DRAFT

Supporting Statement

for

Information Collection Request

EPA(s In-Use Vehicle and Engine Testing Programs

EPA ICR 0222.08

OMB Control No: 2060-0086

March 2007

Compliance and Innovative Strategies Division 

Office of Transportation and Air Quality 

Office of Air and Radiation 

U.S. Environmental Protection Agency

Part A SUBMISSION

Section 1: Identification of the Information Collection

1(a) Title and Number of the Information Collection

	EPA’s In-Use Vehicle and Engine Testing Programs, EPA ICR Number
0222.08, OMB Control Number 2060-0086.   This collection was previously
titled “Investigation into Possible Noncompliance of Motor
Vehicles.” 

1(b) Short Characterization/Abstract 

	The Environmental Protection Agency (EPA), Office of Transportation and
Air Quality(s Compliance and Innovative Strategies Division conducts an
integrated motor vehicle and engine emission compliance program.  Motor
vehicles and engines are first evaluated as prototypes prior to
production; those designs that meet applicable criteria are licensed for
introduction into commerce.  EPA also has discretion to conduct assembly
line testing of new vehicles and engines as well as to test emissions of
in-use vehicles and engines.  This Information Collection Request covers
inquiries directed at the owners/lessees of in-use motor vehicles and
engines to see if their specific vehicles are suitable for an EPA in-use
testing investigation and the paperwork burdens attendant upon election
to participate. The program has a light-duty vehicle component and a
heavy-duty and nonroad component. 

	The light-duty component can be broken down into three closely-related
headings. The first is the surveillance testing programs that have been
discussed in detail in prior information collection requests, with the
possibility of an add-on compliance testing phase. Only one compliance
phase testing has been conducted in the last five years, but it remains
an information collection in this request. The second is a small ongoing
program testing the functioning of onboard diagnostics (OBD) systems on
in-use vehicles, which is simply additional testing on a subset of
vehicles already recruited for the surveillance program. Finally, budget
permitting, there are other occasional one-time “special
investigations” spot-check tests of vehicles to address specific
issues. An example of a special investigation might be procurement of a
class of vehicles to test compatibility with a particular portable
emissions monitoring (PEM) unit. Special investigations are similar to
testing of that portion of surveillance classes that have been selected
to address a specific informational need.  Because they use the same
procurement system as the surveillance and OBD programs, they deserve to
be accounted for in this collection request, although the number of such
tests will vary. Light-duty testing typically includes standard
emissions test cycles and standard OBD tests performed at EPA’s
facility in Ann Arbor. The primary purpose of these programs is
informational: to give EPA and manufacturer engineers intelligence
regarding emissions performance for in-use vehicles. Manufacturers are
involved at every step of the ongoing light-duty programs: they are
informed of the surveillance tests, can be present during vehicle
preparation and testing, are given test results, and participate in
post-failure investigations. The testing supplements information from
the manufacturers’ own in-use testing programs as well as the
mandatory reporting under the manufacturers’ In-Use Vehicle Program
(IUVP) under 40 CFR 1845 – 1847. 

	The light-duty programs entail two formalized information collections.
Participation in the information collections, as well as the vehicle
evaluation, is strictly voluntary. (The actual solicitation of
information is conducted by EPA(s contractor, EG&G, at its Michigan
Procurement Facility (MPF)).  First, 25 to 50 owners/lessees are
randomly selected from the owner list of vehicles obtained from the
Michigan Secretary of State within about 60 miles of Ann Arbor and sent
a postcard soliciting participation.  After a suitable time for
response, all positive respondents are considered for inclusion, and
called in order from the list. If the owner/lessee is reached and
willing, a telephone questionnaire is conducted that asks about a half
dozen questions concerning vehicle condition and maintenance (see
Attachment V). The first three who complete the telephone questionnaire
provide the vehicles for the surveillance class. If there are any test
failures in the first three, then two more are recruited in the same
manner. Additional groups of potential participants will be contacted if
necessary until the necessary three to five vehicles has been obtained.

	Information collected is used to insure that vehicles procured meet
relevant criteria.  For example, the vehicle should not have been
tampered with or have other overt problems.  Other testing
investigations and vehicle types may have different criteria. 

	Those who elect to participate are asked if they are willing to bring
in their maintenance records for copying when they deliver their
vehicles. Doing so is voluntary and has no effect on eligibility. At the
time of delivery, participants go over the telephone questionnaire
answers and sign a notarized statement that the answers are correct.
They sign either E G & G’s cash incentive or a loaner car agreement,
and an E G & G test agreement. Upon picking up their vehicle, they sign
a vehicle release.

	As part of the surveillance process, EPA attempts to determine the
cause of any test failures. Post-test “special maintenance” involves
close examination of the vehicle, nearly always with manufacturer
participation. This will most often produce relevant information about
the cause of the failure. Surveillance test data are also supplemented
with information from defect reports, service bulletins, CARB 
(California Air Resources Board) warranty reports,
Inspection/Maintenance (I/M) information, service technician bulletins,
and the results of the manufacturers’ IUVP. Manufacturers/importers
are involved in the process from the outset, and receive all test
results, including test failures. The process of identifying problems is
collaborative and cooperative in the large majority of cases.  If EPA
believes that a recall is indicated, and the manufacturer/importer
agrees that EPA's conclusion is valid, it will agree to conduct a
voluntary recall.  However, if questions remain, EPA has procedures in
place to run a compliance test phase with continued manufacturer
involvement. Even at this stage the inferences are informational rather
than statistical, to identify based on engineering judgment the
appropriate population to which the problem applies, identify the cause
of the problem, resolve issues regarding the testing protocols and
results, etc. The process has not been adversarial in recent years.
There has only been one compliance class in the last five years, and
that was amicably resolved without any recall (manufacturer and EPA
in-use test results compared and found acceptable).  

	Based on information gathered from all sources, EPA can make an
administrative finding mandating recall and repair of in-use vehicles if
it determines that “a substantial number” of vehicles in a class or
category do not comply with the emissions requirements as a result of
its own in-use testing program. In reality, such a determination will be
based on information from a variety of sources in addition to EPA in-use
testing. Such findings are subject to the Administrative Procedures Act
and are reviewable in court under the “substantial evidence” test (5
USC 706(2)(E)), which mirrors the “substantial evidence” standard in
the Clean Air Act for ordering recalls. 

	Procurement of light duty vehicles for a compliance testing phase is
similar, except that EPA may make several attempts to contact an
owner/lessee by telephone or mail; participants in the surveillance
phase are screened out.

	The heavy-duty and nonroad in-use testing component is quite similar to
the light-duty component. It likewise supplements the authority for
confirmatory testing during the certification process and for production
line audits as part of a comprehensive compliance strategy. In this
case, the in-use testing authority bears a heavier burden within the
overall compliance strategy than it does in the light-duty program
because little if any production-line or confirmatory testing currently
occurs. The program also differs considerably in its procurement and
testing procedures. 

	Heavy duty trucks, those commonly referred to as over 3/4 ton capacity,
are usually parts of fleets leased to businesses, held by the leasing
companies themselves, or government owned. Potential fleet
owners/lessees can be found in registrations lists; engine manufacturers
will also supply identities of their customers.  In addition, EPA’s
heavy-duty and nonroad staff in Washington, D.C., have a network of such
entities who have shown a willingness to participate over the years.
Once a potential source is identified, EPA will make a brief telephone
call to the fleet manager to ascertain if they wish to participate.  If
the response is positive, EPA’s contractors at the U.S. Army Aberdeen
Test Center in Maryland will frequently visit the fleet to install the
testing instruments at the company’s service facility or government
garage. (EPA also has the capability of conducting some in-use testing
in Denver, Colorado.)  Otherwise, the lessee will be within driving
distance of the testing grounds and the devices will be installed there.
A single fleet can supply multiple vehicles. All participation is
voluntary.  The procedure for procuring nonroad vehicles and engines
(e.g., farm tractors, compressors) is similar; in some cases the vehicle
or engine may be rented for the day. Therefore, EPA’s heavy duty and
nonroad in-use testing program makes far fewer inquires than with
individual owners of light vehicles.

	The heavy-duty and nonroad vehicle and engine in-use testing is done
via the installation of “Rover” model portable emissions monitoring
devices. If the devices are installed at the fleet location, typically
the fleet’s drivers will operate the installed trucks; if the tests
are conducted at Aberdeen, there are standard test routes. A typical
data session will last an hour to an hour and a half. The driving
conditions and information gathered may vary depending on the issues
relevant to the in-use class selected. 

	In the last fiscal year an estimated 311 vehicles and engines were
in-use tested by EPA. Adding an allowance for about 25 special
investigation vehicles (the number varies considerably from year to
year) and the possibility of a compliance class, the estimate here is
336 procured vehicles and engines, corresponding to 4,411 contacts and
290 telephone interview and/or other followup participant contacts.
Assuming that 4,411 respondents spend an average of 8.94 minutes, this
collection imposes a burden of 658 hours annually.  This collection has
no recordkeeping requirements.  

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.),
manufacturers of motor vehicles and engines are required to design and
build vehicles which will comply with emission standards throughout
their useful lives.  ((Useful life( is defined by statute and
regulation; it varies by type of vehicle or engine.)  Pursuant to
section Clean Air Act section 207(c) (42 USC 7541, see Attachment I), 
EPA is responsible for monitoring compliance and investigating possible
noncompliance with  emission standards.  



	In order to fulfill this function, it is necessary for EPA to test
actual (in-use( vehicles; these vehicles must be obtained from their
owners/lessees.  As part of the procurement process, EPA must determine
that the vehicle is within the useful life and that it has been
(properly maintained and used(.  In order to do this, EPA must make a
limited inquiry of the owner/lessees who are willing to participate; see
Attachment V for an example telephone questionnaire. 

2(b) Practical Utility/Users of the Data

	EPA needs the information from the vehicle owner/lessee to determine
that the vehicle is within its (useful life( and that it has been
(properly maintained and used.(  EPA(s Compliance and Innovative
Strategies Division, Office of Transportation and Air Quality, is the
sole user of this information. Manufacturers are informed of pre-test
maintenance and test dates and receive all test results from the
light-duty programs. They also participate in post-test “special
maintenance” to investigate failures.

Section 3:  Nonduplication, Consultations, and Other Collection Criteria

 

3(a)Nonduplication

	The information obtained from the vehicle owner/lessee is unique to
that specific vehicle or engine; it is not obtainable from any other
source. There is no information  available, in either public or private
databases, that will adequately serve the program purposes. (Some
vehicle maintenance information, such as warranty repairs and scheduled
maintenance done at dealers’ outlets, is available from manufacturers
and commercial automotive data services, and such information may be
supplied by manufacturers in their own interests or as queried by EPA.
However, it is not a substitute for owners’/lessees’ own records.)
Additionally, there are no other similar government programs which would
allow sharing of data. 

3(b) Public Notice Prior to ICR Submission to OMB

	EPA  solicited public comment by means of a Federal Register Notice
published on xx April,  2007, xx Federal Register xxxx.  No comments
were received.

3(c) Consultations

	In preparing this ICR, EPA consulted with Ms. Kim Cieslak, E G & G
Michigan Procurement Facility,  (734) 214-4568.   ( E G & G is EPA(s
contractor that procures and maintains in-use passenger cars and light
duty trucks.)   Ms. Cieslak mails out the procurement letters and
conducts the telephone interviews; she was asked to monitor how much
time the interviews required.  She determined the average to be 20
minutes. 

3(d) Effects of Less Frequent Collection

	Information is collected only once per vehicle evaluation; less
frequent collection is not possible.

 

3 (e) General Guidelines

	This information collection activity complies with the requirements of
5 CFR 1320.5(d)(2).

3 (f) Confidentiality

 	Information gathered from respondents is stored in contractor files.
These paper records, including names and social security numbers needed
for those who accept payment in lieu of loaner cars in the light-duty
program, are completely segregated from test results, which are
separately handled and stored by EPA. Respondent information is handled
and stored exclusively by the contractors E G & G.  It is not available
to the public. Non-personal information (such as maintenance record
data) may occasionally be queried by EPA staff, who convey the request
to E G & G, who in turn retrieve the information from respondent files
and answer the EPA query.  Test results are tracked by VIN number and
are shared with manufacturers by email automatically; and are available
to the public. This information collection complies with the Privacy Act
of 1974 and OMB Circular A-130.   

 

3(g) Sensitive Questions

	No sensitive questions are asked in this information collection.

Section 4. Respondents and Information Requested

4(a) Respondents/SIC & NAICS Codes

	The respondents are individual vehicle owners/lessees of any regulated
vehicle or engine regulated by EPA under the Clean Air Act (No NAICS
code) as well as members of the trucking industry (NAICS 484110, 484121
& 484122.)

4(b) Information Requested

(i) Data items

	Respondents who receive EPA(s initial request (see Attachments II and
III and IV) are asked to supply  the following information on a card via
a postage paid return envelope; participation is entirely voluntary:

Do they own/lease the desired vehicle; verify the make and model

Current odometer reading

Are they the original owner/lessee

Transmission type

Are they interested in participating; how EPA should contact them.

	Those who indicate they wish to be considered for participation are
asked for additional information:

Has the odometer malfunctioned and, if so, for how long was it
inoperative

Has the vehicle catalyst ever been replaced

Do they have maintenance records; would they allow EPA to review and
copy them 

	There are no recordkeeping requirements associated with this
collection.

(ii) Respondent Activities

	Responses to the request for participation and information collection
are strictly voluntary.

	Those wishing to participate are asked to fill out a postage-paid
information card.  They are then contacted by telephone to obtain the
additional information listed above.  Vehicles which will be evaluated
are brought to EPA(s facility for testing. For the light-duty programs,
the owners/lessees receive either a cash incentive for each day EPA
keeps the vehicle or a late model loaner car with a full tank of gas and
unlimited mileage for the duration of the testing, which may take two to
three weeks. 

	Most of the information requested is known by the owner/lessee; some
information might have to be obtained by simple vehicle or engine
inspection or by reference to maintenance records (if available).

Section 5: The Information Collected--Agency Activities, Collection
Methodology, and Information Management

5(a) Agency Activities

	Agency staff typically have no involvement in gathering the
information, as that task is done by an EPA contractor.   However, on
occasion, staff are required to answer specific questions that arise
during the information gathering process. Agency staff do review the
final telephone questionnaire for completeness as well as potential
issues relevant to the vehicle being evaluated. Agency staff select the
vehicle class to be tested, view test results, and participate in
discussions with manufacturers relating to the testing preparations and
results. 

5(b) Collection Methodology and Management

	Information is obtained via mailed responses and telephone interviews;
it is stored on paper in a vehicle file.  The information is reviewed to
see if the specific vehicle or engine meets the criteria for evaluation.
 The file is typically maintained for five years and then destroyed

	Due to the limited amount of information collected and its very limited
use, electronic storage and processing are not employed.

5(c) Small Entity Flexibility

	The information requested is completely voluntary and imposes no
mandatory burden on any respondent. The information collected is the
minimum necessary to assure that vehicles meet the criteria for
evaluation.  Therefore, there can be no process which reduces the burden
on small entities.

5(d) Collection Schedule

	Information is collected on a continuous basis.  The number of
solicitations mailed out in a given time frame is a function of
available test capacity and how difficult a particular vehicle type is
to procure. 

Section 6.Estimating the Burden and Cost of the Collection

6(a) Estimating Respondent Burden

As explained above, EPA(s contractor estimated that each telephone
interview takes approximately 20 minutes on average.  Subsequent
information-related burdens for participants (such as reviewing and
attesting to the telephone questionnaire answers and supplying
maintenance records voluntarily) upon delivery of light-duty vehicles,
is estimated at 40 minutes. We estimate that the initial contact burden
(by postcard and letter) to averages 5 minutes. We estimate paperwork
burdens for heavy-duty and nonroad testing to be 60 minutes per contact.

6(b) Estimating Respondent Costs

(i) Estimating labor costs.

The is no typical individual owner/lessee; they represent the average
person who acquires or owns a vehicle or engine.  The average respondent
from a firm using commercial vehicles would be classified as (manager(
with a total cost of $75.00/hour. (Estimated from the US Department of
Labor, Bureau of Labor Statistics 2001 National Occupational Employment
and Wage Estimates, 11-1021 General and Operations Manager at $35.37
with 110% assumed for benefits and overhead. )  Since EPA has no
information on the population of individual owners/lessees (that
information is not collected) the (manager( class will be used here as
well.  The labor total is thus $49,320 a year. 

 

(ii) Estimating Capital and Operations and Maintenance Costs

This collection has no capital, operations or maintenance costs.

(iii) Start-up Costs 

This collection has no start-up costs.

6(c) Estimating Agency Burden

	EPA uses contractor employees to collect essentially all the
information covered by this information collection request. The most
recent annual cost contractor costs for the light duty testing programs
was approximately $697,000 plus $70,000 for the OBD portion. For the
heavy-duty and nonroad portion, the most recent contract cost was
$661,000. An estimated 1.5 EPA employees oversee the programs at an
annual cost of $150,000. The total estimated Agency cost is $1,578,000
per year.

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 as presented below.

6(e) Bottom Line Burden Hours and Cost

(i) Respondent Tally

Program	Vehicles/Engines	Initial Contacts    	Burden @ 5 min ea.(min)
Participa-nt Contacts	Burden @ 60 min ea (min)

LD Surveillance	150	3673	18365	150	9000

LD Confirmatory	0	0	0	0	0

OBD Surveillance	35	0	0	0	0

Special	25	612	3061	14	840

HDV	54	54	270	54	3240

Non-road	72	72	360	72	4320

Total	336	4411	22056	290	17400

Total burden (hrs)



	658



There are no respondent operating, capital, or startup costs associated
with this collection. 

 

(ii) Agency tally

EMPLOYEES 	1.5 (directly involved in information collection) 

COST    		$ 150,000

6(f) Reasons for change in burden

The changes in burden  are due to an updated and more particularized and
accurate estimate of EPA’s ongoing and anticipated in-use testing
numbers and the numbers of solicitations mailed. Burdens have been
re-estimated for, and allocated among, initial solicitations for
participation and subsequent information burdens attendant upon
participation. 

6(g) Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average approximately 658
hours per year; 8.94 minutes on average for each owner/lessee who
receives a solicitation to participate.   This estimate includes the
time to review the solicitation material, complete the reply
correspondence, complete the telephone questionnaire, and complete
paperwork for delivery and pickup of participating vehicles and engines.
 Participation is completely voluntary. 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 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 regulation 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 No.
OAR-2007-0286, 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 Ave., NW, Washington,
DC.  The EPA Docket Center Public Reading Room is open from 8:30 a.m. to
4:30 p.m., Monday through Friday, excluding legal holidays.  The
telephone number for the Reading Room is (202) 566-1744, and the
telephone number for the Air and Radiation Docket and Information Center
is (202) 566-1742.  An electronic version of the public docket is
available through EPA Dockets (EDOCKET) at http://www.epa.gov/edocket. 
Use EDOCKET to submit or view public comments, access the index listing
of the contents of the public docket, and to access those documents in
the public docket that are available electronically.  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, DC 20503, Attention: Desk Office for EPA.  Please
include the EPA Docket ID No. (OAR-2007-0286) and OMB control number
(2060-0086) in any correspondence.

	Attachment I

 	Legal Authority

42 USC 7541. - Compliance by vehicles and engines in actual use 

*   *   *   *   *

(c) Nonconforming vehicles; plan for remedying nonconformity;
instructions for

   maintenance and use; label or tag 

Effective with respect to vehicles and engines manufactured during model
years beginning more than 60 days after December 31, 1970 - 

(1) If the Administrator determines that a substantial number of any
class or category of vehicles or engines, although properly maintained
and used, do not conform to the regulations prescribed under section
7521 of this title, when in actual use throughout their useful life (as
determined under section 7521(d) of this title), he shall immediately
notify the manufacturer thereof of such nonconformity, and he shall
require the manufacturer to submit a plan for remedying the
nonconformity of the vehicles or engines with respect to which such
notification is given. The plan shall provide that the nonconformity of
any such vehicles or engines which are properly used and maintained will
be remedied at the expense of the manufacturer. If the manufacturer
disagrees with such determination of nonconformity and so advises the
Administrator, the        Administrator shall afford the manufacturer
and other interested persons an opportunity to present their views and
evidence in support thereof at a public hearing. Unless, as a result of
such hearing the Administrator withdraws such determination of
nonconformity, he shall, within 60 days after the completion of such
hearing, order the manufacturer to provide prompt notification of such
nonconformity in accordance with paragraph (2). 

*   *   *   *   *

	Attachment II

	Sample Solicitation Letter (EPA)

Dear Vehicle Owner:

The Environmental Protection Agency and EG&G Inc. (under contract to
EPA) are conducting an important program to help control air pollution,
which involves analyzing vehicle exhaust emissions.  You may be able to
contribute significantly toward this program and be rewarded for your
cooperation.  If your vehicle qualifies, we will offer you a number of
incentives to participate:

 

The use of a late-model, fully insured loaner car with a full tank of
fuel, and $20.00 per day.

2.	If you do not wish to use the loaner vehicle, you will receive $50.00
per day.

Your vehicle will be returned with a full tank of fuel.	

The testing will be conducted in EPA's National Vehicle and Fuel
Emissions Laboratory (formerly known as the Motor Vehicle Emissions
Laboratory) in Ann Arbor.  Your vehicle will probably accumulate less
than 300 miles under simulated driving conditions.  No unusual
operations will be performed on your vehicle and it will be fully
insured for the entire test period, which will take approximately two to
three weeks.

Please complete and return the enclosed reply card in the prepaid
envelope to EG&G Inc. as soon as possible, even if you choose not to
participate.  If you are willing to participate, a representative of
EG&G will be in touch with you to ask questions about your vehicle.

The enclosed information sheet answers some questions people often ask
about this program.  If you have any additional questions, please feel
free to call EG&G Inc. at (734) 665-1227 or me, Sue Cook, at (734)
214-4200.  We will be happy to answer any questions you may have.  We
look forward to receiving your reply card or a telephone call very soon.

Sincerely,

 Sue Cook

	Attachment III

	Sample Solicitation Letter (EPA( Contractor)

Dear Vehicle Owner:

EG&G Inc. is under contract with the United States Environmental
Protection Agency to obtain privately owned vehicles for the test
program explained in the enclosed message and to perform routine
maintenance and inspection procedures on the selected candidate
vehicles.

Additionally, it is our responsibility to provide you with the
incentives which have been authorized by the Environmental Protection
Agency.

We hope you will join us in this important project.  Please complete and
return the enclosed card in the prepaid envelope.

If you have any questions, an unlisted telephone number, or if it may be
difficult to reach you by telephone, we would appreciate your calling us
at (734) 665-1227.

Sincerely,

John H. White

Program Manager

Attachment IV

	Example Return Card

	Attachment V

	Example Telephone Questionnaire

	TELEPHONE QUESTIONNAIRE          	OMB No. 2060-0086

                                                 For Surveillance CLASS
G138/139   	(Expires (09/30/07)

                                                   	            2000
MITSUBISHI LDV

VEHICLE CONTROL NUMBER                                              DATE
                                                                 

ADMINISTERED BY                                                         
                                                                        
         

OWNER'S NAME                                                            
                                                                        
            

STREET ADDRESS                                                          
                                                                        
          

CITY                                                                    
                                                                        
                        

STATE                                        ZIP                        
     

(CALL NUMBER BELOW THAT IS MARKED WITH AN "X")

TELEPHONE (Home)  /           /                                         
    (Business)   /          /                                           
     

BEST TIME TO CALL                                                       
   

"WE ARE AUTHORIZED BY FEDERAL LAW TO COLLECT THIS INFORMATION.  WHILE
YOU ARE NOT REQUIRED TO RESPOND, YOUR COOPERATION IS NEEDED TO MAKE THE
RESULTS OF THIS INVESTIGATION VALID."

DATE OF CONTACT _______________________ TIME OF CONTACT 
__________________

INDIVIDUAL
CONTACTED_______________________________________________________

TO BE COMPLETED ___________________ DATE AND TIME OF 
COMPLETION___________

You have been selected from a list of vehicle owners living in the
Detroit/Ann Ann Arbor metropolitan area to participate in a study of
vehicle emissions being conducted by the U.S. Environmental Protection
Agency.

EPA is authorized by law to conduct this study and to offer incentives
to you for your cooperation should you decide to participate.  Your
participation in this program is strictly voluntary.

The accuracy of the information that you provide is important.  The
information that you provide will be used by EPA along with emission
results for your vehicle to determine whether the automobile
manufacturer has complied with clean air standards established by
Congress.  The test results from your vehicle will not be used by EPA to
take action against you.  Your cooperation will help EPA's efforts to
control air pollution due to motor vehicle emissions.

The public reporting and recordkeeping burden for this collection of
information is estimated to average 20 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.  

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 No.
OAR-2003-0011, which is available for public viewing at the Air and
Radiation Docket in the EPA Docket Center (EPA/DC), EPA West, Room B102,
1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public
Reading Room  is open from 8:30 a.m. to 4:30 p.m., Monday through
Friday, excluding legal holidays.  The telephone number for the Reading
Room is (202) 566-1744, and the telephone number for the Air and
Radiation Docket is (202) 566-1742.  An electronic version of the public
docket is available through EPA Dockets (EDOCKET) at
http://www.epa.gov/edocket.  Use EDOCKET to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  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, DC 20503, Attention: Desk
Office for EPA.  Please include the EPA Docket ID No.  (OAR-2003-0011)
and OMB control number (2060-0086) in any correspondence. 

These are the conditions of the program:

- we ask that you bring your vehicle into our testing facility where you
will receive either a cash incentive for each day we keep your vehicle
or a late model loaner car which will have a full tank of gas and
unlimited mileage.  This vehicle is yours to use without charge for the
duration of the testing, which may take approximately 2 to 3 weeks. 
During this time, we will be performing a series of tests on your
vehicle to measure vehicle emissions.

At the time the vehicle is delivered to us for testing, you will be
required to sign an affidavit stating that the answers to the questions
you will be asked are true and accurate to the best of your knowledge.

We will provide you the following incentives for participating in our
program:

- If your vehicle is accepted into he program, a full tank of gas and a
cash incentive will be awarded. You will be receive $20 per day for each
day your vehicle is at NVFEL, and the use of a fully-insured loan car;
or $50 per day for every day your vehicle is at NVFEL in lieu of a loan
car.

However, if your vehicle is rejected after you bring it to the lab, but
before you leave, you will receive a $20 payment.

The compensation will be based upon whole days, beginning with the day
your vehicle arrives.  It will end one day after you are notified your
vehicle is ready for return.

The maintenance performed on your vehicle will depend on program
requirements. 

You will be given a list of any parts that are replaced.

Are you willing to participate?  YES /  /      NO /  /

If you are not, may we ask why not?                                     
                                                        

                                                                        
                                                                        
    

                                                                        
                                                                        
    

IF RESPONSE IS POSITIVE:

For the purpose of this study, I am going to ask you some questions
about your vehicle's maintenance and usage history.  You should answer
these questions to the best of your knowledge and indicate when you are
not sure of something.



FOR (MPF PERSONNEL( ONLY

SENTENCES IN CAPITAL LETTERS ARE INSTRUCTIONS TO THE CLERK

AND ARE NOT INTENDED TO BE READ TO THE OWNER.

1.  a. What are the model year, transmission type, vehicle
identification number and engine family of your vehicle?  The engine
family can be found on a Vehicle Emission Control Information decal
located underside of the hood.

The engine family should start with the letters Y D S 

/  /  Owner is unable to locate.

/  /  Owner located.  ENGINE FAMILY _____________________               
                              

/  /  Engine family located when vehicle arrived at the Lab.

ENGINE FAMILY                                               

Engine Family must be = YDSXV02.4GNG or GFG

b. MODEL ________________________ VEHICLE ID NO._______________________

MODEL YEAR ___________________ 

TRANSMISSION: 	AUTOMATIC / / 	AIR CONDITIONED: YES / /  NO / /	

MANUAL    / /	ODOMETER MILEAGE:_________________

FOR CLASS G138 PROCURE TWO VEHICLES WITH ODOMETER MILEAGE BETWEEN 0 AND
50,000 MILES.  FOR CLASS G139, PLEASE PROCURE ONE VEHICLE WITH ODOMETER
MILEAGE BETWEEN 50,001 AND 75,000 MILES, IF POSSIBLE.

  c. Has the odometer ever not functioned properly?

YES /  /        NO /  /

If yes, approximately how long (months/miles) was it inoperable? 
________________                                                      

CONSULT EPA FOR ELIGIBILITY IF THE RESPONSE IS "YES"

  d. Has the oxygen-sensor ever been replaced ?  

YES / / 		NO / /

CONSULT WITH EPA IF THE RESPONSE IS YES.

2. Has your vehicle(s catalyst ever been replaced?

YES /  /        NO /  / 

If yes, eliminate.

3. Have you kept records of the maintenance and repairs performed on
your vehicle?

YES /  /      NO /  /

4. Would you allow them to be reviewed and duplicated?

YES /  /      NO /  /

     IF RECORDS ARE AVAILABLE, INFORM OWNER THAT: It is important that
they are brought to the lab for review.  DUPLICATE THE RECORDS.         
                                                                    

      

      INFORM THE OWNER THAT:  All valuables should be removed from the
vehicle (including those in the glove box) prior to bringing the vehicle
to the lab.

      

      ALSO INFORM THE OWNER THAT: Due to the location of some systems,
the glove box and trunk may need to be opened during maintenance by MPF
and EPA personnel.  Any records pertaining to the vehicle's maintenance
history found in the vehicle may need to be copied.

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