DRAFT

Supporting Statement

for

Information Collection Request

Motor Vehicle Emissions:

Revisions to Certification of Alternative Fuels Conversions 

EPA ICR 0783.55

April 2010

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	 

	Motor Vehicle Emissions: Revisions to Certification of Alternative
Fuels Conversions; EPA ICR number 0783.55, OMB control number 2060-0104.

1(b) Short Characterization/Abstract

	The Environmental Protection Agency is proposing changes designed to
simplify and lessen the burdens for manufacturers seeking approval to
introduce into commerce in the U.S. light-duty vehicles, light-duty
trucks, medium-duty passenger vehicles, and heavy-duty vehicles and
engines that have been converted for use of fuels that the original
models were not designed for, such as from gasoline to liquid propane
gas (LPG) or compressed natural gas (CNG). This ICR covers the
light-duty portion of the proposal. These applications are currently
administratively handled as a part of EPA’s motor vehicle and engine
certification program, covered by the ICR 0783 series. This ICR
addresses the anticipated paperwork burden reduction of the proposal
within the context of the existing baseline from OMB 2060-0104 (ICR
0783.54), which was approved on August 31, 2009. 

	These changes would start taking effect with 2011 model year light-duty
vehicles and trucks or upon the effective date of the final rule. 
Starting then, manufacturers will be given expanded options for
submitting simplified applications. ICRs normally have a three year time
horizon. This ICR will cover the expected paperwork burden changes for
the three years after the effective date of the final rule. 

	Information collected under the existing alternative fuels conversion
program consists of test results and related submissions under existing
procedures for the EPA light-duty vehicle certification program.  All
information from converter applicants is currently submitted
electronically directly to the Verify system.  Subject to
confidentiality claims, this information is made available to interested
parties upon request.  Emission test information is available on the
internet.

	The burden analysis in this ICR differs from the cost analysis in the
preamble to the proposed rule in important respects. First, ICRs are
concerned with paperwork burdens, a subset of all business costs: this
ICR covers the costs and labor hours of providing information to EPA,
including both the paperwork itself and the costs and labor to develop
the information, such as testing to provide test results, and facilities
to carry out that testing. It is not concerned with the costs of
compliance in general, nor with general business overhead or profits. 
The preamble, on the other hand, focuses on costs incurred in developing
conversions that comply with the Clean Air Act and subsequent
certification applications through contracts by converters with testing
companies, which include overhead and profit elements not counted in the
0783 series. The analysis in this ICR uses the traditional capital cost,
O&M cost, and labor cost assumptions in this ICR series, so that, for
example, facility costs that would be recovered as part of a consulting
firm's contract are here allocated to capital costs. Second, the
preamble focuses on the burden for a single converter enterprise of
interest (and generalizes this to four such enterprises). This ICR
attempts to generalize the analysis to the industry as a whole. Third,
the ICR does not cover development costs associated with compliance with
the Clean Air Act, but only the paperwork-related costs once such a
conversion has been achieved to the point where the converter submits an
application for certification.  

	The existing baseline estimates that certification applications for 36
test groups from five converter respondents are submitted annually. The
most recent model year data available (model year 2008) shows 18
light-duty vehicle conversions. This ICR adjusts the baseline to 18
conversions and calculates industry savings against that number. The
analysis also gives the change in the 0783 ICR overall collection. 

	These test groups consist of conversion kits that apply to a specific
certified OEM (original equipment manufacturer) vehicle engine family,
or in some cases group of families. As with OEM certifications, the
biggest paperwork cost component for converters is testing. However,
estimating testing costs under the existing regulations has been
difficult because the alt. fuel converter program encompasses a diverse
range of circumstances. Many of the tests are currently waived in
certain situations. For example, currently, evaporative testing may or
may not be waived depending on whether a closed fuel system is used.
Exhaust and evaporative emission testing can be waived for dual-fueled
gasoline/LPG or gasoline/CNG vehicles if the modification doesn’t
increase the weight more than 500 pounds and no increase in emissions is
expected. (Assumptions for dealing with these complexities both in the
existing program and under the proposal are discussed in Section 6.) 

	The current baseline applied to 18 test groups estimates an industry
total paperwork cost of $137,856. As with the main light-duty program,
this does not include development costs (such as repeated testing needed
to perfect a conversion kit that can meet emission and OBD standards),
which are not directly mandated by the Clean Air Act but which can be
considerable. Other elements of the alt. fuels certification process
covered by this ICR are listed in Part 4 below, including paperwork
filing burdens, which are budgeted in the ICR as O&M costs and labor
hours. Converted vehicles are also, as with other certified vehicles,
subject to EPA's confirmatory testing program, durability demonstration,
Vehicle Emission Control Information (VECI) labeling, defect and
voluntary emission recall reporting, and other light-duty requirements
(all covered in ICR 0783). In addition, they are subject to EPA’s
certification fee requirements (ICR2080; OMB 2060-0545) but burden
changes in this program is de minimis (the number of fee forms affected
is small and will be reflected in the next fees ICR renewal). All burden
elements in this ICR are in the Emissions (Certification) IC. 

	The proposed changes will recognize three classes of conversions: to
(1) vehicles that are new or relatively new, (2) vehicles within EPA’s
definition of useful life but which are neither new nor relatively new
(“intermediate life vehicles”), and (3) vehicles that are outside
EPA’s definition of useful life.  For the newest vehicles,
certification will still be required, but with some additional
flexibilities and expansion of options.  Conversion of intermediate life
vehicles will be not be certified but audited through reporting of a
simplified testing demonstration that the converted vehicle family still
meets emissions standards certified for the OEM vehicle family. For
conversion of outside useful life vehicles EPA intends to finalize a
single demonstration requirement but is seeking comment on three
options. 

	Beginning in model year 2011 or the effective date of these
regulations, the proposed changes will reduce total costs annually on
the regulated manufacturers by $50,667 in non-labor costs and 7,073
labor hours. 

	Additional details on the coverage of this ICR are given in Section
2(b), below. 

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.), EPA is
charged with issuing certificates of conformity for motor vehicle
designs that comply with applicable emission standards set under section
202(a)(1) of the Act.  A manufacturer must have a certificate before
vehicles may be legally introduced into commerce.  To insure compliance
with the Act, EPA reviews product information and manufacturer test
results; EPA also tests some vehicles to confirm manufacturer results.  

	Section 203 of the Clean Air Act contains “anti-tampering”
provisions prohibiting alteration of OEM vehicle components relevant to
the vehicle’s certification under the Act.  Regulations at 40 CFR,
Part 85, Subpart F, provide exemption for aftermarket conversion systems
from these tampering prohibitions for those converters complying with
the regulations of that Part. Under Subpart F, these exemptions are
currently administered through a certification process that is modeled
on the OEM certification provisions: converters submit certification
requests for engine families, and those that satisfy EPA’s regulations
upon review are granted certificates of conformity for one model year. 

2(b) Practical Utility/Users of the Data

	The information collection under the rule would be used to determine
whether the new requirements have been complied with by means of the
revised certification and compliance program. 

Section 3: Nonduplication, Consultations, and Other Collection Criteria 

3(a) Nonduplication

	The information collection, reporting, and storage provisions of the
proposed rule rely to the maximum extent possible on EPA’s existing
certification program, while simplifying that program to reflect the
needs of this industry. 

	Efforts have been made to eliminate duplication in this information
collection.    EPA-CISD (Compliance and Innovative Strategies Division)
is currently using, for light-duty vehicles, a new information
management system (Verify), under which the manufacturer submission
process will occur within a Central Data Exchange (CDX) environment that
should further help minimize duplication in submissions. 

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

 

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

	EPA solicited public comment by means of a Federal Register Notice
published on ____,  2010, __ Federal Register ___; a copy can be found
at _____________ . The draft ICR was placed in the docket. 

3(c) Consultations

	The proposed regulations, including the cost analysis that is reflected
in this ICR, were developed based on experience with similar regulations
developed in the past in close consultation with the affected industry. 
In designing this proposal EPA sought and received significant input and
feedback from the fuel conversion community.  

 

	In preparing the proposed rule, EPA made use of consultations with
several converters and an independent test lab working in the regulated
industry:

	Their comments have been considered in developing the burden estimates
discussed below. EPA wishes to thank them and their colleagues for their
assistance in preparing this report.

3(d) Effects of Less Frequent Collection

	As required by the Clean Air Act (42 USC 7525(a)), emission information
is currently submitted on a yearly basis coinciding with the
manufacturer’s “model year.”  EPA allows applicants to define
their own “model year”, thus granting some flexibility in this
regard.  Major product changes typically occur at the start of a model
year. For these reasons, a collection frequency longer than a model year
is not possible normally possible.  However, this rule would replace the
annual application and compliance process with a one-time submittal for
intermediate and outside useful life vehicles. Furthermore, for new and
relatively new vehicles, when a vehicle design is “carried over” to
a subsequent model year, the amount of new information required is
substantially reduced.  

3(e) General Guidelines

	Manufacturers are required to keep some records for periods longer than
three years This requirement stems from the statutory requirement that
manufacturers warrant some items for periods longer than 3 years. 

	This information collection activity complies with the remaining
guidelines in 5 CFR 1320.5.  The proposal makes no changes in the
reporting and recordkeeping provisions that impact any of the guidelines
for information collections as approved in the existing approved
collection.

3(f) Confidentiality

	Information submitted by manufacturers is held as confidential until
the specific vehicle to which it pertains is available for purchase. 
After vehicles are available, most information associated with the
manufacturer/importer’s application is available to the public.  Under
section 208 of the Clean Air Act (42 USC 7542(c)) all information, other
than trade secret processes or methods, must be publicly available. 
Proprietary information is granted confidentiality in accordance with
the Freedom of Information Act, EPA regulations at 40 CFR Part 2, and
class determinations issued by EPA’s Office of General Counsel.

3(g) Sensitive Questions

	No sensitive questions are asked in this information collection.  This
collection complies with the Privacy Act and OMB Circular A-108.

Section 4: Respondents and Information Requested

4(a) Respondents/NASIC Codes

	The respondents are potentially involved in the industries shown in the
following table:

Industry	335312A

336312

336322

336399

454312

485310	Alternative fuel vehicle converters

A North American Industry Classification System (NAICS)

4(b) Information Requested

(i) Data items

	The information and reporting burden associated with this rule occurs
within the context of EPA’s motor vehicle certification and compliance
program.  Current regulations require converters to submit emissions
information to EPA in conjunction with this program.  Converters of
newer vehicles must submit an application for emission certification
prior to production.  Intermediately aged vehicle converters will submit
a simplified testing demonstration without the burdens of the formal
certification application process. For vehicles converted outside their
useful life, regulation will be through an information submission that
the conversion is technically viable and will not increase emissions. 
These reporting formats describe the major aspects of the proposed
product line, technical details of the emission control systems, and the
results of any required tests to indicate compliance with the emissions
limitations.  The reports and supporting test results are reviewed and,
if appropriate, a certificate of conformity is issued, the applicant is
notified of possible noncompliance with anti-tampering provisions, or
additional post-production information is requested.  

	New/revised data items:

	At the time of certification:

		For all vehicles: 

expanded  conversion test or "demonstration" groups 

exemption from HCHO testing for conversions to CNG and LPG 

conversion factors for calculating NMOG for conversions to CNG and LPG 

new VECI label requirement describing test group, mileage, and date 

For intermediate-age and outside useful-life age vehicles (25%)

online notification and test result report rather than application for
certification (savings in “paperwork” burden) or compliance
“demonstration” for outside useful-life conversions

description of OBD compliance strategy or OBD demonstration rather than
current OBD test results

	

(ii) Respondent Activities

	While there is no “typical” converter respondent, all converters
must describe their product and supply test data and other information
to verify compliance. In some cases the proposal would replace the
current application and certification process with a notification and
audit process. Applicants for certification submit certification fees,
usually “reduced fees” set at 1% of the estimated retail sales value
of the conversion package, including labor. Converters or installers of
conversion kits must install a second VECI label on converted vehicles.
Converters must also retain records.  These tasks are repeated for each
model year, although typically previous data and information can be
“carried over” when no significant changes have occurred.  

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

Agency Activities

	The test data used by EPA to determine compliance with emissions
standards are derived from vehicle testing done by vehicle converters
who report their own test data to EPA, and at EPA's National Vehicle and
Fuel Emissions Laboratory in Ann Arbor, Michigan.  EPA staff review
applications (or notifications or demonstrations), issue certificates,
and oversee the program. 

5(b) Collection Methodology and Management

	  All information from converter applicants will be submitted
electronically directly to the Verify system by the effective date of
the new rule.  By guidance letter CISD-09-14, vehicle converters are
required to submit applications for certification through Verify
beginning with the 2010 model year. The rule makes no changes in this
reporting system, only changing the format and content of some of the
information reported within it. 

	All information received by EPA is subject to review.  Data submitted
are screened to determine that the test results insure compliance with
emission and fuel economy standards.  Narrative descriptions of the
proposed product line are checked to verify that the appropriate "worst
case" vehicles have been tested. Except for projected sales and a very
limited amount of proprietary product information, all information is
available to the public as soon as the vehicle is offered for sale. 
Emission data are available on the internet; other information is
available upon request under the Freedom of Information Act.

5(c) Small Entity Flexibility

	Converters already enjoy various exemptions and special provisions
tailored to their small entity status and special business needs in
contrast to original vehicle manufacturers, such as use of assigned
deterioration factors, exemption from the manufacturers’ in-use
vehicle testing program (IUVP) and availability of reduced certification
fees. This proposal further extends this flexibility in numerous ways
detailed in the proposal and summarized in this Supporting Statement.   

5(d) Collection Schedule

	Currently, information must be submitted for each “model year” that
a manufacturer intends to convert vehicles. Under the proposal, only the
newest vehicles will be required to renew annually, but all categories
will file an end-of-year report (as do light-duty manufacturers). For
emissions purposes, a “model year” is statutorily defined as the
annual production period of a manufacturer, as decided by the
Administrator, that includes January 1 of that calendar year; or  that
calendar year if the manufacturer does not have an annual production
period.  If a product is unchanged between model years, much of the
information can be “carried over.”  The collection frequency and
burden are determined to a large extent by the manufacturer’s
marketing and production plans.  

Section 6: Estimating the Burden and Cost of the Collection

	The following estimates of reduced burden use baselines and
methodologies developed in the process of continuing updates of the 0783
ICR series, including the last renewal (ICR 0783.54), and the proposed
greenhouse gasses rule (ICR 0783.56).  The reasoning behind estimates of
decreased burden from the current baseline are given below and
summarized in Section 6(f). 

 

6(a) Estimating Respondent Burden (Hours)

	As noted above, the number of converter test groups covered by the ICR
is subject to small number fluctuations. The baseline in the last
renewal (ICR 0783.54) was 36 test groups; in the renewal three years
before that (ICR 0783.47) it was 15. Following normal practice, the
baseline is here adjusted to reflect the most current information
available; we count 18 light-duty conversion test groups for Model Year
2008. The Emissions IC will reflect this adjustment. The discussions
below compare the burdens on 18 families before and after the proposal. 

	Within the converter program under the adjusted baseline, the
respondent hours burden decrease for the Light-Duty Vehicle Emissions
Information Collection reflects reduced labor hours associated with
conducting tests and reduced reporting. This is largely due to the
broader definition of test groups, since this definition determines how
many tests must be conducted. The paperwork reporting burdens in
particular are significantly reduced for intermediate and out of useful
life conversions. As converters are a very small subset of the current
light-duty baseline (currently 18 out of 427 test groups/engine
families), the decrease in burden is correspondingly small; but for
vehicle converters the hour savings are significant (from 14,869 hours
down to 7,796 hours, a savings of over 40%). 

	In particular, the number of test groups requiring any reporting under
this rule is estimated to be reduced by 25 percent. This correspondingly
reduces the labor hours associated with conducting emissions tests
(including preparation costs, FTP tests, NMOG tests and HFET tests), OBD
compliance reporting, confirmatory testing costs (including shipment
costs), and paperwork reporting and recordkeeping costs associated with
preparing this information in any of the required formats and submitting
it to EPA for review and saving it for possible submission to EPA upon
request. Intermediate and beyond useful life conversion test groups are
estimated to achieve an additional 80 percent reduction in paperwork
reporting for those  qualifying.

	

	The ICR includes a minor startup cost for implementing new labeling
requirements. All labor hours associated with startup costs are treated
as capital/startup costs, so they are included under that heading,
following EPA guidance (EPA ICR Handbook, Rev. 11/05, p. A-31).  

6(b) Estimating Respondent Costs

Estimating labor costs

	Labor costs for testing follow the testing labor cost assumptions of
ICR 0783.54 and average out to $59.07 per hour across management,
technical, and secretarial categories. This figure, which was initially
based on the fees rule cost study of EPA laboratory expenses, matches
very closely with an analysis based on rates for engineering managers,
mechanical engineers, and secretaries (except legal, medical, and
executive) from the May 2005 BLS National Industry-Specific Occupational
Employment and Wage Estimates
(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. The labor cost analysis may be updated for the
final ICR. 

(ii) Estimating Capital and Operations and Maintenance Costs

	Operation and Maintenance costs are the non-labor costs associated with
conducting the new tests that are anticipated for the full model year
after the effective date of the new regulations.  The O&M costs for
conducting emissions tests follow the assumptions in prior ICRs in this
series, with an improved figure for NMOG and HCHO analysis, totaling
about $4,000 per vehicle, with another $3,600 for OBD compliance and
$2,000 for each confirmatory test. The estimate also includes O&M items
for evaporative emissions testing, and reporting and recordkeeping, with
the baseline total coming to about $10,000 per activity (test group).
Applied to the industry, the baseline O&M cost is $121,541 annually. The
proposal reduces this figure by $44,650, down to $76,891. This is
primarily due to 1) reduction in the number of test groups by 25%; and
2)  savings of $1,750 in NMOG and HCHO testing per test group. 

(iii)  Start-up Costs

	“Startup” costs are one-time costs to implement the new
requirements in the proposal that are applicable to the next model year
conversions being certified or by the respondent converters after the
effective date of the final rule. These startup burdens fall into two
categories. 

	First are startup costs to redesign the VECI label.  This burden is an
add-on to well established reporting requirements: manufacturers already
submit similar label data to EPA.  Once the new label templates are in
place, we anticipate no increase in burden for this startup item.  This
part of the estimate costs new analysis and coding for 18 test groups,
reduced to 14 by the new rule. This is a small item, less than $10,000
for the industry, and is annualized and discounted at 7% in the cost
estimate. 

	Second are capital costs associated with the testing requirements.
Because manufacturers vary widely in their existing testing facilities,
their excess capacities, their work shift arrangements and
availabilities, the real estate cost and land availabilities for
hypothetical expansions, and their contractual arrangements with other
testing facilities, CISD has for many year now used the approximation
that a facility capable of performing 750 FTP/HFET tests per year costs
$4,000,000 and allocated this cost to each testing increment. This cost
is then allocated over ten years and discounted at 7%. This methodology
is considered conservative, because it assumes no excess capacity.
Similarly, evaporative facilities are costed at $3,000,000 to conduct
900 evaporative tests a year. While most converters work through
contractors whose contract costs do not break down costs in this manner,
for consistency the analysis in the Certification IC series is continued
here. 

	Primarily due to the reduction in the number of test groups (slightly
offset by the new labeling startup) he total non-depreciated  capital
costs for the conversion program of $114,600 are reduced by $45,417 to
$69,183.  

6(c) Estimating Agency Burden

	The emission and fuel economy compliance programs are primarily
administered by EPA’s Compliance and Innovative Strategies Division
and Laboratory Operations Division.  Approximately 47.5 full time
employee equivalents are directly involved in the combined emission and
fuel economy light-duty, motorcycle, and other, secondary programs;
their cost is approximately $5.9 million, including benefits but not
overhead.  EPA also participates in a program whereby the agency
contracts with an organization that provides qualified persons to
perform duties for the agency that are not performed by EPA employees. 
The cost associated with these persons who work directly on these
programs is approximately $0.23 million, excluding overhead.   Overhead
percentage for the entire division is approximately 16.9%, yielding an
estimated total agency labor cost of $7.17 million. The total
non-capital costs for the light-duty and motorcycle programs, including
direct and indirect labor, operations and maintenance, and overhead, is
estimated as $11.14 million for FY 2007. 

	Implementation of the new alternative fuels rule will be carried out by
existing staff. Other ongoing database management, oversight, and
certification activities are part of the fuel economy and emissions
program Agency baseline.  All EPA labor estimates are based on Office of
Personnel Management draft annual pay rates effective January, 2008,
with a 1.6 multiplier for overhead based on EPA’s latest fees cost
allocation study (1.37 indirect program cost overhead times 1.16 overall
EPA overhead).  This estimate does not include Agency burdens incurred
prior to the effective date of the rule, such as costs of developing the
rule and preliminary consultations with converters. 

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.  (Due to the diverse nature of the converter
industry, there is no typical or average respondent.)  

6(e) Bottom Line Burden Hours and Cost

(i)  Respondent Tally 

[a] Overall Emissions IC 

	This analysis is against the Emissions IC baseline in ICR 0783.54. EPA
has another rulemaking underway (Revisions to Reduce Emissions of
Greenhouse Gases; EPA ICR 0783.56) which will result in other changes.

[1] Existing authorization

RESPONDENTS	35

BURDEN HOURS	362,033

LABOR COST	$6,308,800

OPERATING COST	$5,929,702

CAPITALIZED COST	$2,256,127

TOTAL NON-LABOR COST	$8,185,829

[2] After proposal

RESPONDENTS	35

BURDEN HOURS	340,091

LABOR COST	$5,054,396

OPERATING COST	$5,763,511

CAPITALIZED COST	$2,233,795

TOTAL NON-LABOR COST	$7,997,306

[3] Reduction in burden

BURDEN HOURS	-21,997

LABOR COST	-$1,254,404

OPERATING COST	-$166,191

CAPITALIZED COST	-$22,332

TOTAL NON-LABOR COST	-$188,523

[b] Alternative Fuels Converters

[1] Existing baseline

RESPONDENTS	5

FAMILIES	36

BURDEN HOURS	29,738

LABOR COST	$1,756,606

OPERATING COST	$243,082

CAPITALIZED COST	$32,630

TOTAL NON-LABOR COST	$275,712

[2] After proposal

RESPONDENTS	5

FAMILIES (75% OF 18)	14

BURDEN HOURS	7,796

LABOR COST	$502,202

OPERATING COST	$76,891

CAPITALIZED COST	$10,298

TOTAL NON-LABOR COST	$87,189

[3] Reduction in burden

BURDEN HOURS	-21,942

LABOR COST	-$1,254,404

OPERATING COST	-$166,191

CAPITALIZED COST	-$22,332

TOTAL NON-LABOR COST	-$188,523

[4] Reduction in burden applied to a hypothetical pre-proposal 18 family
baseline

BURDEN HOURS	-7,073

LABOR COST	-$376,101

OPERATING COST	-$44,650

CAPITALIZED COST	-$6,017

TOTAL NON-LABOR COST	-$50,667

(ii)  Agency Tally

EMPLOYEES	47.5

CONTRACT LABOR COST	$0.27 million

COST	$11.1  million

6(f) Reasons for change in burden

	The burden change is from changes in the baseline number of test groups
and reductions in the capital and operations and maintenance costs and
labor hours associated with implementing the new programs detailed in
this draft ICR.

6(g) Burden Statement

	The table in Section 6(e)(i)[b][2] presents the total estimated burden
for the alternative fuels conversion light-duty program after the
proposed rule: approximately 7,796 hours per year, with total annual
capitalized and O&M costs estimated at $87,189. These represent a
savings of 21,942 hours and $188,523 over the existing alternative fuels
light-duty baseline. The annual costs and hours for information
collection activities by a given manufacturer under any of the options
in this proposed rule depend upon manufacturer-specific variables, such
as the number of different test groups and the number of vehicles
tested.  The estimated number of likely respondent manufacturers is 5. 
The responses will be submitted annually and occasionally as a part of
the existing EPA certification program.  

	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.

	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 rule, which includes this
ICR, under Docket ID number EPA-HQ-OAR-2009-0299.  Submit any comments
related to the ICR for this proposed rule to EPA and OMB.  Submit your
comments, identified by Docket ID No. EPA-HQ-OAR-2009-0299, by one of
the following methods:

	•	www.regulations.gov: Follow the on-line instructions for submitting
				comments.

	•	Fax:  (202) 566-1741.  

	•	Mail:  Environmental Protection Agency, EPA Docket Center (EPA/DC),
Air 		and Radiation Docket, Mail Code 6102T, 1200 Pennsylvania Avenue,
N.W., 			Washington, DC 20460, Attention Docket ID No.
EPA-HQ-OAR-2009-0299.  		In addition, please mail a copy of your
comments on the information 				collection provisions to the Office of
Information and Regulatory Affairs, 			Office of Management and Budget
(OMB), Attn: Desk Officer for EPA, 725 			7th St. NW., Washington, DC
20503.”

	•	Hand Delivery: Docket Center, (EPA/DC) EPA West, Room B102, 1301 		
Constitution Ave., NW, Washington, DC., Attention Docket ID No. OAR-		
2009-0299.  Such deliveries are only accepted during the Docket’s
normal 			hours of operation, and special arrangements should be made
for deliveries 			of boxed information  

  SEQ CHAPTER \h \r 1 Docket ID No. EPA-HQ-OAR-2009-0299, 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 also (202)
566-1744.  An electronic version of the public docket is available
through EPA Dockets (EDOCKET) at   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov .

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