Final

Supporting Statement

for

Information Collection Request

Motor Vehicle Emissions:

Revisions to Certification of Alternative Fuels Conversions 

EPA ICR 0783.59

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 0783.59, OMB control number 2060-0104.

1(b) Short Characterization/Abstract

	The Environmental Protection Agency is finalizing a rule that is
designed to simplify and lessen the burdens for conversion 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 rule. 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
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
or medium-duty vehicles and trucks or upon the effective date of the
final rule.  Starting then, manufacturers will be given expanded options
for submitting a simplified notification process in some cases. 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 previous alternative fuels conversion
program consisted 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 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 by conversion
manufacturers such as contracts by converters with testing companies,
which include overhead, profit and possibly compliance 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, whereas the ICR attempts to generalize the
analysis to the industry as a whole. 

	The existing baseline estimates that certification applications for 36
test groups from five converter respondents are submitted annually.
During the proposal phase of this rule, the most recent model year data
available (model year 2008) showed 18 light-duty vehicle conversions,
and the draft ICR (0783.55) baseline was adjusted accordingly. However,
the number of certificates steadily increased in 2009 and 2010.  In
2010, there were 42 new certificates issued for 7 different conversion
manufacturers. Following this upward trend, this ICR adjusts the
baseline to 50 new conversions from 8 conversion manufacturers and
calculates industry savings against that number. The adjusted baseline
also assumes 50 carryover applications. The analysis also gives the
change in the 0783 ICR overall collection with the adjusted baseline
after savings. 

	These test groups consist of conversion systems that apply to a
specific certified OEM (original equipment manufacturer) vehicle test
group, or in some cases combinations of OEM test groups. 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  fuel conversion 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 final rule are
discussed in Section 6.) 

	The current baseline program costs applied to 50 new test group
applications estimates an industry total paperwork cost of $380,828. 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
alternative 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 (ICR 2080;
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 age 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 age
vehicles will be not be certified but audited through reporting of a
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 is finalizing a requirement for
information submission demonstrating that the conversion is technically
viable and will not increase emissions. 

	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 $195,735 in non-labor costs and 23,267
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 May 26,  2010, 75 Federal Register 29606; a copy can be
found at   HYPERLINK "http://www.regulations.gov"  www.regulations.gov 
under docket EPA-HQ-OAR-2009-0299. The draft ICR was placed in the
docket. No comments were received.

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. 
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 ( at 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 normally possible.  However, this rule would replace the annual
application process with a one-time submittal for intermediate age and
outside useful life vehicles, only requiring an end-of-year sales volume
submission. In addition many conversion manufacturers will no longer
need to renew their certificate of conformity; if the OEM vehicle design
is “carried over” to a subsequent model year, the amount of new
information required is substantially reduced or eliminated.  

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’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 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 

renewal application for certificates for “carryover” test groups is
optional

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 and for intermediate-age vehicles
an OBD scan tool report 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 may be repeated for
each conversion model year, although  previous data and information may
be “carried over” when no changes have occurred. Carryover,
intermediate and outside useful-life test group manufacturers will
continue to be subject to the end-of-model-year sales reporting through
the same existing Verify reporting module that applies to their new test
groups. 

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

	Many conversion manufacturers  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 “conversion model
year” that a manufacturer intends to convert vehicles. Under the final
rule, only the newest vehicles will be required to renew annually, if a
new certificate is desired, 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 greenhouse
gasses rule (ICR 2387.01).  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 as well as a recent upward
trend. 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 predict 50 new light-duty
conversion test groups for Model Year 2011. The Emissions IC will
reflect this adjustment. The discussions below compare the burdens on 50
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 outside
useful-life conversions. As converters are a very small subset of the
current light-duty baseline (prior to this ICR, 36 out of 427 families,
after this ICR, 50 reduced to 38 out of 429), the decrease in burden is
correspondingly small; but for vehicle converters the hour savings are
significant (from 41,802 hours down to 18,535 hours, a savings of over
45% (23,267 hours). 

	In particular, the number of test groups requiring any reporting under
this rule is estimated to be reduced by at least 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 age and outside 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 next renewal of the ICR will likely update
this figure. 

(ii) Estimating 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 (about
$50 for intermediate- age OBD scan tool test) 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 $380,828 annually. The revised
regulation reduces this figure by $195,735, to $185,093. This is
primarily due to 1) reduction in the number of test groups by at least
25%; and 2) savings of $1,750 in NMOG and HCHO testing per test group. 

(iii)  Start-up and Other Capital 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. 

	Startup costs are included for redesign of 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 50 test
groups, reduced to 38 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 this ICR series estimates 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 0783 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 $318,333 are reduced by $146,400 to
$171,933.  

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 recent rulemaking (Revisions to Reduce Emissions of
Greenhouse Gases; EPA ICR 2387.01) 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 final rule

RESPONDENTS	38

BURDEN HOURS	350,830

LABOR COST	$5,612,,466

OPERATING COST	$5,848,800

CAPITALIZED COST	$2,247,926

TOTAL NON-LABOR COST	$8,096,726

[3] Change in burden

BURDEN HOURS	-11,203

LABOR COST	-$696,334

OPERATING COST	-$80,920

CAPITALIZED COST	-$8,201

TOTAL NON-LABOR COST	-$89,103

[b] Alternative Fuels Converters

[1] Existing baseline

RESPONDENTS	5

FAMILIES	36

BURDEN HOURS	29,738

LABOR COST	$1,756,606

OPERATING COST	$241,566

CAPITALIZED COST	$32,630

TOTAL NON-LABOR COST	$274,196

[2] After final rule

RESPONDENTS	8

FAMILIES (75% OF 50)	38

BURDEN HOURS	18,535

LABOR COST	$1,060,272

OPERATING COST	$160,664

CAPITALIZED COST	$24,429

TOTAL NON-LABOR COST	$185,093

[3] Change in burden

BURDEN HOURS	-11,203            

LABOR COST	-$696,334

OPERATING COST	-$80,920

CAPITALIZED COST	-$8,201

TOTAL NON-LABOR COST	-$89,103

[4] Reduction in burden applied to 50 families without final rule
changes

BURDEN HOURS	-23,267

LABOR COST	-$1,408,994

OPERATING COST	-$174,845

CAPITALIZED COST	-$20,890

TOTAL NON-LABOR COST	-$195,735

(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, a reduction in the number of test groups after accounting for
this baseline change, and reductions in the capital and operations and
maintenance costs and labor hours associated with implementing the new
programs detailed above.

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 final
rule: approximately 18,535 hours per year, with total annual capitalized
and O&M costs estimated at $185,093. These represent a savings of 11,203
hours and $89,103 over the existing alternative fuels light-duty
baseline, notwithstanding application of program costs to an increased
number of manufacturers and test groups. 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 8.  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 .

 PAGE   

 PAGE   7 

