Supporting Statement

for

Information Collection Request

Emissions Certification and Compliance Requirements for Nonroad
Compression-ignition and On-highway Heavy Duty Engines 

(Final Rule for Alternative Fuel 

Conversions of Heavy-Duty Engines)

EPA ICR 1864.17

OMB Control Number 2060-0287

February 2011

Compliance and Innovative Strategies Division

Office of Transportation and Air Quality

Office of Air and Radiation

U.S. Environmental Protection Agency

1.	Identification of the Information Collection

1(a) 	Title And Number Of The Information Collection	 

	Emissions Certification and Compliance Requirements for Nonroad
Compression-ignition and On-highway Heavy Duty Engines (Final Rule for
Clean Alternative Fuel Conversions of Heavy-Duty Engines); EPA ICR
number 1684.17, OMB Control Number 2060-0287.

1(b) 	Short Characterization/Abstract

	The Environmental Protection Agency is finalizing 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
heavy-duty portion of the final rule.  The proposed rule was submitted
under EPA ICR Number 1684.15.

	These changes would start taking effect with the 2011 conversion model
year 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. 

Under previous iterations of this ICR, EPA analyzed the cost of
obtaining a certificate of conformity under current regulations and used
that as a baseline cost.  This Supporting Statement addresses only the
anticipated paperwork burden of the Clean Alternative Fuel Vehicle and
Engine Conversions final rule in relation to the existing baseline.
Also, it should be noted that this Supporting Statement amends the
Supporting Statement submitted in May 2010 (under EPA ICR Number
1684.15) by replacing the OBD requirement for intermediate-age and
outside-useful life conversions with the procedure already established
in 40 CFR 85.2222.  

It is important to note that HD conversions have not received as much
interest as LD conversions.   As a result, EPA’s experience with and
data available on HD conversions is limited.  For example, in model year
(MY) 2008, EPA only received seven certification applications from four
different converters. In 2009, the number drop to three applications
from three different manufacturers. Despite limited historical data on
HD conversions, EPA has evaluated the cost a converter would incur to
fully certify a HD engine that has been converted at each of the three
engine age categories offered in this rulemaking: (1) beginning of
useful life, (2) mid-useful life, and (3) outside the useful life. 
These costs are then compared to the baseline -- the current cost of
certification. 

	

	It has been estimated that a total of 8 manufacturers will respond to
this collection (proposed rule only) with an approximate cost of
$757,468. 

Section 2: Need For And Use of the Collection 

2(a) Need/Authority For The Collection

	Under Title II of the Clean Air Act (CAA, 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 CAA 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 were
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.  The modified
program will recognize two other age-based categories which permit an
exemption from the prohibition on tampering that does not result in a
certificate of conformity.

2(b) Practical Utility/Users of the Data

	EPA uses information to verify that the proper engine prototypes have
been selected and that the necessary testing has been performed to
assure compliance with emission standards. 

	EPA uses the information requested to support various enforcement
actions as mandated by the CAA.  This information collection enables EPA
to ensure that engine manufacturers are complying with applicable
emission regulations, measure the impact of engines' emissions on air
quality, and take corrective actions as needed.	

	The information will be received and used by HDNEG/CISD/OTAQ/OAR. 
Non-confidential portions of the information submitted to HDNEG is
available to and used by importers, environmental groups, members of the
public and local, state and federal government organizations. 

Section 3: Nonduplication, Consultations, and Other Collection Criteria 

3(a) Nonduplication

	The information requested under this ICR is required by statute. 
Because of its specialized (and sometimes confidential) nature, and the
fact that it must be submitted to EPA prior to the start of production,
the information collected is not available from any other source.  

 

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

	An announcement of the public comment period for this ICR renewal was
published in the Federal Register on May 26, 2010 (75 FR2 9606).  This
document may be accessed through the Federal Register's website at  
HYPERLINK "http://www.gpoaccess.gov/fr/index.html" 
http://www.gpoaccess.gov/fr/index.html .  

3(c) Consultations

	The burden estimates described in this ICR is based on the HD
certification program burden already approved by OMB under ICR 1684. 
EPA sought comment on these estimates through the FR notice mentioned in
Section 3(b).  The comments received dealt with the regulation itself
and are discussed in the preamble of the final rule.  No comments were
received regarding the estimates presented in this Supporting Statement.
 

As a result of the comments received, EPA has streamlined the way
converters can demonstrate compliance with OBD requirements.  Now EPA
will be accepting an OBD scan tool report and a statement about the
integrity of the OBD system in lieu of OBD test data or a description of
an OBD compliance strategy. This Supporting Statement reflects that
change.

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

3(e) General Guidelines

	According to 40 CFR 86.098-7, certification related records must be
maintained for eight years.  Note that "records may be retained as hard
copy or reduced to microfilm, ADP film, etc., depending on the
manufacturer's record retention procedure, provided that in every case
all the information contained in the hard copy is retained."  These
recordkeeping requirements stem, in large part, from the statutory
requirement to warrant some items for long periods of time.  In
addition, the manufacturers must comply with requirements to recall
vehicles and engines failing to meet emission standards during their
useful lives.

	Manufacturers are required to submit confidential business information
such as sales projections and certain sensitive technical descriptions
(Please see section 4(b)(i) for reference).  This information is kept
confidential 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.  Also, non-proprietary information submitted
by manufacturers for certification is held as confidential until the
specific vehicle or engine to which it pertains is available for
purchase. The non-proprietary information submitted to support
intermediate age and outside useful life submissions may be made
available once the notification has been submitted to EPA.

	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

	Manufacturers are allowed to assert a claim of confidentiality over
information provided to EPA.  Confidentiality is provided in accordance
with the Freedom of Information Act and EPA regulations at 40 CFR Part
2.  For further detail, refer to section 3(e).

3(g) Sensitive Questions

	No sensitive questions are asked in this information collection.  

Section 4: Respondents and Information Requested

4(a) Respondents/NAICS Codes

	Respondents are manufacturers of non-road engines within the following
North American Industry Classification System (NAICS) codes:

336312 Gasoline Engine and Engine Parts Manufacturing

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 and engine certification and
compliance programs.  Currently requested data items related to
heavy-duty engine certification are discussed in detail in ICR 1684.12. 
Converters seeking certification for engines converted at the beginning
of their useful lives are expected to go through current certification
procedures.  However, under the revised rule, the amount of information
collected from converters will be reduced due to the provision that will
allow the grouping of multiple engine families into a larger one. 
Currently, engine manufacturers and converters must submit one
certification application per engine family, as currently defined in the
regulations.  Under the revised rule, converters of new and nearly new
engines will be able to obtain one certificate for a group of engine
families.  Engine families must share certain characteristics before
they can be combined into a larger family.  This provision may reduce
converters reporting burden by up to 50%. 

Converters of intermediate age engines will be able to submit a
simplified testing demonstration without the burdens of the formal
certification application process. Intermediate age engine converters
will also benefit from not having to pay the certification fee currently
required under the authority of Section 217 of the CAA and the
Independent Offices Appropriation Act (31 U.S.C. 9701).   

Converters of engines outside their useful life will also benefit from a
reduced burden.  EPA sought comment from the public on the suitability
of three proposed options to provide adequate demonstration of
compliance. “Option 3” is being finalized which requires an OBD scan
tool test procedure report and a detailed technical description of the
conversion system sufficient in detail for EPA to confirm the conversion
system’s ability to maintain or improve on emission levels in the
converted engine. 

In general, all reporting formats will 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 following is a list of data items added or revised by the rule.  As
mentioned above, ICR 1864.12 lists the rest of the data items currently
required for certification and that would apply to converters of new and
nearly new engines applying for certificates of conformity.

For all engines: 

expanded  conversion engine families 

new engine label requirement describing OEM engine family, 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 “demonstration”
for intermediate age  and outside useful life conversions

OBD scan tool report showing results of an OBD scan tool test procedure 

A statement that the OBD system remains fully functional in the
converted engine.

Intermediate age and outside useful life engine families will not be
required to pay a certification fee.

	

(ii) Respondent Activities

	While there is no “typical” converter respondent, all converters
must submit a description of their product and other information.. As
described in Section 4(b)(i), in some cases the current application and
certification process will be replaced with an alternative, simpler
process for intermediate age and outside useful life programs. 
Converters of new and nearly new engines will carry-out the same
activities as other engine manufacturers currently seeking
certification. 

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

Agency Activities

	In general, EPA officials carry out the following activities:

Review and interpret regulations, provide guidance;

Review the applications for completeness and accuracy;

Verify that the correct engines have been selected and tested;

Verify compliance with applicable provisions;

Request additional information if needed;

Answer questions from manufacturers and the public;

Issue appropriate certificates of conformity, as applicable;

Periodically perform maintenance or enhance the database;

Make data available to the public;

Analyze and manage requests for confidentiality;

Determining if "carry over" of data from a previous model year is
appropriate or if new testing will be required; and

Store, file and maintain data.

5(b) Collection Methodology and Management

	EPA currently makes extensive use of electronic media in gathering and
evaluating information from engine manufacturers.  EPA expects to
receive the information submitted by converters in electronic format as
well.

	Once the information is received it will be entered into a database and
reviewed for completeness.  If the manufacturer chooses to make hard
copy submittals, then EPA manually enters the information into the
database.  The certification reviewer analyses the information to ensure
compliance with the CAA and applicable regulations.  

	Currently, the public can access non-confidential portions of the
certification applications and test data by contacting HDNEG or through
the Engine Certification Information Center at    HYPERLINK
"http://www.epa.gov/otaq/certdata.htm"  
http://www.epa.gov/otaq/certdata.htm .  Non-confidential certification
information submitted by alternative fuel converters will also be posted
at that website.

5(c) Small Entity Flexibility

	Small on-highway engine manufacturers may use optional procedures
outlined in 40 CFR part 86, subpart A to demonstrate compliance with the
general standards and specific emission requirements.  These procedures,
also available to HD converters, and apply to conversion manufacturers
with US sales of fewer than 10,000 units.  The alternate procedures
reduce small volume conversion manufacturers' burden associated with
durability data requirements, testing, determination of deterioration
factors and certification test data.  Converters may also request EPA to
assign deterioration factors, thus eliminating the durability testing
burden.

Small volume conversion manufacturers are also exempt from some
reporting and recordkeeping requirements associated to the certification
of evaporative families (86.098-14).

	EPA can also approve a reduction in the certification application fee
upon request by the manufacturer.  A fee waiver could be granted if: 
(1) the certificate is to be used to sell engines within the United
States; and (2) the full fee exceeds 1% of the aggregate projected
retail sales price of all vehicles covered by the certificate of
conformity.  Although this is a provision available to all
manufacturers, it is beneficial to some small manufacturers.  Section
6(b)(ii) provides more details.

5(d) Collection Schedule

	Collection of certification data (or demonstration data when
applicable) on a per engine family basis occurs on occasion.  Overall
collection frequency is largely determined by the converter's marketing
and product plans.  For all age-based categories, information must be
submitted before the start of production For new and nearly new
vehicles, a  certificate of conformity must be obtained before the start
of production. Manufacturers submit information, such as an end of year
sales report on an annual basis and will submit their applications for
certification and intermediate age and outside useful life notifications
at their earliest convenience.

	Running change and correction applications will be submitted by
manufacturers as the need occurs.  

Section 6: Estimating the Burden and Cost of the Collection

6(a) Estimating Respondent Burden (Hours)

	Since the current process for certifying an engine family will remain
basically unchanged for converted families, burden estimates were taken
from the previous supporting statement in this ICR series. Costs have
been updated and reflect the impact of the new, broader definition of
engine family by this rule. Tables 1 through 3 summarize the
respondents’ overall burden associated with this ICR.

6(b) Estimating Respondent Costs

Estimating labor costs

  SEQ CHAPTER \h \r 1 To estimate labor costs, EPA used the Bureau of
Labor Statistics' May 2008 industry specific occupational hourly wage
estimates for the Motor Vehicle Manufacturing Industry (NAICS 336100). 
EPA then increased the hourly wage estimates by a factor of 2.1 to
account for benefits and overhead.  The specific rates used are listed
below.  These are mean hourly rates.

  SEQ CHAPTER \h \r 1 Table 4

Labor Costs Estimates

Occupation	SOC Code Number	Mean Hourly Rate (BLS)	2.1 Factor for
Overhead and Benefits

Mechanical  Engineers	17-2141	$37.59 	$78.94 

Engineering Managers	 11-9041	$54.56 	$114.58 

Lawyers	23-1011	$67.14	$140.99 

Secretaries, Except Legal, Medical and Executive	43-6014	$19.76 	$41.50 



(ii) Estimating Capital and Operations and Maintenance Costs

	The Operation and Maintenance costs (O&M Costs) in this ICR look
somewhat different from those explained in the rule preamble.  The
language in the preamble considers the costs an individual converter may
incur in its effort to obtain exemption from the prohibition on
tampering via this regulation. Since conversion manufacturers can
sometimes “carry-over” test data from one model year to the next,
further cost reductions may be achieved. In this ICR, one time costs
such as testing have been annualized.

So far, all HD converters are small businesses.  EPA believes this will
still be the case after this rule is finalized.  Small businesses
contract outside laboratories to perform testing.  Therefore, there are
no capital start-up costs associated with this collection.

	EPA has estimated that testing at a private facility costs, on average,
$30,000.  Evaporative testing costs, on average, $7,050.  Testing cost,
however, is a one-time cost per engine family since manufacturers can
carry over emissions data from one model year to the next.  This cost
has been annualized over the approval period requested for this ICR (3
years).

Heavy-Duty and Large Nonroad CI:	$10,000

Evaporative testing:	  $2,350

	New and nearly new engines require certificates of conformity and
require a fee when submitting an application for a certificate of
conformity.  This fee is requested under the authority of the CAA
Section 217.  EPA published a revision to its 2010 schedule of fees in
the document CISD-09-05.  The relevant fees for calendar year 2010 are: 

Federal Exhaust Certificate:	$35,967

Evaporative-only:			     $511

	The fees rule provides for a reduction in fee when "the full fee
exceeds 1.0 percent of the projected aggregate retail price of all
vehicles or engines covered by that certificate" (69 FR 26226, Section
F).  The reduced fee must not exceed one percent of the aggregate retail
price of the vehicles and engines covered by the certificate.

Since all respondents are small businesses and no laboratories will be
built or modified to comply with the new rule, there are no capital
start-up costs associated with this collection.

	Other O&M Costs associated with this information collection include
CDs, photocopying, postage and other shipping expenses, calls, and
testing costs.  CDs may be  used by manufacturers to submit their
electronic applications and to keep records.

(iii)  Start-up Costs

Under the new clean alternative fuel conversions rule, converters of
intermediate-age and outside-useful-life engines will be able to
demonstrate compliance with OBD requirements by submitting an OBD scan
tool report.  Therefore, converters will need to acquire OBD scan tools.
 EPA has found that most OBD scan tools for HD trucks range vary widely,
depending on the size of the vehicle.  For smaller trucks (under 14,000
lbs), OBD scan tools range between $90 and $1,000.  The less expensive
ones are usually specific to a particular vehicle make and model.  For
trucks weighing between 14,001 lbs and 33,000 lbs, OBD scan tools range
between $1,300 and $2,500, but most cost around $1,500.  For the largest
trucks (over 33,000 lbs), scan tools cost as much as $8,000.   

In recent years, EPA has received alternative fuel conversion
applications only for truck engines below 14,000 lbs.  However, since
this rule streamlines and lowers the cost of complying with the
conversion regulations, EPA expects more businesses to venture into
clean alternative fuel conversions.  Therefore, it is plausible that
responders will seek to convert engines for heavier trucks.  For the
purpose of this ICR, EPA has chosen to use $1,500 as an estimate for a
scanning tool.  Since all respondents to this collection, especially
those converting intermediate-age and outside-useful-life engines, are
expected to be small business with limited production, EPA estimates
that respondents will purchase an average of three OBD scan tools in the
next three years.  

Many OBD scan tools have software specific to a certain range of models
and model years.  EPA estimates that converters may need to purchase
software updates at least once in the three-year period covered by this
ICR.  The cost of these updates range between $300 and $800.  EPA will
use the average, $550, to estimate capital costs.

Total costs per respondent, annualized over a three year period, are:

OBD scan tool for HD engines		$1,500  

Software updates for new models		$183

(iv)  Annualizing capital costs

EPA has used the period covered by this ICR to annualize the cost of the
OBD scan tool and software updates.

 

6(c) Estimating Agency Burden

	Table 5 summarizes EPA's overall additional burden associated with the
rule.  Table 6 below summarizes EPA's labor.  These costs are based on
2010 hourly wage rates obtained from the Office of Personnel Management
and adjusted by a factor of 1.6 to account for benefits and overhead. 

Table 6

Agency Labor Costs

Occupation	Hourly Rate	160%

Engineer (GS-13/10)	$55.46 	$88.74 

Lawyers (GS-13/10)	$55.46 	$88.74 

Managers (GS-15)	$65.23 	$104.37 

SES-1	$99.00 	$158.40 

Senior ( SEE Program)	$13.81 	$20.72 (see text below) 



The salary of a senior from the Senior Environmental Employment (SEE)
Program for clerical support is $13.81 per hour plus approximately 150%
increase for benefits, for a total of $20.72.  EPA also pays $2,151.83
as an administrative fee to the Senior Services America, Inc., the
organization from which EPA’s SEE Employees are obtained. These data
were obtained from HDNEG’s financial officer.

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

Interest in HD conversions has been low in the past.  In model year
2008, EPA received only seven applications for certification from a
total of four converters; while in 2009, only three of those converters
submitted one application each.  EPA understands that this is in part
due to converters not submitting an application until they find a market
for the engines. The amount of engines in a HD engine family is
typically lower than the amount of engines in a LD test group.  Since
the cost of certification is spread over a smaller pool of engines, it
is more expensive to certify a HD family on a per engine basis.  This
fact discourages many companies from seeking certification for
heavy-duty products.

Based on the experience of EPA certification reviewers, the Agency
estimates that interest in heavy-duty conversions certification may
double as a result of the rule. This is due to the ability to combine
engine families into a larger group that could be certified as one
family with only one emissions test.  EPA estimates that eight
converters will seek certification for 12 converted heavy-duty engine
families (under the new, expanded definition) in the rule.

	Since the process for demonstrating emission requirements differ
depending on the age of the engines being converted, EPA has accounted
for each stage separately.

New and Nearly New Engine Conversions

Converters of new and nearly new engines must seek full certification.
There are three distinct costs these converters will incur. 

Exhaust emissions certification: Table 1 summarizes burden and costs for
exhaust certification of these families.  

Evaporative emissions certification: Converters will also need to obtain
a certificate of conformity with evaporative emission requirements. 
Table 2 summarizes costs and burden associated with evaporative
certification. 

OBD compliance demonstration.

Currently, alternative fuel converters are required to submit test data
to demonstrate compliance with OBD regulations.  However, 40 CFR
86.010-18(o) provides exemptions for small volume and alternative fueled
engines used in applications over 14,000 lbs.  All HD converters who
have sought EPA certification in recent years have been able to claim
one of these exemptions.  

In an effort to also reduce costs for those HD manufacturers who are not
able to claim this exemption, EPA is accepting approval issued by either
the California Air Resource Board (CARB) or the EPA Light-duty (LD)
Certification Program as proof of compliance.  Manufacturers must
demonstrate how the OBD system they have designed to comply with
California OBD requirements also complies with the intent of federal
requirements.  So far, HD manufacturers have been able to either claim
the exemption or submit approval from CARB or the LD Team. Therefore,
EPA does not have historical data to use as basis for OBD demonstrations
specifically related to HD conversions. 

 Based on past experience with both HD engine and conversion engine
certification, EPA estimates that all converters will be able to use one
the provisions described above to avoid the cost of HD OBD compliance
through the period covered by this ICR.  The cost of LD OBD compliance
demonstration is already accounted for in ICR series 783.

If we needed to account for these costs now, EPA considers it
appropriate to adopt for HD the estimates developed by the LD program
described in ICR 783.55: $26,317.

Intermediate age Engine Conversions

Under the final rule, converters of intermediate age engines will be
required to gather and submit all required data, including test data. 
However, the rule does not require EPA to issue a certificate of
conformity for intermediate age engines.  Instead, the Agency will
collect the data and audit it from time to time.  In addition, to
demonstrate compliance with OBD requirements, converters of
intermediate-age engines will need to submit a print-out of the OBD scan
results (per the procedure already established in 40 CFR 85.2222) and
attest that the OBD system remains fully functional in the converted
engine.  EPA will not issue a certificate of conformity, and fees will
not be collected.

As a result, the cost of testing for intermediate age engine conversions
will be the same as for new and nearly new engine conversions with the
exception of fees and OBD demonstration costs.  Table 3 shows these
costs and burden.

EPA believes that there is little interest in intermediate age engine
conversions. Therefore, EPA has estimated that two manufacturers will
participate in the intermediate age program for one engine family each.

	iii. Outside-useful life conversions

After careful evaluation of comments received, EPA has decided to adopt
Option #3 of the proposed rule for outside useful life conversions. 
This approach requires manufacturers to submit a technical description
of the conversion that provides sufficient detail for EPA to evaluate
emissions performance and durability. In some cases this technical
description may need to include emission test data to demonstrate that
the conversion system will not degrade emissions. Conversion
manufacturers must also submit an OBD scan tool report.

EPA would expect the maximum testing costs for this option to be
equivalent to those costs incurred for intermediate age engines, since
conducting all testing required for the intermediate age engine program
would be an acceptable demonstration of good engineering judgment.  
Intermediate-age engine conversions must also submit an OBD scan tool
report.

Based on past experience, EPA does not expect to have any respondents
interested in outside-useful-life conversions.  Therefore, no burden is
allocated for these conversions in this ICR.

6(e) Bottom Line Burden Hours and Cost

(i)  Respondent Tally 

Table 6

Total Estimated Respondent Burden and Cost Summary

Program (Age of Converted Engine)	Number of Respondents	Number of
Activities	Total Hours Per Year	Total Labor Cost Per Year	Total Annual
Capital Costs	Total Annual O&M Costs	Total Costs

 	 	 	 	 	 	 	 

New and Nearly New Exhaust Cert	8	12	1,002	 $   86,279 	       -   	 $
562,744 	 $  649,023 

New and Nearly New Evaporative Cert	8	8	354	 $   29,177 	       -   	 $ 
 34,408 	 $    63,585 

Intermediate Age	2	12	222	 $   19,622 	$3,366	 $   21,871 	 $    44,860 

Outside Useful Life	              -   	             -   	              -
  	                -   	       -   	               -   	               
-   

Total:	8	32	1,578	 $  135,078 	      $3,366	 $ 619,023 	 $  757,468



(ii)  The Agency Tally

Table 7

Total Estimated Agency Burden and Cost Summary

Program (Age of Converted Engine)	Number of Respondents	Number of
Activities	Total Hours Per Year	Total Labor Cost Per Year	Total Annual
Capital Costs	Total Annual O&M Costs	Total Costs

 	 	 	 	 	 	 	 

All programs	8	12	3,101	 $  237,382 	 $        -   	 $  604 	 $ 237,986 



6(f) Reasons for change in burden

	The burden described in this ICR adds to the existing inventory for
this ICR series.  This increase is due to the expected increase in
respondents as well as increased capital start-up costs. 

6(g) Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is, on average, 197 hours per respondent
(1,578 total hours/8 respondents).  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 ICR under Docket ID number
EPA-HQ-OAR-2009-0299, which is available for online viewing at  
HYPERLINK "http://www.regulations.gov"  www.regulations.gov , or in
person viewing at the Air And Radiation Docket in the EPA Docket Center
(EPA/DC), EPA West, Room 3334, 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)
566-1742.  An electronic version of the public docket is available at
www.regulations.gov.  This site can be used to submit or view public
comments, access the index listing of the contents of the public docket,
and to access those documents in the public docket that are available
electronically.  When in the system, select “search,” then key in
the Docket ID Number identified above.  Also, you can send comments to
the Office of Information and Regulatory Affairs, Office of Management
and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk
Officer for EPA.  Please include the EPA Docket ID Number
EPA-HQ-OAR-2009-0299 and OMB Control Number 2060-0287 in any
correspondence.

 PAGE   

 PAGE   14 

