour
(
rounded).
This
rate
was
taken
from
the
Bureau
of
Labor
Statistics
Civilian
Worker
Cost
Table
which
was
most
recently
updated
on
June
16,
2005
(
http://
stats.
bls.
gov/
news.
release/
ecec.
t02.
htm).
This
table
estimates
the
costs
per
hour
worked
for
employee
compensation
and
costs
as
a
percent
of
total
compensation
for
the
civilian
workforce
by
occupational
and
industry
group.
According
to
this
table,
employee
compensation
for
the
occupational
group
that
represents
installation,
maintenance,
and
repair
workers
is
$
27.59/
hour.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
Participation
in
the
audit
requires
the
availability
of
desk
top
or
lap
top
computers
in
the
maintenance
facility
or
shop.
In
addition,
internet
access
is
needed
in
the
facility
in
order
to
access
the
information
on
individual
automobile
manufacturer
web
sites.
It
is
anticipated
that
a
vast
majority
of
vehicle
repair
facilities
have
already
made
these
capital
investments
for
the
day
to
day
operations
of
their
businesses
and
that
no
additional
costs
will
be
incurred
by
technicians
who
participate
in
the
audit.

Currently,
automobile
manufacturers
have
in
place
a
variety
of
fees
to
access
the
information
that
is
available
on
their
web
sites
averaging
from
approximately
$
20
for
24
hour
access
to
approximately
$
2000
for
yearly
access.
However,
the
automobile
manufacturers
have
agreed
to
arrange
for
free
access
to
all
their
web
sites
for
participants
for
the
3­
4
month
duration
of
the
audit.
Therefore,
participants
will
not
incur
any
additional
charges
or
fees
as
a
result
of
participating
in
the
audit.

(
c)
Estimating
Agency
Burden
and
Cost
EPA's
Outreach
and
Planning
Group
in
the
Certification
and
Compliance
Division
is
responsible
for
the
implementation
of
the
service
information
regulations
and
will
oversee
the
audit.
This
group
has
about
14
full­
time
employees.
We
project
a
total
of
50
hours
over
a
1
year
period
of
staff
time
(
at
$
67
per
hour,
loaded)
to
complete
this
project.
In
addition,
EPA
has
procured
the
services
of
Perrin
Quarles
Associates,
Inc
(
PQA),
an
independent
consulting
firm,
who
will
oversee
the
entire
process
including
facilitation
and
participation
in
meetings
and
conference
calls,
development
of
communication
tools,
creation
of
reports
and
documents,
and
performing
other
support
work
as
needed.
This
is
a
work
assignment
under
a
larger
contract
currently
in
place
with
PQA
to
assist
EPA
in
a
variety
of
compliance
assessment
activities.
The
web
site
audit
work
assignment
is
currently
funded
at
$
50,000
for
FY2005.
As
a
result,
EPA
estimates
that
the
Agency
Burden
and
Cost
will
be
minimal
given
that
a
contractor
is
already
in
place
in
help
facilitate
the
audit
process.
8
(
d)
&(
e)
Total
Burden
Hours
and
Cost
From
the
above
discussion
the
following
total
burden
and
cost
estimates
can
be
calculated.
Due
to
the
diverse
nature
of
the
vehicle
service
and
repair
industry,
there
is
no
typical
or
average
respondent.
Respondents
can
be
the
owner
of
a
large
or
small
shop
or
an
employee
of
a
large
or
small
shop.

Table
2
INDUSTRY
RESPONDENTS
250
TOTAL
BURDEN
HOURS
6,125
(.
5
hours
to
complete
auditor
application
and
2
hours/
week
over
12
weeks
to
conduct
the
audit,
resulting
in
24.5
hours/
response
X
250
respondents,
=
6,125
hours)
ANNUALIZED
BURDEN
HOURS
2,042
TOTAL
LABOR
COST
$
165,375
(
technical
labor
@
$
27.00/
hr)
ANNUALIZED
LABOR
COST
$
55,125
OPERATING
&
MAINTENANCE
COST
$
0
CAPITALIZED/
START­
UP
COST
$
0
EPA
EMPLOYEES
1
FTE
HOURS
50
TOTAL
LABOR
COST
$
3350
ANNUALIZED
LABOR
COST
$
1,117
(
f)
Burden
Statement
Section
6(
d)
&
(
e)
presents
the
total
estimated
burden
for
implementing
the
proposed
information
collection
requirements.

The
annual
public
reporting
and
record
keeping
burden
for
this
collection
of
information
is
estimated
to
average
24.5
hours
per
response.
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
collection,
validating,
and
verifying
information,
processing
and
maintaining
information,
9
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
number
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
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
0512,
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,
D.
C.
The
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
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.
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,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Please
include
the
EPA
Docket
ID
No.
OAR­
2004­
0512
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
section
is
not
applicable
to
this
ICR.
10
Attachment
I
Legal
Authority
&
Regulatory
Citations
Clean
Air
Act
42
U.
S.
C.
7525.
Motor
Vehicle
and
Motor
Vehicle
Engine
Compliance
Testing
and
Certification
45
U.
S.
C.
7542.
Records
and
Reports
40
CFR
Part
86
Control
of
Air
Pollution
From
Motor
Vehicles
and
New
Motor
Vehicle
Engines;
Revisions
to
Regulations
Requiring
Availability
of
Information
for
use
of
On­
Board
Diagnostic
Systems
and
Emission­
Related
Repairs
on
1994
and
Later
Model
Year
Light­
Duty
Vehicles
and
Light­
Duty
Trucks
and
2005
and
Later
Model
Year
Heavy­
Duty
Vehicles
and
Engines
Weighing14,000
Pounds
Gross
Vehicle
Weight
or
Less.
