  SEQ CHAPTER \h \r 1 

Supporting Statement

for

Information Collection Request

Information Requirements for Importation of Nonconforming Vehicles
(Renewal)

EPA ICR 0010.12

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 OF THE SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

1. IDENTIFICATION OF THE INFORMATION COLLECTION

    (a)  TITLE OF THE INFORMATION COLLECTION

Information Requirements for Importation of Nonconforming Vehicles
(40CFR Part 85, Subparts P and R) (Renewal), EPA ICR Number 0010.12, OMB
Control Number 2060-0095

     (b)  SHORT CHARACTERIZATION (ABSTRACT)

     The Clean Air Act requires motor vehicles and engines imported into
the U.S. to conform to applicable emission requirements.  This
Information Collection Request (ICR) covers importation reporting
requirements for light-duty vehicle, light-duty truck, and on-road
motorcycle vehicles and engines. The information collection instruments
are Form 3520-1 ("Form 1") for initial entry, and Form 3520-8 ("Form 8")
for final entry (see below). All heavy-duty on-road and all non-road
vehicle and engine importation reporting requirements are now covered by
ICR 1723 (OMB 2060-0294). The two programs use separate forms, have
differing regulatory provisions, and are processed by differing staffs.
Most importers are also required to apply for and obtain a certificate
of conformity from EPA; that information burden for the light-duty and
motorcycle certification program is covered by ICR 0783 (OMB 2060-0104).
 There is some program overlap between the present ICR and 0783 because
testing for Independent Commercial Importers (ICIs) is reported both on
Form 8, covered by this ICR, and, initially and in more detail, for
certification purposes, via ICR 0783. (Similarly, all importing
light-duty vehicle and motorcycle manufacturers, and not just ICIs, use
Form 1.) Thus, the certification information burden is covered in ICR
0783 and the (different and less detailed) testing burden for imports
subsequent to certification for ICIs in this ICR. 

     The burden of submitting the fee and associated forms is covered by
ICR 2080 (OMB 2060-0545). 

     The post-certification, final-entry testing burden for light-duty
vehicle imports falls into two categories. For the category of certified
light-duty ICIs, a city test (the “FTP”) is required for every third
vehicle imported under a certificate for the first 300 vehicles
imported, and every fifth thereafter (40 CFR 85.1505). The second
light-duty imports category is “mod and test”, which applies to
vehicles whose original production year is six or more prior to the year
of importation. Each such vehicle must be modified to meet applicable
emissions requirements and tested with the FTP (40 CFR 85.1509). In the
first category, each FTP test will be accompanied by a two-hour
evaporative emissions test, and in both categories, by a highway test in
order to compute a combined fuel economy number to comply with fuel
economy requirements. Form 8 includes spaces for reporting the test
results and combined fuel economy for those vehicles that undergo them. 
A very limited number of nonconforming motorcycles have been imported in
the last three years.  Most are imported under a provision (40 CFR
85.1505(a)(2)(i)) that allows for no additional testing beyond the
original certification testing. Otherwise, testing requirements are the
same as those for light duty vehicles except that a highway test is not
required. 

     Most ICIs contract with a broker to do some of the imports process
and a testing laboratory to perform the necessary tests. The testing lab
also performs whatever modifications are necessary to bring the vehicle
up to certification standards. 

     The Compliance and Innovative Strategies Division  (CISD) in
EPA’s Office of Transportation and Air Quality collects information
and requires some recordkeeping to help insure that imported vehicles
and engines are brought into compliance with federal emission
requirements or that they qualify for exemption or exclusion from them.
“Nonconforming” refers to the vehicles and engines that are not
constructed to EPA certification standards and therefore must meet
various additional requirements, such as testing, prior to being
certified and available for sale in the U.S.  The information is also
used by the U.S. Customs Service (Customs), state regulatory agencies,
businesses, and individuals to verify whether or not vehicles are in
compliance.

    Information collected includes vehicle identification data, U.S.
Customs entry statements that such information is correct, and summary
emission test results.  The information is either stored in a computer
database, or retained in document form.  The information is used to
monitor compliance of imports and respond to inquiries from the public
concerning the compliance status of specific imported vehicles. This
information is collected on two forms (attached in ICRAS):

	EPA Form 3520-1.  This form is used by importers who are applying for
entry into the U.S. of light-duty vehicle, light-duty truck, and
motorcycle vehicles or engines, whether conforming, nonconforming,
exempt, or excluded.  The form identifies to all parties involved the
category of import and the requirements that are appropriate to that
category. The form goes from the importer or its agent (broker) to
Customs, which stamps the form and forwards it in batch to EPA. EPA
gathers the forms in Ann Arbor where they are logged and filed for
future reference.  The form is posted on EPA’s imports website,  
HYPERLINK "http://www.epa.gov/otaq/imports/index.htm" 
http://www.epa.gov/otaq/imports/index.htm  .

	EPA Form 3520-8. This form is used by ICIs to request “final
admission” of a nonconforming vehicle or engine upon their
certification that it has been brought into compliance with Federal
emission requirements. The form is held for fifteen days, during which
the ICI can not release the vehicle for sale or to its owner. This gives
EPA a chance to conduct any review or oversight, including confirmatory
testing, deemed necessary before the vehicle or engine is released. 

The EPA requests a waiver from posting the expiration date of the OMB
clearance on these forms. Because Form 1 is used by both Customs, EPA,
and importers, repeated uploadings to the imports website and revisions
to reflect expiration of the clearance deadline, continuation of
clearance pending review, and the new expiration date may be burdensome,
with the existence of revisions inadequately communicated to users. Form
8 has a limited number of users who in the past have had to be
individually contracted to inform them of substantive updates. Posting
of Form 8 on the imports website is currently under consideration. Both
forms have been in use for many years and importers are familiar with
their features. 

     The information collection will involve an estimated yearly 12,352
responses from 12,005 respondents at an Operations & Maintenance (O&M)
cost of $90,894, a capital cost of  $73,353, and a labor cost of
$370,803 (see Table 1 below).

2.   NEED FOR AND USE OF THE COLLECTION

(a)  NEED/AUTHORITY FOR THE COLLECTION

     Joint EPA and Customs regulations at 40 CFR 85.1501 et seq., 19 CFR
12.73,  and 19 CFR 12.74, promulgated under the authority under the
Clean Air Act (Sections 203 and 208), give authority for the collection
of the information.  The collection helps insure compliance of imported
vehicles and engines with federal emissions requirements, which helps
meet the Agency goal of reducing air pollution.  Without this
information, EPA and Customs officials could not confirm that imported
vehicles and engines conform to U.S. emission requirements, and
consequently would not be able to allow importation or sale of these
vehicles and engines.

     (b)  PRACTICAL UTILITY/USERS OF THE DATA

     The information on Form 1 and Form 8 is used by Customs and/or
Agency  personnel to verify that all Federal emission requirements (or
exemptions or exclusions thereto) concerning imported nonconforming
light-duty motor vehicles and motorcycles are met.  The information is
also used to identify and prosecute violators of the regulations and to
monitor the program in achieving the objectives of the regulations. It
is also used to answer public inquiries concerning the compliance or
exempted or excluded status of particular motor vehicles. Public access
to this information is not direct but rather through  the EPA’s
imports section and the Automotive Imports Helpline in order to maintain
security of information protected under the Privacy Act. 

3.  NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

     (a)  NON-DUPLICATION

     A search of the Government Information Locator System (GILS) found
no other program or agency collecting this information. As explained
above, Form 1 is necessary to identify, at the point of importation, the
applicable category of the vehicle or engine for regulatory purposes;
Form 8 is necessary to report test results to EPA (where required) and
alert it of pending release to the owner. As stated on Form 1, vehicles
that are primarily manufactured for use on public roads are also
required to file an HS-7 Declaration Form to identify the basis for the
vehicle’s admission under the laws administered by the Department of
Transportation (DoT). EPA had discussions with the DoT in late 2005 that
considered whether a combined form would be feasible, and the conclusion
was that a single form was not practical at this time because of the
unique requirements of each program and the different agencies
administering them.  

     (b)  PUBLIC NOTICE

     A Federal Register notice was published, soliciting public comment
for this ICR on January 22, 2010 (75 FR 3723). A copy of the draft
Supporting Statement was also placed in the docket. No comments were
received.  

     (c)  CONSULTATIONS

     Consultations have been made with ICIs to discuss form revisions,
to update burden and cost estimates, and to receive suggestions about
the operation of the program.  The following ICIs were contacted:

Auto Enterprises, Inc.

850 N. Rochester Rd.

Clawson, MI  48017

Rep: Mr.  Philip Trupiano

Phone: (248) 723-6677

J.K. Technologies , L.L.C. 

3500 Sweet Air Street

Baltimore, MD  21211

Rep: Mr. Jonathan Weisheit

Phone: (410) 366-6332

Compliance and Research Services, Inc. 

1701 Front Street

Plainfield, NJ  07063-1066

Rep: Bob DePalma

Phone: (908) 561-1824

     (d)  EFFECTS OF LESS FREQUENT COLLECTION

                 Since reporting is done only at the time of initial and
“final” entry, the effects of less frequent collection would be to
seriously undermine the Agency's ability to determine whether vehicles
being imported meet applicable emission requirements. Consequently, the
Agency would not be able to allow entry of vehicles being imported. 
Therefore, less frequent collection is not feasible.

     (e)  GENERAL GUIDELINES

     This ICR requires that ICIs notify EPA when requesting final
admission for vehicles (Form 8) and this may occasionally result in
reporting more often than quarterly if vehicles are tested and ready for
sale more frequently than quarterly.  This requirement is necessary for
EPA to have the opportunity to inspect vehicles prior to release from
the ICI.  If EPA only required quarterly reports, either the ICI would
have to hold vehicles and release them on a quarterly basis or EPA would
not likely have the opportunity to inspect or require confirmatory
testing of vehicles imported by the ICI.

     EPA's regulations require that ICIs retain records for a period of
six years from the date of entry (40 CFR 85.1507(a)).  ICIs are
responsible for the same emissions warranties that apply to original
manufacturers, generally extending to 8 years or 80,000 miles for major
emission control components.  The Clean Air Act requires that light-duty
vehicles meet federal emission standards throughout their useful lives,
which is defined by the Clean Air Act to be either 10 years or 100,000
miles (Sec. 202(d)); these requirements are implemented through the
certification process for ICIs just as they are for original
manufacturers. The imports regulations specify that the useful life
period starts from the date that the vehicle is released to the owner by
the ICI.  The six-year record retention requirement is the minimum
considered consistent with these obligations.

                                                        

       (f)  CONFIDENTIALITY

      Any information submitted to the Agency for which a claim of
confidentiality is made will be safeguarded according to policies set
forth in Title 40, Chapter 1, Part 2, Subpart B - Confidentiality of
Business Information (CBI) (see CFR 2).  The public is not permitted
access to information containing personal or organizational identifiers.
 This collection complies with the Privacy Act of 1974 and OMB Circular
A-130.

      (g) SENSITIVE QUESTIONS

      There are no sensitive questions.

4.  THE RESPONDENTS AND THE INFORMATION REQUESTED

       (a)  RESPONDENTS/NAICS CODES

      The Light-duty Vehicle Group and Imports Team of CISD collect
information from individual importers and both small and large companies
that import light-duty vehicle, light-duty truck, and on-road motorcycle
vehicles or engines.  The NAICS code for respondents is: 1) 423110,
Automobile and Other Motor Vehicle Merchant Wholesalers; and 2) 441200,
Other Motor Vehicle Dealers. 

      (b)  INFORMATION REQUESTED

                           (i)  Data Items

     The data requested in reports include:

     - vehicle identification number

     - vehicle make

     - vehicle model

     - model year of the vehicle

     - port of entry

     - date of entry

     - entry number

     - importer name, address and telephone number

     - owner name, address, telephone number and SSN or EIN

     - emission test results

     - applicable EPA certificate of conformity

     - fuel economy

     - test date

     - modification date

     - name of emissions test laboratory

     - vehicle storage location

     - justification for an exclusion or exemption, if applicable and
records are maintained on:

     - documents related to certification, modification, importation,
storage, registration or                     emission testing

     - bills of sale, invoices, or purchase agreements

     - documents providing parts identification data associated with the
emission control system

     - documents providing evidence of the initiation of the "hold
period"

                           (ii) Respondent Activities

     To complete the collection, the respondent would:

      -read form instructions

      -collect data and complete forms

      -conduct required emission testing (ICIs only)

INFORMATION REQUIREMENTS FOR 

IMPORTATION OF NONCONFORMING MOTOR VEHICLES 

AND MOTOR VEHICLE ENGINES

(40 CFR PART 85, SUBPARTS P and R) (Renewal)

INFORMATION REQUIREMENTS      				CITATION

I. ICI requirements

- Reporting

- Application for final admission   					85.1505(a)

   (certified)

- Reasonable assistance during inspection, 					85.1506(c),(g)(4)

   including copies of records or documents 				85.1506(b)(2)

- Application for final admission   					85.1509(b)

   (modification/test)

- Repair and retest							85.1509(g)

- Maintenance instructions, attestation,  				85.1510(a)

   parts list

- Altitude compensator instructions, attestation 			85.1510(b)

- Emission warranties, attestation   					85.1510(c)

- Emission labeling, attestation   					85.1510(d)

- Fuel economy labeling, attestation  					85.1510(e)

- Gas guzzler tax forms, attestation  					85.1510(f)

- Reply to notice of suspension or  					85.1513(f)(3)(ii),

   revocation      							85.1513(f)(3)(iv)

   									85.1513(f)(6)

- Request for hearing    						85.1513(f)(3)(iii)

Recordkeeping

- Certification, modification, test, purchase, 				85.1507

   sale, storage, registration, importation     

- Owners or ultimate purchasers  					85.1508(b)

- Maintenance instructions, parts list,  				85.1510

   altitude compensator instructions, 

   emission warranties, emission labeling,

   fuel economy labeling

II. Requirements applying to all importers

- Notification of conditional admission  				85.1504(a)

- Request for prior approval (exemption), 				85.1511(b),(g)

   request for extension of exemption     

- Request for prior approval (exclusion)				85.1511(c)-(g)              
                                          

- Attestations, copy of paid invoice  					85.1512(f)

- Claim of confidentiality    						85.1514

5.  THE INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT

     (a)  AGENCY ACTIVITIES

     Form 1s  are collected as they are received from Customs and, in
some cases, from importers or their agents and collected by the Imports
Team; Form 8s are collected by the Imports Team and copies distributed
to certification staff; since late 2005 the data from Form 8 has been
entered into the Automated Imports Tracking System (AITS).  After
receiving the information, EPA uses it to determine whether vehicles
meet EPA requirements and whether to conduct investigations or require
confirmatory testing, and retains it in order to respond to public,
State government, and Federal government inquires.  In addition, ICI
applications for certification are now included in the “Verify”
information system, effective with the 2010 year imports. 

     (b)  COLLECTION METHODOLOGY AND MANAGEMENT

     Form 1 is available in fillable .pdf form downloadable from EPA's
imports website. Form 8 has recently been converted to fillable and
posting at the same site is under consideration. Forms are submitted to
EPA by the importer or its agent or Customs after being filled out at
the port of entry in the case of Form 1 and by the importer or its agent
in the case of Form 8. Both Customs and CISD use the information to
determine if vehicles meet EPA requirements.  CISD retains information
in the AITS and document form in order to respond to public, State
government, and Federal government inquires, which are handled by CISD
staff.

      (c)  SMALL ENTITY FLEXIBILITY

     Small entities that are required to submit information to EPA have
been doing so by completing and submitting EPA paper forms.  EPA
regulations provide, as an alternative, for submission of imports data
electronically (e.g. 40 CFR 85.1505(a), 85.1509(b) & (c)). Under EPA
guidance (CCD-02-04; (  HYPERLINK "http://www.epa.gov/otaq/cert/dearmfr/
dearmfr.htm"  http://www.epa.gov/otaq/cert/dearmfr/ dearmfr.htm ), ICIs
qualify per se as small volume manufacturers entitled to the special
provisions available to all certifying small manufacturers under EPA’s
certification regulations. As stated above, ICI certification activities
are now conducted electronically via “Verify”. Form 8s are currently
submitted electronically as email attachments or in paper form. 

      (d) COLLECTION SCHEDULE

      The information is not subject to a collection schedule, but is
collected at the time of vehicle entry and when the vehicle is ready for
final admission by EPA.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

      (a) ESTIMATING RESPONDENT BURDEN (HOURS)

     See the table below.  Each form is estimated to take 0.5 hours to
complete. Completing required post-certification testing is estimated at
28 hours per test. There is no requirement for importers to keep copies
of Form 1. Extra recordkeeping for Form 8s were formerly estimated at an
additional 0.5 hour per form; however, these recordkeeping burdens are
more appropriately attributed to the certification ICR, which will be
adjusted accordingly during the next renewal. There is no recordkeeping
burden associated with Form 8 other than adding it to the existing
records for the certified family.  

     (b) ESTIMATING RESPONDENT COSTS

(i) Labor Costs

     Labor costs are considered to be more closely approximated by the
motor vehicle manufacturing industry, NAICS 336100, than retail and
wholesale trades in vehicles that do not involve testing and
modification.   Rates for engineering managers, mechanical engineers,
and secretaries (except legal, medical, and executive) are from the May
2008 National Industry-Specific Occupational Employment and Wage
Estimates (http://www.bls.gov/oes/2008/may/naics4_336100.htm, accessed
December 10, 2009). With a 160% overhead multiplier, these are $87.30,
$60.40, and $30.50, respectively. Test labor costs are $55.82 per hour
based on ICR 0783.54. 

 (ii) Operations and Maintenance (O&M) Costs 

     Operations and maintenance costs apply only to Form 8 and  were
calculated based on responses received from the ICIs contacted.  The
Operations and Maintenance cost for reporting ordinarily involves a
purchase of services from a broker who complete a package of importation
forms (including those of other agencies) and files them with both
Customs and EPA.  This cost is estimated as a component of overall
broker activities to import a vehicle or engine, and incorporates a $2
per form paperwork cost for broker form handling within overall broker
activities, and a $3 per form mailing cost for Form 8s.  O&M costs
associated with testing are much less than those for certification
vehicles; post-certification vehicles do not have mileage accumulation
or durability demonstration requirements or consequent vehicle
depreciation; vehicle preparation is minimal.  O&M testing costs are
estimated at $651 per vehicle. Costs associated with modification of
vehicles necessary to bring them up to certification standards are
excluded: they are not reported on the imports forms, they vary widely
depending on the vehicle being imported, and they therefore can not be
predicted or accounted from one year to another; finally, they are
analogous to, for example, the costs of catalytic converters and other
emissions control technologies that original manufacturers are required
to install in vehicles in order to comply with the Clean Air Act, and
which are not included in the certification paperwork burden. 

                      

            (iii) Capital/Startup vs. Operations and Maintenance (O&M)
Costs 

              

Capital/Startup vs. Operation and Maintenance (O&M) Costs





 	O&M	Capital/Startup (unamortized)	Capital/Startup (amortized)	Total
Dep. Cap + O&M

Capital/Startup (unamortized)	Capital/Startup (amortized)	Total Dep. Cap
+ O&M

Filing







	Form 3520-1	$0 	0	$0 	$0 	$0 	0	$0 	$0 

Form 3520-8	$1,056 	0	$0 	$0 	$1,056 	0	$0 	$0 

Testing  	 	 	 	 

Form 3520-8	 	 	 	 	 	 	 	 

     Regular ICI	$62,496 	$358,400 	$51,028 	$113,524 	$62,496 	$358,400
	$51,028 	$113,524 

     Mod and Test	$27,342 	$156,800 	$22,325 	$49,667 	$27,342 	$156,800
	$22,325 	$49,667 

Total 	$90,894 	$515,200 	$73,353 	$164,247 	$90,894 	$515,200 	$73,353 
$164,247 



            (iv) Capital/Start-up Costs 

     Consistent with ICR 0783, a capital cost of $4,000,000 for a test
facility capable of conducting 750 combined FTP and highway tests per
year has been allocated on a per-test basis. Following ICR 2387.01,
which is the Light Duty Greenhouse Gases rule ICR, this is allocated 0.7
to the FTP portion. For ICIs, these test facility costs will in most
cases be covered by contractual costs between the importer and a testing
laboratory.      As mentioned above, these costs listed here are not
initial certification costs but the post-certification test costs for
additional imported vehicles. As with other ICRs, these capital costs
are annualized and subject to 7% interest depreciation but are
considered to be on-going rather than startup capital costs in the sense
that as facilities are depreciated they are continually being replaced. 

     (c) ESTIMATING AGENCY BURDEN AND COST

     The imports program is administered by EPA's Compliance and
Innovative Strategies Division (CISD). Forty percent of one Full Time
Equivalent employees (FTE), GS 12/3;  twenty percent of one Senior
Environmental Employment (SEE) Program employee (the SEE Program is an
employment program for older workers authorized by the Environmental 
Programs assistance Act, passed by Congress in l984, and provides
employment opportunities to senior citizens age 55 and over); and a
portion of the work assignment under a government contract  are
allocated to imports activities.  Government cost is based on a GS-12,
step 3 salary for professional engineers ($63,341 per year) obtained
from the Office of Personal Management 2009 Salary Table; and $15.53 per
hour for SEE employees, with a 1.6 multiplier for overhead applied to
both, yielding $40,538 and  Based on the 2006 GS pay schedule, EPA
estimates an hourly $34.35 for the FTE, then multiplies the hourly rates
by the standard government benefits multiplication factor of 1.6, at a
cost of  $45,728, and a cost of  $9,939 for the SEE;  $106,000 is
estimated for the contractor.  The contractor estimate is based upon the
work assignment rather than an estimate of hours. An estimated total
agency cost of $161,667 per year is therefore allocated to imports
activities.  These activities include both on-road imports (this ICR)
and nonroad imports (ICR 1723; OMB 2060-0320). An estimated 90% of these
activities currently involve on-road imports; consequently, $145,500 is
the estimate for the agency cost for purposes of this ICR.   

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

	In the previous renewal we estimated that 12,000 Form 1s are submitted
annually, averaging one respondent per form, and 352 Form 8s from five
ICIs, based on a hand count of Form 8s received in 2005 and 2006, plus
an estimate based on actual and projected imports from one high-volume
importer covering four original production years. The total number of
responses was therefore estimated as 12,352. The estimated number of
respondents was 12,005. 

	Both estimates are approximate and variable. For Form 1, our
information is that Customs does not require every importer subject to
the regulations at 19 CFR 12.73 to fill out the form; furthermore, the
forms that are forwarded to us by Customs or by importers may not
represent every form that is filled out. For Form 8, the number of ICIs
is small, the number of engine families certified is small, and the
number of vehicle imports within an engine family can vary widely. All
these factors add up to produce significant "small number fluctuations".
In 2005 there were 21 ICI families, including one high-volume importer
that greatly multiplied the number of FTP tests employed. In 2008 there
were 10 families, and without the high-volume importer. Consequently, to
insure that EPA has the authority to accommodate the possible level of
forms and tests needed under the collection authorization, we have
retained the numbers of forms and tests from the previous renewal. 

	For each engine family, one imported vehicle is used for certification
testing; therefore, while the forms count does not decrease, the testing
responses is decreased by the number of import engine families. For
model year 2005, 21 ICI engine families were certified; the count of 300
regular ICIs was reduced by 11 to total 289 vehicles subject to
post-certification testing; every third vehicle results in an estimate
of  96 tests; the total of 52 mod & test vehicles was reduced by 10
certification vehicles; the remaining 42 are subject to tests. 

           (e) Bottom Line Burden Hours and Cost

                (i) Respondent Tally

Respondents					                12,005	

Responses						    12,352				

Burden Hours						      9,350

Labor Cost						$370,803

Operating Cost					  $90,894

Capital Cost						$515,200

Capital Cost (Annualized, discounted)		  $73,353

Total (Annualized)					$535,050

                 (ii) Agency Tally

Employees						             2

Employee Labor Cost					  $50,100

Contract Labor Cost					  $95,400

Total Cost						$145,500

     (f) Reasons For Change In Burden

     This ICR follows the burden hours assumptions of the previous
renewal for filling out the forms themselves, as well as the testing
cost elements. The previous Supporting Statement and Federal Register
notices reported depreciated capital costs consistent with the treatment
in all other ICRs dealing with similar testing costs, but the authorized
burden requested was mistakenly based on un-depreciated capital costs;
correcting this results in a large reduction in the request without a
change in the underlying program. Other changes in burden reflect minor
improvements to the hour and cost estimates for these elements to
reflect information obtained for similar elements in intervening ICRs.
This has resulted in an increase in O&M costs, a decrease in capital
costs, and a decrease in hours associated with FTP tests.  The agency
and importer labor costs have been updated with more recent cost figures
for government and industry. The agency contract cost for the imports
program is down over $50,000 from the previous report.   

     (g) BURDEN STATEMENT

     Public reporting burden for this collection is estimated to average
45.4 minutes per response.  Burden means the total time, effort, or
financial resources expended by persons to generate, maintain, retain,
or disclose or provide information to or for a Federal agency.  This
includes the time needed to review instructions; develop, acquire,
install, and utilize technology and systems for the purposes of
collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information;
adjust the existing ways to comply with any previously applicable
instructions and requirements; train personnel to be able to respond to
a collection of information; search data sources; complete and review
the collection of information; and transmit or otherwise disclose the
information.  An agency may not conduct or sponsor, and a person is not
required to respond to, a collection of information unless it displays a
currently valid OMB control number.  The OMB control numbers for EPA's
regulations are listed in 40 CFR part 9 and 48 CFR Chapter 15.

To comment on the Agency's need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OAR-2009-0982.    Submit any comments related to the ICR for this
rule to EPA and OMB. Submit your comments, identified by Docket ID No.
EPA-HQ-OAR-2009-0982, by one of the following methods:  

   HYPERLINK "http://www.regulations.gov"  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-2009-0982. 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 3334, 1301
Constitution Ave., NW, Washington, DC., Attention Docket ID No.
EPA-HQ-OAR-2009-0982.  Such deliveries are only accepted during the
Docket’s normal hours of operation, and special arrangements should be
made for deliveries of boxed information  

Docket ID Number EPA-HQ-OAR-2009-0982, is available for public viewing
at the Air and Radiation Docket in the EPA Docket center (EPA/DC), EPA
West, Room B102, 1301 Constitution Avenue, NW, Washington, D.C.  The EPA
Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding legal holidays.  The telephone number
for the Reading Room is (202) 566-1744, and the telephone number for the
Air and Radiation Docket and Information Center is also (202) 566-1744.
An electronic version of the public docket is available at
www.regulations.gov.  

	

	.

Table 1:  Annual Respondent Burden and Cost --Information Requirements
for Importation of Nonconforming Vehicles (40CFR Part 85, Subparts P and
R) (Renewal)  

 Burden Item	Number Activities	Hours per Activity	Total Hours	Labor 

Filing

Form 3520-1	12,000	0.5	6,000	$183,000 

Form 3520-8	352	0.5	176	$10,630 

Testing 

Form 3520-8 

     Regular ICI	96	23	2,208	$123,251 

     Mod and Test	42	23	966	$53,922 

Total 	12,352	0.5	9350	$370,803 



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