  SEQ CHAPTER \h \r 1 

Supporting Statement

for

Information Collection Request

Information Requirements for Importation of Nonconforming Vehicles
(Renewal)

EPA ICR 0010.11

December 2006

Compliance and Innovative Strategies Division 

Office of Transportation and Air Quality 

Office of Air and Radiation 

U.S. Environmental Protection Agency

PART A OF THE SUPPORTING STATEMENT

1.    IDENTIFICATION OF THE INFORMATION COLLECTION

(a)  TITLE OF THE INFORMATION COLLECTION

    Information Requirements for Importation of Nonconforming Vehicles,
OMB Control Number 2060-0095, ICR 0010.11.

(b)  SHORT CHARACTERIZATION (ABSTRACT)

     The Clean Air Act requires motor vehicles and engines imported into
the U.S. to conform to applicable emission requirements.  This
Information Collection Request covers importation reporting requirements
for light-duty vehicle, light-duty truck, and on-road motorcycle
vehicles and engines. The information collection instruments are Form
3520-1 (“Form 1) for initial entry, and Form 3520-8 (“Form 8”) for
final entry (see below). All heavy-duty on-road and all non-road vehicle
and engine importation reporting requirements are now covered by EPA ICR
Series 1723 (OMB 2060-0320). The two programs use separate forms, have
differing regulatory provisions, and are processed by differing staffs.
Most importers are also required to apply for and obtain a certificate
of conformity from EPA; that information burden for the light-duty and
motorcycle certification program is covered by EPA ICR Series 0783 (OMB
2060-0104).  There is some overlap between the present ICR and 0783
because testing for Independent Commercial Importers (ICIs) is reported
both on Form 8, covered by this ICR, and, initially, and in more detail,
for certification via ICR 0783. (Similarly, all importing light-duty
vehicle and motorcycle manufacturers, and not just ICIs, use Form 1.)
Thus, the certification information burden is covered in ICR 0783 and
the (different and less detailed) testing burden for imports subsequent
to certification in this ICR. 

     Rather than attempting to allocate the fees for light-duty vehicle
and motorcycle imports between initial certification fees and additional
fees upon importation of additional vehicles under a certificate (most
ICIs pay reduced fees and therefore pay additional 1% fees upon each
additional import) the entire import fees burden is included under ICR
0783. The burden of submitting the fee and associated forms is covered
by EPA ICR Series 2080 (OMB 2060-0545).

     The post-certification, final-entry testing burden for light-duty
vehicle imports falls into two categories. For regular light-duty ICIs,
a city test (the “FTP”) is required for every third vehicle imported
under a certificate for the first 300 vehicles imported, and every fifth
thereafter (40 CFR 85.1505). The other light-duty imports category is
“mod and test”, which applies to vehicles whose original production
year is six or more prior to the year of importation. Each such vehicle
must be modified to meet applicable emissions requirements and tested
with the FTP (40 CFR 85.1509). In the first case, each FTP test will be
accompanied by a 2-hour evaporative emissions test, in the second case
by an OBD (on-board diagnostics) demonstration, and in both cases by a
highway test in order to compute a combined fuel economy number to
comply with gas guzzler fuel economy requirements. Form 8 includes
spaces for reporting the test results and combined fuel economy for
those vehicles that undergo them. For motorcycle imports, no additional
testing is required beyond the original certification testing. Only four
nonconforming motorcycles have been imported in the last two years. 

     Most ICIs contract with a broker to do some of the imports process
and a testing laboratory to perform the necessary tests. The testing lab
also performs whatever modifications are necessary to bring the vehicle
up to certification standards. 

     The Compliance and Innovative Strategies Division  (CISD) in
EPA’s Office of Transportation and Air Quality collects information
and requires some recordkeeping to help insure that imported vehicles
and engines are brought into compliance with federal emission
requirements or that they qualify for exemption or exclusion from them.
“Nonconforming” refers to the vehicles and engines that are not
constructed to EPA certification standards and therefore must meet
various additional requirements, such as testing, prior to being
certified and available for sale in the U.S.  The information is also
used by the U.S. Customs Service (Customs), state regulatory agencies,
businesses, and individuals to verify whether or not vehicles are in
compliance.

    Information collected includes vehicle identification data, U.S.
Customs entry statements that such information is correct, and summary
emission test results.  The information is either stored in a computer
database, or retained in document form.  The information is used to
monitor compliance of imports and respond to inquiries from the public
concerning the compliance status of specific imported vehicles. This
information is collected on two forms (attached):

EPA Form 3520-1.  This form is used by importers who are applying for
entry into the U.S. of light-duty vehicle, light-duty truck, and
motorcycle vehicles or engines, whether conforming, nonconforming,
exempt, or excluded.  The form identifies to all parties involved the
category of import and the requirements that are appropriate to that
category. The form goes from the importer or its agent (broker) to
Customs, which stamps the form and forwards it in batch to EPA. EPA
gathers the forms in Ann Arbor where they are logged and filed for
future reference.   

EPA Form 3520-8. This form is used by ICIs to request “final
admission” of a nonconforming vehicle or engine upon their
certification that it has been brought into compliance with Federal
emission requirements. The form is held for fifteen days, during which
the ICI can not release the vehicle for sale or to its owner. This gives
EPA a chance to conduct any review or oversight, including confirmation
testing, deemed necessary before the vehicle or engine is released. 

     The information collection will involve an estimated yearly 12,352
responses from 12,005 respondents at an O&M cost of $1,780, a capital
cost of  $104,790, and a labor cost of $431,765.

2.   NEED FOR AND USE OF THE COLLECTION

(a)  NEED/AUTHORITY FOR THE COLLECTION

     Joint EPA and Customs regulations at 40 CFR 85.1501 et seq., 19 CFR
12.73,  and 19 CFR 12.74, promulgated under the authority under the
Clean Air Act (Sections 203 and 208), give authority for the collection
of the information.  The collection helps insure compliance of imported
vehicles and engines with federal emissions requirements, which helps
meet the Agency goal of reducing air pollution.  Without this
information, EPA could not confirm that imported vehicles and engines
conform to U.S. emission requirements, and consequently would not be
able to allow importation or sale of these vehicles and engines.

(b)  PRACTICAL UTILITY/USERS OF THE DATA

     CISD receives the forms, and the information on them is used by
Agency  personnel to verify that all Federal emission requirements (or
exemptions or exclusions thereto) concerning imported nonconforming
light-duty motor vehicles and motorcycles are met.  The information is
also used to identify and prosecute violators of the regulations and to
monitor the program in achieving the objectives of the regulations. It
is also used to answer public inquiries concerning the compliance or
exempted or excluded status of particular motor vehicles. Public access
to this information is not direct but rather through the Automotive
Imports Helpline in order to maintain security of information protected
under the Privacy Act. 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

(a)  NONDUPLICATION

     A search of the Government Information Locator System (GILS) found
no other program or agency collecting this information. As explained
above, Form 1 is necessary to identify, at the point of importation, the
applicable category of the vehicle or engine for regulatory purposes,
and to receive Customs acknowledgement thereof; Form 8 is necessary to
report test results to EPA (where required) and alert it of pending
release to the owner. As stated on Form 1, vehicles that are primarily
manufactured for use on public roads are also required to file an HS-7
Declaration Form to identify the basis for the vehicle’s admission
under the laws administered by the Department of Transportation. EPA had
discussions with the Department in late 2005 that considered whether a
combined form would be feasible, and the conclusion was that a single
form was not practical at this time because of the unique requirements
of each program and the different agencies administering them.  

(b)  PUBLIC NOTICE

     A Federal Register notice has been published, soliciting public
comment for this ICR on September 14, 2006 (71 FR 54280); no comments
were received.

(c)  CONSULTATIONS

     Consultations have been made with ICIs to discuss form revisions,
to update burden and cost estimates, and to receive suggestions about
the operation of the program.  The following ICIs were contacted:

Auto Enterprises, Inc.

850 N. Rochester Rd.

Clawson, MI  48017

Rep: Mr.  Philip Trupiano

Phone: (248) 723-6677

J.K. Technologies , L.L.C. 

3500 Sweet Air Street

Baltimore, MD  21211

Rep: Mr. Jonathan Weisheit

Phone: (410) 366-6332

Compliance and Research Services, Inc. 

1701 Front Street

Plainfield, NJ  07063-1066

Rep: Bob DePalma

Phone: (908) 561-1824

(d)  EFFECTS OF LESS FREQUENT COLLECTION

                 Since reporting is done only at the time of initial and
“final” entry, the effects of less frequent collection would be to
seriously undermine the Agency's ability to determine whether vehicles
being imported meet applicable emission requirements. Consequently, the
Agency would not be able to allow entry of vehicles being imported. 
Therefore, less frequent collection is not feasible.

(e)  GENERAL GUIDELINES

     This ICR requires that ICIs notify EPA when requesting final
admission for vehicles (Form 8) and this may occasionally result in
reporting more often than quarterly if vehicles are tested and ready for
sale more frequently than quarterly.  This requirement is necessary for
EPA to inspect vehicles prior to release from the ICI.  If EPA only
required quarterly reports, either the ICI would have to hold vehicles
and release them on a quarterly basis or EPA would not likely have the
opportunity to inspect or require confirmatory testing of vehicles
imported by the ICI.

     EPA's regulations require that ICIs retain records for a period of
six years from the date of entry (40 CFR 85.1507(a)).  ICIs are
responsible for the same emissions warranties that apply to original
manufacturers, generally extending to 8 years or 80,000 miles for major
emission control components.  The Clean Air Act requires that light-duty
vehicles meet federal emission standards throughout their useful lives,
which is defined by the Clean Air Act to be 10 years or 100,000 miles
(Sec. 202(d)); these requirements are implemented through the
certification process for ICIs just as they are for original
manufacturers. The imports regulations specify that the useful life
period starts from the date that the vehicle is released to the owner by
the ICI.  The six year record retention requirement is the  minimum
considered consistent with these obligations.

                                                        

(f)  CONFIDENTIALITY

      Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to policies set
forth in Title 40, Chapter 1, Part 2, Subpart B - Confidentiality of
Business Information (see CFR 2).  The public is not permitted access to
information containing personal or organizational identifiers.  This
collection complies with the Privacy Act of 1974 and OMB Circular A-130.

(g) SENSITIVE QUESTIONS

 	There are no sensitive questions.

4.  THE RESPONDENTS AND THE INFORMATION REQUESTED

(a)  RESPONDENTS/NAICS CODES

      The Light-duty Vehicle Group of CISD collects information from
individual importers and both small and large companies that import
light-duty vehicle, light-duty truck, and on-road motorcycle vehicles or
engines.  The NAICS code for respondents is 423110, Automobile and Other
Motor Vehicle Merchant Wholesalers, and 441200, Other Motor Vehicle
Dealers. 

(b)  INFORMATION REQUESTED

(i)  Data Items

     The data requested in reports include:

     - vehicle identification number

     - vehicle make

     - vehicle model

     - model year of the vehicle

     - port of entry

     - date of entry

     - entry number

     - importer name, address and telephone number

     - owner name, address, telephone number and SSN or EIN

     - emission test results

     - applicable EPA certificate of conformity

     - fuel economy

     - test date

     - modification date

     - name of emissions test laboratory

     - vehicle storage location

     - justification for an exclusion or exemption, if applicable

     and records are maintained on:

     - documents related to certification, modification, importation,
storage, registration or                     emission testing

     - bills of sale, invoices, or purchase agreements

     - documents providing parts identification data associated with the
emission control system

     - documents providing evidence of the initiation of the "hold
period"

(ii) Respondent Activities

     To complete the collection, the respondent would:

      -read form instructions

      -collect data and complete forms

      -conduct required emission testing (ICIs only)

INFORMATION REQUIREMENTS FOR 

IMPORTATION OF NONCONFORMING MOTOR VEHICLES 

AND MOTOR VEHICLE ENGINES

40 CFR PART 85 SUBPARTS P and R

INFORMATION REQUIREMENTS      				CITATION

I. ICI requirements

- Reporting

- Application for final admission   					85.1505(a)

   (certified)

- Reasonable assistance during inspection, 				85.1506(c),(g)(4)

   including copies of records or documents 				85.1506(b)(2)

- Application for final admission   					85.1509(b)

   (modification/test)

- Repair and retest							85.1509(g)

- Maintenance instructions, attestation,  				85.1510(a)

   parts list

- Altitude compensator instructions, attestation 			85.1510(b)

- Emission warranties, attestation   					85.1510(c)

- Emission labeling, attestation   					85.1510(d)

- Fuel economy labeling, attestation  					85.1510(e)

- Gas guzzler tax forms, attestation  					85.1510(f)

- Reply to notice of suspension or  					85.1513(f)(3)(ii),

   revocation      							85.1513(f)(3)(iv)

   									85.1513(f)(6)

- Request for hearing    						85.1513(f)(3)(iii)

Recordkeeping

- Certification, modification, test, purchase, 				85.1507

   sale, storage, registration, importation     

- Owners or ultimate purchasers  					85.1508(b)

- Maintenance instructions, parts list,  				85.1510

   altitude compensator instructions, 

   emission warranties, emission labeling,

   fuel economy labeling

II. Requirements applying to all importers

- Notification of conditional admission  				85.1504(a)

- Request for prior approval (exemption), 				85.1511(b),(g)

   request for extension of exemption     

- Request for prior approval (exclusion)				85.1511(c)-(g)              
                                          

- Attestations, copy of paid invoice  					85.1512(f)

- Claim of confidentiality    						85.1514

5.  THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT

(a)  AGENCY ACTIVITIES

     CISD receives the forms in paper form either directly from the
importers (Form 8) or indirectly from the importers through Customs
(Form 1).  Form 1 data is entered into the Automated Imports Tracking
System (AITS); Form 8 data is collected by the imports team and copies
distributed to certification staff; since late 2005 the data from Form 8
has also been entered into the AITS.  After receiving the information,
EPA uses it to determine whether vehicles meet EPA requirements and
whether to conduct investigations or require confirmatory testing, and
retains it in order to respond to public, State government, and Federal
government inquires.  In addition, ICIs will be included in the Verify
information system, which eventually will include EPA certification
application data for all regulated categories of vehicles and engines;
the first ICI certification applications are currently scheduled for
inclusion in the version of Verify scheduled for initial release in
August, 2007. As part of its effort to provide electronic versions of
all current paper forms, the Verify system will also include Form 8
submissions upon completion of the ICI module.  Any reductions in burden
resulting from this change will be reflected in the next renewal of this
ICR. 

(b)  COLLECTION METHODOLOGY AND MANAGEMENT

    Both Customs and CISD use the information to determine if vehicles
meet EPA requirements.  CISD retains information in the AITS and
document form in order to respond to public, State government, and
Federal government inquires, which are handled by CISD staff.

(c)  SMALL ENTITY FLEXIBILITY

     Small entities that are required to submit information to EPA have
been doing so by completing and submitting EPA paper forms.  EPA
regulations provide, as an alternative, for submission of imports data
electronically (e.g. 40 CFR 85.1505(a), 85.1509(b) & (c)). Under EPA
guidance (CCD-02-04;   HYPERLINK
"http://www.epa.gov/otaq/cert/dearmfr/dearmfr.htm" 
http://www.epa.gov/otaq/cert/dearmfr/dearmfr.htm  ) ICIs qualify per se
as small volume manufacturers entitled to the special provisions
available to all certifying small manufacturers under EPA’s
certification regulations. 

(d) COLLECTION SCHEDULE

      The information is not subject to a collection schedule, but is
collected at the time of vehicle entry and when the vehicle is ready for
final admission by EPA.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

(a) ESTIMATING RESPONDENT BURDEN (HOURS)

Motor vehicles and motor vehicle engines, and on-road motorcycles and
engines

	Hours per Activity	Number Activities	Total Hours

I. Reporting

Form 3520-1	0.5	12,000	6,000

Form 3520-8	0.5	     352	176     

Total Responses = 12,352

	II. Recordkeeping

Form 3520-8	0.5	352	176

III. Testing

Form 3520-8



	     Regular ICI	28.0	96	2,688

     Mod and Test	28.0	42	1,176

Total 

12,856	10,216



(b) ESTIMATING RESPONDENT COST

	Labor	O&M	Capital/Startup (unamortized)

I. Reporting

Form 3520-1	$201,420	$0	0

Form 3520-8	$8,749 	$1056      	     0

II. Recordkeeping

Form 3520-8	$5,908 	$704 	0

III. Testing

Form 3520-8



	     Regular ICI	$150,044 	$0	$512,000

     Mod and Test	$65,644 	$0	$224,000 

Total	$431,765	$1,780	$736,000



(i) Labor Costs

     Labor costs are considered to be more closely approximated by the
motor vehicle manufacturing industry, NAICS 336100, than retail and
wholesale trades in vehicles that do not involve testing and
modification.   Rates for engineering managers, mechanical engineers,
and secretaries (except legal, medical, and executive) are from the May
2005 BLS National Industry-Specific Occupational Employment and Wage
Estimates (  HYPERLINK
"http://www.bls.gov/oes/current/naics4_336100.htm" 
http://www.bls.gov/oes/current/naics4_336100.htm  , accessed August 22,
2006). With a 160% overhead multiplier, these are $81,38, $49.71, and
$33.57, respectively. Most ICI certification representatives who fill
out Form 8s are motor vehicle technicians; Form 1 labor burdens are
considered secretarial. Test labor costs are $55.82 per hour based on
ICR 0783.47. 

(ii) Capital/Start-up Costs 

     Consistent with ICR 0783, a capital cost of $4,000,000 for a test
facility capable of conducting 750 FTP and highway tests per year has
been allocated on a per-test basis. For ICIs, these test facility costs
will in most cases be covered by contractual costs between the importer
and a testing laboratory. As mentioned above, these costs listed here
are not initial certification costs but the post-certification test
costs for additional imported vehicles. As with other ICRs, these
capital costs are annualized and subject to 7% interest depreciation but
are considered to be on-going rather than startup capital costs in the
sense that as facilities are depreciated they are continually being
replaced. 

(iii) Operations and Maintenance Costs 

     Operations and maintenance costs were calculated based on responses
received from the ICIs contacted.  The Operations and Maintenance cost
for reporting ordinarily involves a purchase of services from brokers
who complete a package of importation forms (including those of other
agencies) and file them with Customs and EPA.  This cost is estimated as
a component of overall broker activities to import a vehicle or engine,
and incorporates a $2 per form recordkeeping cost for broker form
retention within overall broker activities, a $3 per form mailing cost
for Form 8s, and a total of $1 per form for Form 1.  O&M costs
associated with testing are negligible compared with those for
certification vehicles; post-certification vehicles do not have mileage
accumulation or durability demonstration requirements or consequent
vehicle depreciation; vehicle preparation is minimal.  Costs associated
with modification of vehicles necessary to bring them up to
certification standards are excluded: they are not reported on the
imports forms, they vary widely depending on the vehicle being imported,
and they therefore can not be predicted or accounted from one year to
another; finally, they are analogous to, for example, the costs of
catalytic converters and other emissions control technologies that
original manufacturers are required to install in vehicles in order to
comply with the Clean Air Act, and which are not included in the
certification paperwork burden. 

(c) ESTIMATING AGENCY BURDEN AND COST

     The imports program is administered by EPA's Compliance and
Innovative Strategies Division (CISD). Forty percent of one Full Time
Equivalent employee (FTE), GS 12/3;  twenty percent of one Senior
Environmental Employment (SEE) Program employee (the SEE Program is an
employment program for older workers authorized by the Environmental 
Programs assistance Act, passed by Congress in l984, and provides
employment opportunities to senior citizens age 55 and over); and a
portion of the work assignment under a government contract  are
allocated to imports activities.  Based on the 2006 GS pay schedule, EPA
estimates an hourly $34.35 for the FTE, then multiplies the hourly rates
by the standard government benefits multiplication factor of 1.6, at a
cost of $45,728, and a cost of  $8,480 for the SEE;  $179,450 is
estimated for the contractor.  The contractor estimate is based upon the
work assignment rather than an estimate of hours. An estimated total
agency cost of $233,657 per year is therefore allocated to imports
activities.  These activities include both on-road imports (this ICR)
and nonroad imports (ICR 1723; OMB 2060-0320). An estimated 90% of these
activities currently involve on-road imports; consequently, $210,292 is
the estimate for the agency cost for purposes of this ICR. 

(d) Estimating the Respondent Universe and Total Burden and Costs

	We estimate 12,000 Form 1s are submitted, based on an extrapolation of
entries in the AITS (not all have yet been entered), averaging one
respondent per form, and 352 Form 8s from five ICIs, based on a hand
count of Form 8s received in 2005 and 2006, plus an estimate based on
actual and projected imports from one high-volume importer covering four
original production years. The total number of responses is therefore
estimated as 12,352. The estimated number of respondents is 12,005. For
each engine family, one imported vehicle is used for certification
testing; therefore, while the forms count does not decrease, the testing
responses is decreased by the number of import engine families. For
model year 2005, 21 ICI engine families were certified; the count of 300
regular ICIs was reduced by 11 to total 289 vehicles subject to
post-certification testing; every third vehicle results in an estimate
of  96 tests; the total of 52 mod & test vehicles was reduced by 10
certification vehicles; the remaining 42 are subject to tests. 

(e) Bottom Line Burden Hours and Cost

(i) Respondent Tally

Respondents					                12,005	

Responses						    12,352				

Burden Hours						    10,216

Labor Cost						$431,765

Operating Cost					    $1,780

Capital Cost						$736,000

Capital Cost (Annualized)				$104,790

Total (Annualized)					$538,335

(ii) Agency Tally

Employees						             2

Employee Labor Cost					  $48,787

Contract Labor Cost					$161,505

Total Cost						$210,292

6(f) Reasons For Change In Burden

     This ICR follows the burden hours assumptions of the previous
renewal for filling out the forms themselves, but has a substantial
change in other and overall hours and burdens due to the following: 
First, the labor burden of recordkeeping has been adjusted.  These
replace an O&M cost per form in the prior estimate. Second, the number
of Form 8s has been increased from 200 to 352. The number of Form 1s has
been reduced from 20,000 to 12,000 based on a better estimate due to the
availability of a logged database. (The prior renewal listed 13,000
respondents filing 11,200 responses.) Third, the testing cost is
modified to distinguish the different testing requirements for the two
different classes of ICIs.  Fourth, an O&M and a capital cost are
assigned to the testing requirement, consistent with other certification
ICRs, namely the 0783 series. Fifth, this testing O&M cost replaces a
$660,000 O&M expense that was in the prior renewal. That cost was
unelaborated but probably included an estimate of modification costs,
which are excluded here for the reasons stated above.  

6(e) BURDEN STATEMENT

     Public reporting burden for this collection is estimated to average
49 minutes 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-2006-0740, which is available for online
viewing at   HYPERLINK "http://www.regulations.gov"  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,
Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include
the EPA Docket ID Number EPA-HQ-OAR-2006-0740 and OMB Control Number
2060-0095 in any correspondence.     

 PAGE   

 PAGE   13 

