1
DRAFT
Supporting
Statement
for
Information
Collection
Request
Cold
Temperature
Hydrocarbon
Emissions
Standards
for
Light­
Duty
Vehicles,
Light­
Duty
Trucks,
and
Medium­
Duty
Passenger
Vehicles
(
Proposed
Rule)

EPA
ICR
0783.50
February,
2006
Assessment
and
Standards
Division
Office
of
Transportation
and
Air
Quality
Office
of
Air
and
Radiation
U.
S.
Environmental
Protection
Agency
2
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
Identification
of
the
Information
Collection
(
a)
Title
and
Number
of
the
Information
Collection
"
Cold
Temperature
Hydrocarbon
Emissions
Standards
for
Light­
Duty
Vehicles,
Light­
Duty
Trucks,
and
Medium­
Duty
Passenger
Vehicles
(
Proposed
Rule)"
EPA
ICR
0783.50,
OMB
Control
No.
2060­
0104;
expiration
date
11­
30­
2008.

(
b)
Short
Characterization/
Abstract
The
Environmental
Protection
Agency
is
promulgating
stringent
new
controls
on
gasoline,
passenger
vehicles,
and
gas
cans
to
further
reduce
benzene
and
other
mobile
source
air
toxics.
The
action,
titled
"
Control
of
Hazardous
Air
Pollutants
from
Mobile
Sources,"
will
significantly
lower
emissions
of
benzene
and
the
other
air
toxics
in
three
ways:
(
1)
by
lowering
benzene
content
in
gasoline,
(
2)
by
reducing
exhaust
hydrocarbon
emissions
from
passenger
vehicles
operated
at
cold
temperatures,
and
(
3)
by
reducing
emissions
that
evaporate
from,
and
permeate
through,
portable
gasoline
containers.
The
three
components
of
the
action
are
covered
by
independent
ICRs.
Burdens
regarding
the
fuel
standards
are
covered
in
ICR
1591.20;
burdens
regarding
the
gasoline
container
standards
are
covered
in
ICR
2213.01.
The
present
ICR
covers
the
vehicle
emission
standards
that
appear
in
40
CFR
part
85
(
Control
of
Air
Pollution
from
Mobile
Sources)
and
part
86
(
Control
of
Emissions
from
New
and
In­
use
Highway
Vehicles
and
Engines).

Compliance
with
current
exhaust
hydrocarbon
emission
standards
passenger
vehicles
is
determined
by
testing
vehicles
at
an
ambient
temperature
of
approximately
75
°
F.
Recent
research
and
analytical
work
suggest
that
current
standards
often
do
not
result
in
robust
control
of
hydrocarbon
exhaust
emissions
when
vehicles
are
operated
at
cold
temperatures.
Data
indicate
that
emission
control
at
lower
temperatures
can
be
substantially
improved
using
the
same
technological
approaches
already
in
use
to
meet
the
stringent
standards
at
75
°
F.
Therefore,
passenger
vehicles
will
be
subject
to
new
hydrocarbon
emissions
standards
at
20
°
F.
A
credit
program
and
other
provisions
will
provide
flexibility
to
manufacturers,
especially
during
the
phase­
in
period
for
model
years
2010
to
2015.

Burdens
associated
with
the
existing
emissions
program
for
passenger
vehicles
were
updated
in
ICR
0783.47
(
May
2005).
The
present
ICR
addresses
additional
incremental
burdens
associated
with
submitting
cold
temperature
hydrocarbon
emissions
data
to
the
EPA
for
certification
and
compliance.
EPA's
processing
of
this
information
will
be
conducted
by
the
Compliance
and
Innovative
Strategies
Division,
Office
of
Transportation
and
Air
Quality,
Office
of
Air
and
Radiation.

Information
collected
under
this
ICR
will
consist
of
cold
temperature
hydrocarbon
emissions
data
and
calculations
for
the
related
averaging,
banking,
and
trading
(
ABT)
credit
program.
Data
submitted
by
manufacturers
will
be
reviewed
by
EPA
staff
to
verify
that
the
necessary
tests
have
been
performed
and
the
manufacturer's
product
line
meets
3
emission
standards.
Information
will
be
submitted
in
electronic
format
for
inclusion
in
EPA's
computer
databases.
Subject
to
confidentiality
claims,
this
information
will
be
made
available
to
interested
parties
upon
request.
Emission
test
information
will
be
available
on
the
internet.

Approximately
35
passenger
car
and
light
truck
manufacturers
(
allowing
for
interand
intra­
corporate
relationships
and
including
independent
commercial
importers
and
alternative
fuels
vehicle
converters)
will
submit
cold
temperature
hydrocarbon
data
each
year
to
certify
their
products.
The
addition
of
the
cold
temperature
hydrocarbon
emissions
program
will
impose
a
cost
of
about
$
80,900
annually
on
the
regulated
industries:
$
54,100
in
ongoing
labor
costs
and
$
26,800
in
amortized
start­
up
capital
costs.
EPA
estimates
no
ongoing
operations
and
maintenance
costs.

2.
Need
For
and
Use
of
the
Collection
(
a)
Need/
Authority
for
the
Collection
Title
II
of
the
Clean
Air
Act
(
42
U.
S.
C.
7521
et
seq.)
requires
EPA
to
issue
certificates
of
conformity
for
motor
vehicle
designs
that
comply
with
applicable
emission
standards.
A
manufacturer
must
have
a
certificate
before
vehicles
may
be
legally
introduced
into
commerce.
To
ensure
compliance
with
this
statute,
EPA
reviews
product
information
and
manufacturer
test
results.

EPA's
emission
compliance
program
is
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.
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
ensure
that
each
vehicle
design
complies
with
emission
standards.
This
information
is
also
used
by
various
state
and
local
governments
in
running
their
vehicle
Inspection
and
Maintenance
(
I/
M)
programs.

The
regulations
dealing
with
light­
duty
vehicle,
light­
duty
truck,
and
medium­
duty
passenger
vehicle
emission
control
can
be
found
in
40
CFR
Parts
85
and
86.
The
regulations
are
not
attached
to
this
statement
due
to
their
length
and
technical
nature.

(
b)
Practical
Utility/
Users
of
the
Data
EPA
will
use
the
cold
temperature
hydrocarbon
data
submitted
by
manufacturers
to
determine
compliance
with
the
proposed
cold
temperature
hydrocarbon
emissions
standards.
Motor
vehicle
manufacturers
currently
submit
an
application
for
emission
certification
prior
to
production.
The
application
describes
the
major
aspects
of
the
proposed
product
line,
technical
details
of
the
emission
control
systems,
and
the
results
of
tests
to
indicate
compliance
with
existing
emissions
standards.
The
application
and
supporting
test
results
are
reviewed
and,
if
appropriate,
a
certificate
of
conformity
is
4
issued.
The
cold
temperature
hydrocarbon
data
will
be
added
to
applications
for
certification.

An
application
for
certification
is
submitted
for
each
of
the
manufacturer's
test
groups.
A
test
group
is
a
selection
of
the
product
line
that
will
be
certified
to
a
single
emission
standard,
has
the
same
number
and
arrangement
of
cylinders,
and
falls
within
a
limited
range
(
slightly
less
than
one
liter)
of
displacement.
(
Test
groups
are
defined
in
40
CFR
86.1827.)
For
the
cold
temperature
hydrocarbon
program,
each
test
group
will
be
certified
to
a
specific
cold
temperature
hydrocarbon
emission
level.
Then,
sales
of
vehicles
in
each
test
group,
along
with
each
test
group's
emission
level,
will
be
used
to
determine
a
fleet­
wide
sales­
weighted
average
cold
temperature
hydrocarbon
emission
level.
This
fleet­
average
emission
level
will
be
used
to
determined
compliance
with
the
standard.
A
credit
banking
and
trading
program
will
allow
manufacturers
whose
fleet
average
falls
below
the
standard
to
bank
credits
for
future
use
or
sale
to
other
manufacturers.
Manufacturers
whose
fleet
average
falls
above
the
standard
can
use
banked
or
purchased
credits
to
meet
the
standard.

When
a
new
model
year
vehicle
is
sufficiently
similar
to
the
previous
year's
model
that
the
test
group
descriptions
do
not
need
to
be
changed,
a
certification
application
can
be
"
carried
over"
from
the
previous
application.
The
burden
of
preparing
the
application
in
such
cases
will
be
less
because
previous
test
results
can
be
used,
and
the
vehicle
will
be
less
likely
to
be
selected
for
confirmatory
testing.
If
the
model
has
changed
such
that
its
test
group
designations
change,
then
new
supporting
application
information
will
be
required.
Similarly,
when
manufacturers
make
minor
changes
that
affect
the
test
group
for
an
already
certified
engine
model,
a
"
running
change"
for
that
change
must
be
submitted
and
a
new
certificate
issued
if
the
effect
on
emissions
is
substantial.
The
paperwork
burden
for
such
running
changes
is
usually
quite
small.

3.
Nonduplication,
Consultations,
and
Other
Collection
Criteria
(
a)
Nonduplication
Efforts
have
been
made
to
eliminate
duplication
in
this
information
collection.
The
cold
temperature
hydrocarbon
emissions
compliance
program
will
be
highly
integrated
with
existing
emissions
programs.
Data
from
all
programs
and
for
various
standards
will
be
submitted
collectively
and
electronically
during
the
certification
process.

Because
of
the
specialized
nature
of
the
data
submitted
by
manufacturers
and
the
fact
that
product
plans
and
emission
performance
information
must
be
submitted
to
EPA
prior
to
the
start
of
production,
this
information
is
not
available
from
any
source
other
than
the
manufacturer.

(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
The
proposed
information
collection
represented
by
this
ICR
is
included
in
the
notice
of
proposed
rulemaking,
"
Cold
Temperature
Hydrocarbon
Emissions
Standards
for
Light­
Duty
5
Vehicles,
Light­
Duty
Trucks,
and
Medium­
Duty
Passenger
Vehicles
(
Proposed
Rule),"
40
CFR
Parts
59,
80,
85
and
86,
Docket
Number
EPA­
HQ­
OAR­
2005­
0036;
RIN
2060­
AK70.
A
copy
of
the
proposed
rule
is
available
in
this
docket
and
will
be
submitted
for
publication
in
the
Federal
Register.

(
c)
Consultations
The
proposed
regulations,
including
the
cost
analysis
that
is
reflected
in
this
ICR,
were
developed
in
close
consultation
with
the
affected
industry.
In
early
May
2005,
EPA
met
with
the
Alliance
of
Automobile
Manufacturers
to
begin
formal
discussions.
Since
then,
there
have
been
multiple
discussions
with
the
Alliance,
as
well
as
individual
manufacturers
including
Ford,
GM,
DaimlerChrysler,
Honda,
Toyota,
Mercedes,
Mitsubishi,
and
Nissan.

The
individuals
consulted
have
experience
with
various
aspects
of
EPA's
current
programs,
and
were
able
to
lend
their
opinions
regarding
the
additional
reporting
burdens
associated
with
a
new
cold
temperature
hydrocarbon
standard.
Their
collective
input
has
been
reflected
in
the
burden
estimates
discussed
below.

(
d)
Effects
of
Less
Frequent
Collection
As
required
by
the
Clean
Air
Act
(
42
USC
7525(
a)),
emission
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.
Because
of
these
statutory
guidelines
and
evolving
product
lines,
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
of
new
information
required
is
substantially
reduced.

(
e)
General
Guidelines
Manufacturers
are
required
to
keep
some
records
for
periods
longer
than
three
years.
This
requirement
stems
from
the
statutory
requirement
that
manufacturers
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
to
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
function
during
the
life
of
the
warranty
and
that
emissions
limitations
are
met
during
the
full
useful
lives.
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.
The
proposal
makes
no
changes
in
the
reporting
and
recordkeeping
provisions
that
impact
any
of
the
guidelines
for
information
collections
as
approved
in
the
6
existing
approved
collection.

(
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
publicly
available.
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.

(
g)
Sensitive
Questions
No
sensitive
questions
are
asked
in
this
information
collection.
This
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
involved
in
the
industries
shown
in
the
following
table:

Category
NAICS
Code
A
Examples
of
Potentially
Regulated
Entities
Industry
33611
336112
Motor
vehicle
manufacturers
Industry
811112
811198
Commercial
importers
of
vehicles
and
vehicle
components.

A
North
American
Industry
Classification
System
(
NAICS)

(
b)
Information
Requested
(
i)
Data
items
The
information
and
reporting
burden
associated
with
this
rule
occurs
within
the
context
of
EPA's
motor
vehicle
certification
program.
Manufacturers
must
submit
an
application
for
emission
certification
prior
to
production.
The
application
describes
the
major
aspects
of
the
proposed
product
line,
technical
details
of
the
emission
control
systems,
and
the
test
results
to
indicate
compliance
with
the
emissions
limitations.
EPA
reviews
the
application
and
supporting
test
results
and,
if
appropriate,
issues
a
certificate
of
conformity.

Current
regulations
already
require
manufacturers
to
collect
hydrocarbon
emissions
data
at
cold
ambient
temperatures
(
40
CFR
Subpart
C,
sections
86.244
and
86.144).
These
7
data
are
collected
as
part
of
a
standard
for
carbon
monoxide
(
CO)
emissions
at
cold
ambient
temperatures
of
approximately
20
°
F.
With
the
implementation
of
the
new
cold
temperature
hydrocarbon
standard,
manufacturers
will
now
be
required
to
process
and
report
the
hydrocarbon
data
that
they
are
already
collecting
and
include
the
data
on
applications
for
certification
(
40
CFR
86.1811
and
86.1864).
Along
with
the
hydrocarbon
emissions
data,
manufacturers
will
also
submit
information
on
their
salesweighted
fleet
average
cold
temperature
NMHC
emission
levels
and
related
credit
calculations.

(
ii)
Respondent
Activities
Under
the
new
standard,
manufacturers
will
report
cold
temperature
hydrocarbon
emissions
data
which
they
currently
generate
from
testing
procedures
required
by
regulation.
Manufacturer
testing,
data
collection
and
storage,
and
reporting
mechanisms
are
largely
in
place
to
accommodate
the
requirements
of
the
new
cold
temperature
hydrocarbon
emissions
standard
and
will
require
only
minimal
modifications.
The
manufacturers
will
add
the
cold
NMHC
data
to
the
application
for
certification
process
accounted
for
in
ICR
0783.47.
Though
the
overall
emission
compliance
program
is,
of
necessity,
quite
complex
given
the
diversity
of
products
available,
the
additional
information
collection
activities
related
to
the
proposed
standard
are
relatively
minor.

5.
The
Information
Collected 
Agency
Activities,
Collection
Methodology,
and
Information
Management
(
a)
Agency
Activities
EPA
will
review
the
cold
temperature
hydrocarbon
data
electronically
submitted
by
a
manufacturer
as
part
of
the
manufacturer's
application
for
certification.
A
significant
portion
of
EPA's
emission
compliance
activity
is
spent
reviewing
applications
to
verify
that
the
correct
vehicle
tests
have
been
conducted,
that
the
necessary
information
has
been
submitted,
and
that
the
emissions
levels
comply
with
appropriate
standards.
Additionally,
running
change
submissions
must
also
be
reviewed
for
possible
emissions
impacts
and
manufacturers'
evaluations
thereof.
EPA
will
also
monitor
the
credit
banking
and
trading
program.
The
cold
temperature
hydrocarbon
emissions
data
will
be
added
to
various
EPA
publications,
such
as
the
Green
Vehicle
Guide
and
annual
emissions
reports.

(
b)
Collection
Methodology
and
Management
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
through
the
CFEIS
system
and
the
VERIFY
system
under
development.
Remaining
information,
including
diagrams
and
narrative
descriptions,
is
submitted
on
optical
disc.
The
proposed
rule
would
require
only
minor
changes
to
this
reporting
system
currently
used
by
manufacturers.
8
All
information
received
by
EPA
is
subject
to
review.
Data
submitted
electronically
is
automatically
screened;
test
results
that
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
program
relies
on
a
combination
of
"
worst
case"
and
representative
data
to
accomplish
its
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
data
are
available
on
the
internet;
other
information
is
available
upon
request
under
the
Freedom
of
Information
Act.

(
c)
Small
Entity
Flexibility
EPA
has
special
procedures
in
place
for
small­
volume
LDV/
LDT
manufacturer
certifications;
i.
e.,
those
whose
total
sales
are
less
than
15,000
units
per
year.
These
special
procedures
allow
the
small­
volume
manufacturer
to
submit
a
simplified
application
for
certification
with
respect
to
durability
demonstrations.
Further,
by
the
very
nature
of
their
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).
Another
provision
for
small
manufacturers
is
the
reduced
certification
fees
available
for
manufacturers
and
importers
of
vehicles,
who
may
pay
one
percent
of
the
expected
retail
sales
value
of
the
vehicles
if
that
is
less
than
the
normal
fee.
These
flexibilities
are
already
in
place
and
will
not
change
under
the
proposed
standard.

(
d)
Collection
Schedule
The
cold
temperature
NMHC
standards
will
apply
to
2010
and
later
model
year
passenger
vehicles
and
trucks
under
6,000
lbs
gross
vehicle
weight
rating
(
GVWR),
and
2012
and
later
model
year
trucks
between
6,000
and
8,500
lbs
GVWR
and
medium­
duty
passenger
vehicles
between
8,500
and
10,000
lbs
GVWR.
As
shown
in
Table
5.1,
the
lighter
vehicles
will
follow
a
phase­
in
schedule
that
will
result
in
100
percent
compliance
for
model
years
2013
and
beyond.
The
heavier
vehicles
will
follow
a
phase­
in
schedule
that
will
result
in
100
percent
compliance
for
model
years
2015
and
beyond.
During
the
three
model
years
before
full
compliance,
manufacturers
must
ensure
25,
50,
and
75
percent
compliance,
respectively.

Table
5.1
 
Standard
and
Phase­
in
Schedule
Phase­
In:
Percentage
of
Vehicles
by
Model
Year
Vehicle
Category
Fleet­
Average
NMHC
Emissions
(
grams/
mile)
2010
2011
2012
2013
2014
2015
LDVs
&
LLDTs
( 
6,000
lbs
GVWR)
0.3
25%
50%
75%
100%

HLDTs
(>
6,000
 
8,500
lbs
GVWR)
&

MDPVs
(>
8,500
 
10,000
lbs
GVWR)
0.5
25%
50%
75%
100%

To
earn
credits
or
phase­
in
flexibilities,
manufacturers
will
have
the
option
of
certifying
lighter
vehicles
to
the
cold
temperature
hydrocarbon
standards
as
early
as
the
9
2008
model
year
and
heavier
vehicles
as
early
as
the
2010
model
year.
Therefore,
there
will
be
no
reporting
burdens
in
2006
or
2007.
Early
submissions
(
i.
e.,
those
that
manufacturers
voluntarily
submit
before
2010
for
light
vehicles
and
2012
for
heavy
vehicles)
must
comply
with
all
reporting
and
recordkeeping
requirements.

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.

6.
Estimating
the
Burden
and
Cost
of
the
Collection
(
a)
Estimating
Respondent
Burden
Respondent
burden
estimates
reflect
full
implementation
of
the
program
for
both
heavy
and
light
vehicles
in
model
year
2015.
Burdens
hours
for
the
average
individual
respondent
are
shown
in
Table
6.1
below.
EPA
conducted
informal
consultations
with
fewer
than
nine
respondents
from
the
regulated
community
to
obtain
burden
hour
estimates.
The
burden
to
each
respondent
is
estimated
to
be
minimal
for
several
reasons.
First,
we
assumed
that
there
will
be
no
new
testing
burden
since
the
respondents
will
collect
the
necessary
data
in
the
context
of
the
existing
cold
CO
emissions
program.
Testing
burdens
associated
with
cold
CO
standards
were
carefully
analyzed
in
ICR
0783.47.
Second,
the
burden
hours
do
not
include
one­
time
labor,
such
as
time
spent
by
respondents
initially
familiarizing
themselves
with
reporting
requirements
or
upgrading
software.
Such
labor
costs
are
treated
as
one­
time
capital/
start­
up
costs
and
are
amortized
over
ten
years.
Finally,
the
ongoing
labor
hours
account
for
only
the
time
spent
processing
the
cold
NMHC
data
portion
on
applications
for
certification
and
ABT­
related
burdens.
Burdens
associated
with
submission
and
recordkeeping
of
other
data
on
applications
have
already
been
accounted
for
in
ICR
0783.47.

(
b)
Estimating
Respondent
Costs
(
i)
Estimating
labor
costs
Labor
costs
for
an
individual
respondent
are
shown
in
Table
6.1
below.
The
hourly
labor
rates
used
to
determine
labor
costs
are
national
average
hourly
rates
from
November
2004
Bureau
of
Labor
Statistics
survey
data
for
an
Engineering
Manager
SOC
11­
9041
($
50.10),
a
Mechanical
Engineer
SOC
17­
2141
($
33.41),
and
Office/
Admin.
Support
SOC
43­
9199
($
13.23).
The
rates
shown
here
for
management,
technical,
and
clerical,
respectively,
do
not
include
overhead.
An
overhead
multiplier
of
100
percent
was
added
for
the
purpose
of
calculating
labor
costs.
With
the
multiplier
added,
the
rates
are
$
100.20,
$
66.82,
and
$
26.46,
respectively.

The
labor
costs
in
this
section
reflect
the
ongoing
costs
associated
with
processing
raw
10
data
from
emissions
tests
and
incorporating
that
data
on
applications
for
certification.
Processing
data
means
converting
the
raw
data
to
the
appropriate
reported
emission
levels
to
reflect
new
car
emissions
and
"
full
useful
life"
emissions
at
120,000
miles
of
use.
Labor
costs
also
include
time
spent
gathering
and
submitting
ABT
credit
program
information,
such
as
numbers
of
vehicles
sold,
emission
levels,
and
credit
calculations.
One­
time
labor
costs,
such
as
for
time
respondents
spend
initially
familiarizing
themselves
with
reporting
requirements,
are
not
included
here.
Instead,
these
costs
are
considered
capital/
start­
up
costs,
and
are
amortized
and
reported
in
this
ICR
as
annual
capital
costs.

Table
6.1
 
Annual
Burden
Hours
and
Labor
Costs
for
Average
Individual
Respondent
(
model
year
2015
and
beyond)

Burden
Hours
per
Activity
Activity
Avg.
No.
Activities
per
Year
Mgmt.
Technical
Clerical
Total
Burden
Hours
per
Year
Cost
Per
Activity
Total
Labor
Cost
per
Year
Process
data
and
include
on
applications
for
certification
6.3
0.5
1.0
0.1
10.1
$
119
$
750
Collect
and
submit
ABT
information
1.0
1.0
10.0
1.0
12.0
$
790
$
790
TOTAL
7.3
1.5
11.0
1.1
22.1
$
1,540
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
EPA
estimates
no
additional
capital
or
O&
M
costs
associated
with
the
reporting
and
recordkeeping
requirements
of
the
cold
NMHC
data
for
certification
and
compliance
purposes.
Vehicle
emissions
testing
laboratory
equipment,
computers,
data
collection
and
processing,
and
reporting
and
recordkeeping
frameworks
are
already
in
place
as
part
of
the
existing
cold
CO
emissions
program.
The
only
ongoing
costs
are
expected
to
come
from
the
additional
labor
hours
spent
processing
cold
NMHC
data
for
applications
and
ABTrelated
burdens,
which
are
accounted
for
as
labor
costs
in
section
6(
b)(
i).

(
iii)
Capital/
Start­
up
Operating
and
Maintenance
Costs
Capital/
start­
up
and
O&
M
costs
for
an
individual
respondent
are
shown
in
Table
6.2
below.
The
costs
in
this
section
represent
amortized
initial
one­
time
costs
associated
with
processing
cold
NMHC
data.
These
startup
burdens
are
primarily
information
technology
and
paperwork
costs
involving
familiarization
with
the
new
data
reporting
requirements
and
reformatting
management
information
systems
to
carry
out
and
report
the
necessary
data
and
calculations.
All
these
burdens
are
add­
ons
to
well­
established
reporting
mechanisms
for
compliance
and
ABT
programs.

Table
6.2
 
Annual
Capital/
Start­
up
Costs
for
Average
Individual
Respondent
(
model
year
2015
and
beyond)

Activity
Avg.
Number
of
Activities
per
Year
Total
Cost
per
Year
Familiarize
with
reporting
requirements
One­
time
amortized
cost
$
330
Upgrade
data
collection
software
One­
time
amortized
cost
$
440
TOTAL
$
770
11
(
c)
Estimating
Agency
Burden
and
Cost
Agency
burden
estimates
reflect
full
implementation
of
the
program
for
both
heavy
and
light
vehicles
in
model
year
2015.
Labor
rates
and
associated
costs
are
based
on
Office
of
Personnel
Management
Table
2003­
RUS
for
management
grade
GS­
15
($
50.10),
staff
grade
GS­
13
($
33.41),
and
clerical
grade
GS­
7
($
13.23).
An
overhead
of
60
percent
was
added,
resulting
in
the
following
labor
rates:
management
$
81.36;
staff
$
58.53;
and
clerical
$
27.74.

EPA
estimates
the
Agency
will
spend
about
430
labor
hours
at
a
total
annual
cost
for
ongoing
labor
of
$
25,300
per
year.
A
significant
portion
of
EPA's
emission
compliance
activity
is
spent
reviewing
applications
to
verify
that
the
correct
vehicle
tests
have
been
conducted,
that
the
necessary
information
has
been
submitted,
and
that
the
emissions
levels
comply
with
appropriate
standards.
These
costs
also
include
answering
respondent
questions,
monitoring
the
ABT
program,
and
adding
cold
temperature
hydrocarbon
emissions
data
to
various
EPA
publications,
such
as
the
Green
Vehicle
Guide
and
annual
emissions
reports.

EPA
estimates
no
new
ongoing
capital
or
O&
M
costs
associated
with
the
information
collection.
Computers,
data
collection
and
processing,
and
reporting
and
recordkeeping
frameworks
are
already
in
place
as
part
of
the
existing
cold
CO
emissions
program.

EPA
estimates
minimal
initial
one­
time
capital/
start­
up
costs.
These
costs
will
result
from
time
spent
familiarizing
staff
with
the
new
regulations
and
costs
related
to
software
upgrades.
We
are
estimating
start­
up
costs
of
$
1,600
per
year
when
amortized
over
ten
years.

(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Upon
full
implementation
of
the
cold
temperature
NMHC
program
in
2015,
EPA
estimates
that
each
year
approximately
35
respondents
will
submit
a
combined
total
of
approximately
220
certification
applications
for
compliance
with
cold
NMHC
data
reporting
requirements.
Due
to
the
diverse
nature
of
the
motor
vehicle
industry,
there
is
no
typical
or
average
respondent.
However,
the
overall
burden
to
the
respondent
universe
will
be
quite
minimal
since
the
reporting
and
recordkeeping
infrastructure
is
already
in
place.

(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
Total
Annual
Burden
Hours
770
Total
Annual
Labor
Cost
$
54,100
Total
Annual
O&
M
Cost
0
Total
Annual
Capital
Cost
$
26,800
(
ii)
The
Agency
Tally
12
Total
Annual
Burden
Hours
430
Total
Annual
Labor
Cost
$
25,300
Total
Annual
O&
M
Cost
0
Total
Annual
Capital
Cost
$
1,600
(
iii)
Variations
in
the
Annual
Bottom
Line
The
costs
shown
reflect
burdens
upon
full
implementation
of
the
standards
in
2015,
after
which
EPA
does
not
anticipate
any
significant
annual
variations
in
the
bottom
line.

(
f)
Reasons
for
Change
in
Burden
The
burden
reported
in
this
ICR
is
attributed
to
a
new
regulation.
Since
the
proposed
rule
makes
no
changes
to
the
type
of
information
collection
which
manufacturers
currently
undertake,
the
only
burdens
are
a
result
of
submitting
the
data
to
EPA.

(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
22.1
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
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.

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
EPA­
HQ­
OAR­
2005­
0036,
which
is
available
for
online
viewing
at
www.
regulations.
gov,
or
in
person
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
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
at
www.
regulations.
gov.
This
site
can
be
used
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
When
in
the
system,
select
"
search,"
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
13
Washington,
D.
C.
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
EPA­
HQ­
OAR­
2005­
0036
and
OMB
Control
Number
2060­
0104
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
Section
is
not
applicable
to
this
ICR.
