PART A OF THE SUPPORTING STATEMENT

Determine Percentage of High Evaporative Emissions

 Vehicles in the On-Road Fleet 

OMB Control Number 2060-NEW

EPA ICR Number 2292.01Table of Contents

  TOC \o "3-4" \h \z \t "Heading 1,1,Heading 2,2"    HYPERLINK \l
"_Toc197255455"  1.0	IDENTIFICATION OF THE INFORMATION COLLECTION	 
PAGEREF _Toc197255455 \h  1  

	  HYPERLINK \l "_Toc197255456"  1(a)	Title of the Information
Collection	  PAGEREF _Toc197255456 \h  1  

	  HYPERLINK \l "_Toc197255457"  1(b) Short Characterization/Abstract	 
PAGEREF _Toc197255457 \h  1  

  HYPERLINK \l "_Toc197255458"  2.0	NEED FOR AND USE OF THE COLLECTION	 
PAGEREF _Toc197255458 \h  2  

	  HYPERLINK \l "_Toc197255459"  2(a) Need/Authority for the Collection	
 PAGEREF _Toc197255459 \h  2  

		  HYPERLINK \l "_Toc197255460"  2(a)(1) Need for Emissions Inventories
for Light-Duty Vehicles	  PAGEREF _Toc197255460 \h  2  

			  HYPERLINK \l "_Toc197255461"  2(a)(1)(1) Inventory Models Supported
by EPA	  PAGEREF _Toc197255461 \h  2  

			  HYPERLINK \l "_Toc197255462"  2(a)(1)(2) Uses of Emissions
Inventories	  PAGEREF _Toc197255462 \h  3  

			  HYPERLINK \l "_Toc197255463"  2(a)(1)(3) National Ambient Air
Quality Standards.	  PAGEREF _Toc197255463 \h  3  

		  HYPERLINK \l "_Toc197255464"  2(a)(2) The National Academy Report on
Emissions Inventory Modeling	  PAGEREF _Toc197255464 \h  4  

		  HYPERLINK \l "_Toc197255465"  2(a)(3) Legislative Basis	  PAGEREF
_Toc197255465 \h  4  

	  HYPERLINK \l "_Toc197255466"  2(b) Practical Utility/Users of the
Data	  PAGEREF _Toc197255466 \h  4  

  HYPERLINK \l "_Toc197255467"  3.0	NONDUPLICATION, CONSULTATIONS, AND
OTHER COLLECTION 

CRITERIA		  PAGEREF _Toc197255467 \h  5  

	  HYPERLINK \l "_Toc197255468"  3(a) Nonduplication	  PAGEREF
_Toc197255468 \h  5  

	  HYPERLINK \l "_Toc197255469"  3(b) Public Notice Required Prior to
ICR Submission to OMB	  PAGEREF _Toc197255469 \h  5  

	  HYPERLINK \l "_Toc197255470"  3(c) Consultations	  PAGEREF
_Toc197255470 \h  5  

	  HYPERLINK \l "_Toc197255471"  3(d) Effects of Less Frequent
Collection	  PAGEREF _Toc197255471 \h  6  

	  HYPERLINK \l "_Toc197255472"  3(e) General Guidelines	  PAGEREF
_Toc197255472 \h  6  

	  HYPERLINK \l "_Toc197255473"  3(f) Confidentiality	  PAGEREF
_Toc197255473 \h  7  

	  HYPERLINK \l "_Toc197255474"  3(g) Sensitive Questions	  PAGEREF
_Toc197255474 \h  7  

  HYPERLINK \l "_Toc197255475"  4.0	THE RESPONDENTS AND THE INFORMATION
REQUESTED	  PAGEREF _Toc197255475 \h  7  

	  HYPERLINK \l "_Toc197255476"  4(a) Respondents/NAICS Codes	  PAGEREF
_Toc197255476 \h  7  

	  HYPERLINK \l "_Toc197255477"  4(b) Information Requested	  PAGEREF
_Toc197255477 \h  8  

		  HYPERLINK \l "_Toc197255478"  4(b)(i) Data Items, Including
Recordkeeping Requirements	  PAGEREF _Toc197255478 \h  8  

		  HYPERLINK \l "_Toc197255479"  4(b)(ii) Respondent Activities-	 
PAGEREF _Toc197255479 \h  8  

  HYPERLINK \l "_Toc197255480"  5.0	THE INFORMATION COLLECTED – AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	  PAGEREF
_Toc197255480 \h  8  

	  HYPERLINK \l "_Toc197255481"  5(a) Agency Activities	  PAGEREF
_Toc197255481 \h  8  

	  HYPERLINK \l "_Toc197255482"  5(b) Collection Methodology and
Management	  PAGEREF _Toc197255482 \h  9  

	  HYPERLINK \l "_Toc197255483"  5(c) Small Entity Flexibility	  PAGEREF
_Toc197255483 \h  9  

	  HYPERLINK \l "_Toc197255484"  5(d) Collection Schedule	  PAGEREF
_Toc197255484 \h  9  

  HYPERLINK \l "_Toc197255485"  6.0	ESTIMATING THE BURDEN AND COST OF
THE COLLECTION	  PAGEREF _Toc197255485 \h  10  

	  HYPERLINK \l "_Toc197255486"  6(a) Estimating Respondent Burden	 
PAGEREF _Toc197255486 \h  10  

	  HYPERLINK \l "_Toc197255487"  6(b) Respondent Costs	  PAGEREF
_Toc197255487 \h  10  

		  HYPERLINK \l "_Toc197255488"  6(b)(i) Labor Costs	  PAGEREF
_Toc197255488 \h  10  

		  HYPERLINK \l "_Toc197255489"  6(b)(ii) Capital and Operations Costs	
 PAGEREF _Toc197255489 \h  10  

	  HYPERLINK \l "_Toc197255490"  6(c) Agency Burden and Cost	  PAGEREF
_Toc197255490 \h  11  

		  HYPERLINK \l "_Toc197255491"  6(c)(i) Agency Burden	  PAGEREF
_Toc197255491 \h  11  

		  HYPERLINK \l "_Toc197255492"  6(c)(i)(1) Collection of Evaporative
Emissions Data	  PAGEREF _Toc197255492 \h  11  

		  HYPERLINK \l "_Toc197255493"  6(c)(ii) Agency Costs	  PAGEREF
_Toc197255493 \h  14  

			  HYPERLINK \l "_Toc197255494"  6(c)(ii)(1) Labor Costs	  PAGEREF
_Toc197255494 \h  14  

			  HYPERLINK \l "_Toc197255495"  6(c)(ii)(2) Capital and Operations
Costs Establishment Sample.	  PAGEREF _Toc197255495 \h  14  

	  HYPERLINK \l "_Toc197255496"  6(g)(i) Burden Statement for the
Equipment Ownership Questionnaire	  PAGEREF _Toc197255496 \h  14  

  HYPERLINK \l "_Toc197255497"  REFERENCES.		  PAGEREF _Toc197255497 \h 
15   

1.0	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title of the Information Collection

The collection is entitled:

Evaporative Emissions from Light-Duty Vehicles.

1(b) Short Characterization/Abstract

In response to recommendations from the National Research Council of the
National Academy of Sciences, EPA is initiating a systematic data
collection to estimate the fraction of light-duty vehicles with high
levels of evaporative emissions. Data to be collected include vehicle
type, recent repair history and “in-use” or “real-world”
evaporative emission rates. 

The collection is a test program, to be conducted by the Office of
Transportation and Air Quality (OTAQ) in the Office of Air and Radiation
(OAR). This study will combine novel, newly developed test procedures
with statistical survey design to estimate the number of vehicles with
high evaporative emissions. The new procedures will be developed in a
pilot study that will precede the actual test program. Development of
new test procedures employing new technology and test methods promises
to substantially reduce the cost of evaporative emissions measurement as
well as improve the accuracy of these estimates.  

The test program itself will be conducted in Region 6, and participation
in the program shall be voluntary.  The pilot program shall be conducted
in EPA Region 8, and participation in it shall also be voluntary. 
Evaporative emissions will be measured using a variety of methods that
will include Remote Sensing, an infra-red camera specifically designed
to detect fugitive hydrocarbon emissions and a hydrocarbon sniffer
designed for automotive applications.  Remote sensing data will be
collected prior a standard I/M test as the vehicle approaches the
facility.  Those owners solicited that agree to participate in the
program shall be provided with a rental car and their vehicle
immediately subjected to the test protocol outlined below as resources
permit.  Following quality-assurance and analysis, the data will be
stored in OTAQ’s Mobile Source Observation Database. 

2.0	NEED FOR AND USE OF THE COLLECTION

2(a) Need/Authority for the Collection

The term “light-duty high evaporative emission vehicles” refers to
passenger cars and trucks less than 8500 lbs. GVWR with high evaporative
emissions.  Light-duty evaporative emissions contribute substantially to
mobile source hydrocarbon emissions.  Although it is believed light-duty
evaporative emissions may contribute as much as one-third of the mobile
source HC inventory, this figure has not been quantified empirically due
to the difficulty in accurately and inexpensively measuring these
emissions.  Light-duty fuel consumption in the United States was 74,085
million gallons in 2005, and any HC emissions either from exhaust or
evaporation will not only impact the environment, but will also incur a
loss in fuel economy.

An emissions inventory is an estimate of the quantity of a pollutant
emitted to the atmosphere in a given geographic area during a given time
period. For example, an inventory can represent the quantity of carbon
monoxide emitted by various sources in Washtenaw County, Michigan during
the spring of 2004. Within an inventory, emissions are typically
allocated by source category, with sources classified as
“stationary,” “area”, or “mobile.” Stationary sources
include large facilities with identifiable emissions outlets, such as
coal-fired power plants or industrial boilers. Area sources include
activities for which emissions are diffuse. Examples include feedlot
operations, dry cleaners or wildfires. As the name implies, mobile
sources move from place to place. They include light-duty vehicles (cars
and trucks), as well as other categories such as heavy-duty (greater
than 8500 lbs. GVWR) and nonroad equipment.

2(a)(1) Need for Emissions Inventories for Light-Duty Vehicles

2(a)(1)(1) Inventory Models Supported by EPA

The USEPA Office of Transportation and Air Quality (OTAQ) has developed
and supports the MOBILE model to estimate emissions from motor vehicles,
and work is currently underway on a new modeling tool known as MOVES
that will replace MOBILE in the near future.  Both models estimate fleet
emissions for motor vehicles expressed in g/mile and derived as complex
weighted averages of emission rates for various vehicle types; however
MOBILE does this using fleet emission factors and user input activity
data, while MOVES will use fleet inventory data with default activity
rates available to the user.  To develop an inventory (tons/yr), model
users combine emission factors with estimates of usage, expressed as
miles traveled by different types of vehicles, such as cars, light
trucks, buses, and heavy trucks. A typical source of usage data is
“vehicle miles traveled”(VMT) as estimated by the Federal Highway
Administration’s Highway Performance Monitoring System (HPMS).

2(a)(1)(2) Uses of Emissions Inventories

The MOBILE model is used by various agencies for several differing but
related purposes.  The Environmental Protection Agency is a primary
user. The Office of Transportation and Air Quality (OTAQ) relies on
MOBILE to estimate emissions reductions due to proposed emissions
standards for light-duty vehicles. Additionally, the Office of Air
Quality Planning and Standards (OAQPS) uses MOBILE as one tool in
development of the National Emission Inventory (NEI). The NEI is a
comprehensive database of emissions inventories, updated and published
by EPA every three years, (1996, 1999, 2002, etc.). The NEI includes
emissions estimates from stationary, point, area and mobile sources for
each county in the nation.

MOBILE is also extensively used by state and county agencies principally
to assess or plan for compliance with the Clear Air Act (CAA). Two
important programs under the CAA are the National Ambient Air Quality
Standards (NAAQS) and the Regional Haze Rule (RHR). In implementation of
these programs, technical support from EPA is important, particularly
with respect to estimation of emissions from passenger vehicles, because
local agencies typically lack the technical and financial resources to
develop independent inventories.  

2(a)(1)(3) National Ambient Air Quality Standards. 

The NAAQS are standards that regulate concentrations of several air
pollutants including sulfur dioxide, carbon monoxide, nitrogen dioxide,
ozone and fine particles that can be detrimental to human health or
damage vegetation or property. The standards specify maximum
concentrations, with corresponding time periods over which average
concentrations are calculated (averaging periods). For example, the
terms “1-hour” and “8-hour” ozone represent average ozone
concentrations calculated over periods of one hour and eight hours,
respectively, for which different standards are in effect. If local
monitoring consistently shows no violations of the standards for a given
pollutant in a given geographic area, EPA can designate that area as
“in attainment” for that pollutant. However, if monitoring shows
violations for one or more standards, EPA can designate it as “in
non-attainment” for one or more pollutants. For nonattainment areas,
state and local agencies prepare “State Implementation Plans” (SIPs)
to demonstrate how compliance will be reached or maintained over
specific timetables.

Light-duty gasoline vehicles are estimated to contribute roughly 54% of
the overall VOC mobile-source inventory of 8.3 million short tons in
2002.  If one accepts that evaporative emissions account for 30% of
these VOC emissions, the mass of evaporative VOC losses is roughly 1.4
million tons per year.

2(a)(2) The National Academy Report on Emissions Inventory Modeling

At the request of Congress, the National Academy of Sciences published a
report on EPA’s Inspection and Maintenance program (NRC 2001). A
committee of technical experts was given the primary charge of reviewing
I/M programs across the nation as well as the role of the MOBILE model
in these programs.  The committee concluded that there is currently no
accurate inexpensive way to identify vehicles with high evaporative
emissions.  The recommendations in this NRC report along with those in
an earlier NRC study (2000) have influenced the concept and design of
EPA’s new inventory model for highway vehicles, the Motor Vehicle
Emissions Simulator (MOVES).  Similarly, this study is intended as the
first step in an effort to respond to the need to develop test
procedures to identify vehicles with high evaporative emissions and
quantify the level of these emissions.

2(a)(3) Legislative Basis

The legislative basis for this data collection is Section
103(a)(1)(2)(3) of the Clean Air Act, which requires the Administrator
to: “conduct ... research, investigations, experiments,
demonstrations, surveys, and studies relating to the causes, effects,
extent, prevention, and control of air pollution, ...” and
“cooperate with ... pollution control agencies and other appropriate
public or private agencies, institutions, and organizations, and
individuals in the conduct of such activities, ...” and “conduct
investigations and research and make surveys concerning any specific
problem of air pollution in cooperation with any air pollution control
agency ...”

In addition, Section 103(b)(1) of the Clean Air Act authorizes the
Administrator to: “collect and make available, through publications
and other appropriate means, the results of and other information,
including appropriate recommendations by him in connection therewith,
pertaining to such research and other activities.” The full text of
the relevant sections is provided in Appendix A.1. 

2(b) Practical Utility/Users of the Data 

The principal users of the data will be EPA technical staff, for
purposes of estimating the evaporative emissions from the national
fleet.  This data will be used to characterize the fleet evaporative
emissions as the Agency develops the MOVES model.  Little data on the
fraction of high evaporative emissions vehicles exist and this study
would be a landmark study that would define the fraction of high
evaporative emissions vehicles in the fleet.

Finally, analysis and evaluation of the initial collection will enable
evaluation of the cost-effectiveness of the design as proposed.  In
addition, the initial results will guide and inform sample size
analyses. Data collected will provide highly valuable estimates of
variability in key variables, as well as scenarios and expected
differences needed for more refined power analyses. Specific analyses to
be performed are described in Part B of this Supporting Statement, in
sections 2(b)(ii), “Sample Sizes,” and in Section 5(b), “Data
Analysis.”

3.0	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Nonduplication

In development of this collection, EPA has attempted to locate sources
of data that would partially or wholly duplicate the information to be
collected. No such duplication was found.  EPA searched published
literature for terms related to light-duty evaporative emissions
measurement.  No duplication of the data collection effort was found. 
To our knowledge, no other agency has a proven method to identify and
measure emissions from high evaporative vehicles in the field.  

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

The initial announcement of the ICR and request for public comment was
placed in the Federal Register on February 14, 2008.  A second notice
will be published in the Federal Register concurrent with submission of
this collection to OMB. 

3(c) Consultations

Technical Consultations. In the development of this collection, we
consulted with professionals with expertise in survey methodology and
statistics, RSD and on-road HC  measurement both in academia and the
private sector. Specific parties and contact information is listed
below.  Additionally, this supporting statement was drafted by Eastern
Research Group.

Hugh Williamson, Ph.D.

Engineering Scientist

CACI Technologies, Inc.

11211 Taylor Draper Lane, Suite 115

Austin, Texas  78759

(512)406-3618

Dennis McClement

Sierra Research

1801 J Street

Sacrament, CA 95811

916-444-6666

Don Stedman, Ph.D.

Gary Bishop

University of Denver

Chemistry Department

Denver, CO 80208

303-871-2580

Jim Sidebottom

Colorado Department of Health

4300 Cherry Creek Dr.

Denver, CO 80246

303-692-3149

This supporting statement was prepared by:

Eastern Research Group

5608 Parkcrest Drive

Austin, TX  78731-4947

512-407-1830

3(d) Effects of Less Frequent Collection

For each respondent, participation in the study is a one-time event.
Thus, periodic reporting is not requested or required.

3(e) General Guidelines

Participation in the program by each owner is on a voluntary basis.
Further, this information collection complies with the guidelines in the
Paperwork Reduction Act (5 CFR 1320.5(d)(2)). Specifically, the
collection does not require the respondents to:

Report information to EPA more often than quarterly;

Prepare a written response to a collection in fewer than 30 days after
receipt;

Submit more than one original document;

Retain any records for more than three years;

Participate in a statistical survey that is not designed to produce data
that can be generalized to the universe of study;

Use a statistical data classification that has not been reviewed and
approved by OMB;

Submit any information that they may consider to be confidential,
without EPA demonstrating that it has instituted procedures to protect
the information’s confidentiality to the extent permitted by law.

3(f) Confidentiality

Data will be collected under a pledge of confidentiality for exclusively
statistical purposes, as defined in the Confidential Information
Protection and Statistical Efficiency Act of 2002 (CIPSEA). Thus, in
accordance with CIPSEA, EPA will not use or disclose survey results in
identifiable form for any non-statistical purpose.

To protect the confidentiality of respondents, the following items
allowing direct identification of individuals will not be disclosed or
directly linked to survey results under any circumstances.

Participant name(s)

Participant address(es)

Participant phone number(s)

Participant contact name(s)

Vehicle Identification number (VIN)

The following additional items will be protected from disclosure as
necessary to protect individual respondents from identification through
indirect means. The methods considered for prevention indirect
disclosures are briefly described for each item, drawing on approaches
recommended for the protection of public-use microdata by the Federal
Committee on Statistical Methodology (FCSM 2004).

3(g) Sensitive Questions

The questionnaires do not ask any sensitive questions pertaining to
sexual attitudes/behavior or religious beliefs.

4.0	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents/NAICS Codes

As defined in Part B, section 2(a) “Target Population and Coverage,”
respondents to the survey will be owners of light-duty cars and trucks. 
This sector is fairly well-defined and we anticipate our sampling of
this population will provide a representative sample based on the
statistical methods outlined in Part B of this ICR.

We define the target population in more detail in Part B, section 2(a).

4(b) Information Requested

4(b)(i) Data Items, Including Recordkeeping Requirements

Reporting Items. All items that respondents will be requested to report
are listed and described in Part B, Section 3, “Questionnaire
Development.” The survey will employ one written document, the
“Vehicle Ownership Questionnaire”.

Recordkeeping Items. This collection will not request or require
respondents to compile or maintain any records.

4(b)(ii) Respondent Activities- 

Respondent activities for this data collection include:  

Respond to initial screening for under hood inspection solicitation

Respond to Main emissions bin solicitation

Complete solicitation process – transfer vehicle to contractor

Participate in on-site emissions testing

Complete vehicle exit paperwork

Participate in off-site lab testing

5.0	THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT

The following sections describe Agency activities related to survey
design, oversight, and analysis, maintenance and distribution of the
information collected. The primary activities associated with the actual
collection of information will be performed by EPA personnel or
contractors hired by the Agency.

5(a) Agency Activities  

In conduction of the survey, the agency will perform the following
activities:

Develop research questions 

Develop a plan for conducting a study to answer the questions

Develop data forms and test procedures 

Conduct Pilot testing

Analyze Pilot Study data

Refine testing methodology

Modify Data forms and test procedures

Conduct Main Study

Collect and quality-assure data

Perform data analysis

Publish report and findings of the study

5(b) Collection Methodology and Management

The questionnaire to be used for the owner survey will be given to each
owner agreeing to participate in the study.  Due to the brevity and
simplicity of the questionnaire, we do not anticipate any hardship to
the vehicle owner in completing it quickly during the interview process
with the technician.

To ensure data quality for interview information, each interview
response will be reviewed for completeness and internal consistency.
Emissions and activity data collected via instrumentation will be
quality-assured through use of computer algorithms. Time series for key
variables will also be plotted and visually checked on a case-by-case
basis. Quality-assurance steps for data collected are discussed in Part
B, Section 5(a), “Data Preparation.”  Following quality-assurance,
electronic data will be directly transferred into database software.
Computer files containing interview responses will be stored or managed
in spreadsheet software, such as Microsoft Excel®, or database software
such as Microsoft Access® or Microsoft FoxPro®. Analyses will be
performed using SAS, version 8.2®, or SPSS, version 9®.   Data will be
stored in the “Mobile Source Observation Database,” (MSOD), an
Oracle® database residing on an Agency server. This database is
available to the public on request on CDROM, and can also be accessed
from the server via a viewer based on Microsoft Access®. Thus, users
need not be equipped with Oracle software or expertise to access the
database.

5(c) Small Entity Flexibility  

As described above, collection methods for the survey have been designed
to keep the burden of participation to a bare minimum.  Additionally,
participation in the program is voluntary, giving owners the option of
not participating if they so choose.

5(d) Collection Schedule

The tentative schedule below assumes OMB clearance for this collection
will be obtained by July, 2008. For each task, we show the date targeted
for its completion.

Design questionnaire and sampling plan July, 2008

Collect RSD Samples, August, 2008

Field Validation & Questionnaire, August, 2008

Submit Draft Report September, 2008

Submit Final Report November, 2008

6.0	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

Table A.1 presents initial estimates of burden and cost for respondents
participating in the collection.  The initial RSD screening will be done
non-intrusively and will therefore not impact the owner in any way. 
Performing the modified CA leak procedure will take approximately 0.1
hours, as will the initial solicitation of the owner.  Estimated time
for the owner to complete the survey is 15 minutes, and for those that
choose to participate in the study the additional time will be on the
order of 3 hours.  This additional time is primarily due to the process
of receiving a rental car and then the time taken to by the owner to
return the rental and retrieve their vehicle.

6(b) Respondent Costs

Table A.1 presents estimated burden and cost to the respondents.

6(b)(i) Labor Costs

Table A.1 presents the estimated labor costs to the respondents.

6(b)(ii) Capital and Operations Costs

For respondents, participation in this collection will not require any
capital or startup costs, nor will it require operating or maintenance
costs. Thus, no costs in either of these two categories are represented
in Table A.1.

Table A1- Annual Respondent & Burden Cost

Information Activity	Respondent

Time	Labor

cost*	No.

Respondents	Total

Time	Total

Cost

	hrs	($/hr)

hrs	($)

Respond to initial screening based on under hood inspection solicitation
0.1	$25.93 	800	80	$2,074 

Respond to Main emissions bin solicitation	0.1	$25.93 	2000	200	$5,186 

Complete solicitation process - transfer vehicle to contractor	0.1
$25.93 	1000	100	$2,593 

Participate in on-site emissions testing	2	$25.93 	1000	2000	$51,860 

Complete vehicle exit paperwork	1	$25.93 	1000	1000	$25,930 

Participate in off-site lab testing	5	$25.93 	30	150	$3,890 

 





Total	3530	$91,533 

* Source: 	EMPLOYER COSTS FOR EMPLOYEE COMPENSATION— JUNE 2007,Bureau
of Labor Statistics, US Dept of Labor



6(c) Agency Burden and Cost

Table A.2 presents Agency burden and cost for the program.  In all
cases, separate estimates are presented for Contractor personnel and
Agency staff. 

6(c)(i) Agency Burden

6(c)(i)(1) Collection of Evaporative Emissions Data

Table A.2 presents estimated agency labor hours for each activity listed
above.  We have separated labor hours into two components, those hours
to be worked by Agency staff and those to be worked by contractor
personnel. In general, the contractor will perform the emissions
measurements, solicit the vehicle owner, handle the necessary paperwork
and perform initial quality assurance, following which the contractor
will transfer the data to EPA. Agency personnel will then load the
results into an EPA database and perform quality-assurance and
substantive analyses.

For contractor personnel, most of the time represents preparation for
the field work, arranging the field logistics, vehicle solicitation,
data collection, emissions measurement, equipment QA/QC and data entry.
These activities are assumed to take 1.9 man hours per vehicle on
average, respectively. 

For agency staff, we assume that agency personnel will be involved in
the weekly management of the project, provide oversight and arrange
emissions equipment, as necessary. Agency staff will also be involved in
reviewing the data collected on a regular basis and for will provide
technical input throughout the program.  For analysis, we assume that
agency staff will spend about 10% of the hours spent by contractor
personnel.

6(c)(ii) Agency Costs

6(c)(ii)(1) Labor Costs

Contract Labor Costs. The average contract labor cost for this effort is
$100 per hour as listed in Table A2.  

Agency Labor Costs. Labor Costs for EPA staff were taken from the 2008
Locality Schedule for Civilian Federal Employees in the Detroit area.
Based on the Schedule, we have assumed average hourly labor costs of
$56.00 for managerial personnel, $52.09 for technical personnel and
$21.65 for clerical personnel. These assignments correspond to levels of
GS-15-1, GS-13/14-7 and GS-7-5, respectively. We have multiplied the
hourly labor rates by a “benefits multiplier” of 1.6, to represent
the total cost of employment for Federal staff (OEI, 1999).   

6(c)(ii)(2) Capital and Operations Costs Establishment Sample. 

Capital costs represent the cost of obtaining the necessary equipment to
perform the evaporative testing described in the work plan.  Operating
and Maintenance costs represent the cost to perform the pilot study as
well as the costs associated with performing evaporative emissions test
on the large 1,000 vehicle sample.

6(g)(i) Burden Statement for the Equipment Ownership Questionnaire

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 2 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-2008-0118, 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 3334, 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.  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.
(EPA-HQ-OAR-2008-0118) and OMB control number (2060-NEW) in any
correspondence.

REFERENCES.

Bureau of Labor Statistics. 2003. Employer Costs for Employee
Compensation-June 2003.  USDL: 03-446. U.S. Department of Labor,
Washington, D.C.

Federal Committee on Statistical Methodology. 2004. Report of
Statistical Disclosure Limitation Methodology. Subcommittee on
Disclosure Limitation Methodology. Statistical Policy Office, Office of
Information and Regulatory Affairs, Office of Management and Budget. 
Statistical Policy Working Paper 22.   HYPERLINK
"http://www.fcsm.gov/working-papers/spwp22.html" 
http://www.fcsm.gov/working-papers/spwp22.html . May, 2004.

National Research Council. 2000. Modeling Mobile-Source Emissions.
Committee to Review EPA’s Mobile-Source Emissions Factor (MOBILE)
Model. National Academy Press, Washington D.C. 

National Research Council. 2001. Evaluating Vehicle Emissions Inspection
and Maintenance Programs. National Academy Press, Washington D.C. 

Office of Environmental Information. 1999. ICR Handbook: EPA’s Guide
to Writing Information Collection Requests Under the Paperwork Reduction
Act of 1995. Collection Strategies Division, U.S. Environmental
Protection Agency. Washington, D.C.

APPENDIX A-1

Relevant Sections of Statutes

The Statutes relevant to this collection are (103(a) and (103(b) of the
Clean Air Act, listed below:

Sec. 103. (a) The Administrator shall establish a national research and
development program for the prevention and control of air pollution and
as part of such program shall - 

(1) conduct, and promote the coordination and acceleration of, research,
investigations,  experiments, demonstrations, surveys, and studies
relating to the causes, effects (including health and welfare effects),
extent, prevention, and control of air pollution;

(2) encourage, cooperate with, and render technical services and provide
financial assistance to air pollution control agencies and other
appropriate public or private agencies, institutions, and organizations,
and individuals in the conduct of such activities;

(3) conduct investigations and research and make surveys concerning any
specific problem of air pollution in cooperation with any air pollution
control agency with a view to recommending a solution of such problem,
if he is requested to do so by such agency or if, in his judgment, such
problem may affect any community or communities in a State other than
that in which the source of the matter causing or contributing to the
pollution is located;

(4) establish technical advisory committees composed of recognized
experts in various  aspects of air pollution to assist in the
examination and evaluation of research progress and proposals and to
avoid duplication of research; and

(5) conduct and promote coordination and acceleration of training  for
individuals  relating to the causes, effects, extent, prevention, and
control of air pollution.

(b) In carrying out the provisions of the preceding subsection the
Administrator is authorized to - 

(1) collect and make available, through publications and other
appropriate means, the results of and other information, including
appropriate recommendations by him in connection therewith, pertaining
to such research and other activities;

(2) cooperate with other Federal departments and agencies, with air
pollution control agencies, with other public and private agencies,
institutions, and organizations, and with any industries involved, in
the preparation and conduct of such research and other activities;

(3) make grants to air pollution control agencies, to other public or
nonprofit private  agencies, institutions, and organizations, and  to
individuals, for purposes stated in subsection (a)(1) of this section;

(4) contract with public or private agencies, institutions, and
organizations, and with  individuals, without regard to sections 3648
and 3709 of the Revised Statutes (31 U.S.C. 529; 41 U.S.C. 5);

(5) establish and maintain research fellowships, in the Environmental
Protection Agency  and at public or  nonprofit private educational
institutions or research organizations;

(6) collect and disseminate, in cooperation with other Federal
departments and agencies, and with other public or private agencies,
institutions, and organizations having related responsibilities, basic
data on chemical, physical, and biological effects of varying air 
quality and other information pertaining to air pollution and the
prevention and control thereof;

(7) develop effective and practical processes, methods, and prototype
devices for the prevention or control of air pollution; and

(8) construct facilities, provide equipment, and employ staff as
necessary to carry out this Act.

In carrying out the provisions of subsection (a), the Administrator
shall provide training for, and make training grants to, personnel of
air pollution control agencies and other persons with suitable
qualifications and make grants to such agencies, to other public or
nonprofit private agencies, institutions, and organizations for the
purposes stated in subsection (a)(5). Reasonable fees may be charged for
such training provided to persons other than personnel of air pollution 
control agencies but such training shall be provided to such personnel
of air pollution control agencies without charge.

  PAGE  i 

  PAGE  17 

	

