 1 Supporting Statement for Information Collection Request Motor Vehicle Emission and Fuel Economy Compliance; Light Duty Vehicles, Light Duty Trucks and Motorcycles EPA ICR 0783.42 March 2001 Certification and Compliance Division Office of Transportation and Air Quality Office of Air and Radiation U. S. Environmental Protection Agency  2 Part A SUBMISSION Section 1: Identification of the Information Collection 1( a) Title and Number of the Information Collection Motor Vehicle Emission and Fuel Economy Compliance; Light Duty Vehicles, Light Duty Trucks and Motorcycles. EPA ICR number 0783.42, OMB control number 2060 0104.

1( b) Short Characterization/ Abstract Beginning with the 1968 model year, the Federal Government has regulated air pollution emitted by motor vehicles. While light vehicles ( passenger cars and light trucks) were the first to be regulated, other classes ( e. g. motorcycles) were subsequently included. The first phase of regulation consisted of prototype certification; manufacturers demonstrated that a particular design met applicable requirements and they received a " certificate" ( license) allowing that design to be sold. EPA expanded the compliance program to include assembly line and in use testing. Vehicles failing to meet requirements in use would be subject to recall and repair by the manufacturer. During these three decades of emission control, considerable progress has been made in reducing vehicular air pollution. A new passenger car today will emit much less than one tenth the exhaust pollution of its uncontrolled predecessor.

During the 1973 oil embargo, there was a need for improved automotive fuel economy information. EPA was able to fulfill part of this need using information collected during its emission testing program. ( To determine the mass of pollution emitted, the quantity and composition of a vehicle's exhaust must be determined. Using that information, the quantity of fuel consumed can be calculated.) This limited information was expanded by adding a " highway" driving schedule and by implementing a voluntary program whereby vehicle manufacturers tested and submitted information on a more complete spectrum of their product line. ( Because the emission certification program emphasized " worst case" vehicles, it might not accurately reflect a manufacturers entire product line. Hence the need for additional information.) Congress subsequently enacted legislation mandating fuel economy labeling, establishing average fuel economy standards and imposing Gas Guzzler Taxes. Those activities all rely on information generated under EPA's emission compliance and fuel economy programs.

This ICR covers EPA's combined emission compliance and fuel economy programs. Not only do these programs share a common test procedure, they also rely, in large part, on the same information and are administered by the same staff. Developing separate estimates would not be practicable due to this integration.

This ICR covers the application ( and supporting test results) submitted by vehicle manufacturers prior to production. It also covers a much more limited amount of information required when EPA  3 conducts surveillance testing on in use vehicles. In addition, manufacturers are required to submit fuel economy reports for vehicles covered under the Energy Conservation and Policy Act. EPA's processing of this information is conducted by the Certification and Compliance Division, Office of Transportation and Air Quality, Office of Air and Radiation.

Information collected consists of descriptions of motor vehicles ( with emphasis on emission control systems), test results and sales information. This data is reviewed to verify that necessary tests have been performed, the manufacturer's product line meets emission standards and fuel economy reports are accurate. This information is used by EPA as well as the Internal Revenue Service ( gas guzzler taxes), Department of Energy ( Fuel Economy Guides) and the Department of Transportation ( Corporate Average Fuel Economy standards). Descriptive information is submitted on optical disc ( smaller manufacturers may use paper submissions); it is made available to interested parties upon request. Test results are typically submitted in an " electronic" format for inclusion in EPA's computer database. Fuel economy ratings and emission test information is available on the Internet.

Approximately 70 passenger car, light truck and motorcycle manufacturers submit applications each year to certify their products. The motor vehicle emission and fuel economy compliance programs will impose a cost of about $ 51.5 million annually on the regulated industries.

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 which comply with applicable emission standards. A manufacturer must have a certificate before vehicles may be legally introduced into commerce. Similar provisions in the Energy Policy Conservation Act ( codified as Title III of the Motor Vehicle Information and Cost Savings Act, 15 U. S. C. 2001 et. seq.) require fuel economy ratings to be determined and vehicles to be labeled. To ensure compliance with these statutes, EPA reviews product information and manufacturer test results; EPA also tests some vehicles to confirm manufacturer results. Information is also shared with other agencies; Internal Revenue Service for Gas Guzzler Taxes and the Department of Transportation for Corporate Average Fuel Economy ( CAFE) requirements.

EPA's emission compliance and fuel economy programs are statutorily mandated; the Agency does not have discretion to cease these functions. Under Section 206( a) of the Clean Air Act ( 42 U. S. C. 7525) " . . . The Administrator shall test . . . any new motor vehicle . . . submitted by a manufacturer . . . If such vehicle . . . conforms . . . the Administrator shall issue a certificate of conformity . " EPA uses the information supplied by the manufacturer to verify that the proper test vehicles have been  4 selected and that the necessary testing has been performed to assure that each vehicle design complies with emission standards. This information and the test results, are subsequently used by EPA to target assembly line and recall testing. ( " If the Administrator determines that a substantial number of any class or category of vehicles . . . do not conform ... when in actual use . . . he shall immediately notify the manufacturer . . . of such nonconformity . . .") Similarly, the Energy Policy and Conservation Act requires that " . . . . Average fuel economy . . . shall be calculated by the EPA Administrator . . . " 15 U. S. C. 2003. Automobile manufacturers are required to affix fuel economy labels " as determined in accordance with rules of the EPA Administrator," 15 U. S. C. 2006. While EPA has delegated a substantial portion of the process of calculating fuel economy labels to the manufacturers, the test results on which such labels are based are subject to EPA confirmatory testing. Such confirmation testing assures that results from different manufacturers can be accurately used for comparison.

EPA reviews the information submitted to determine that required testing has been appropriately conducted and that the vehicles or engines have demonstrated compliance with emission standards. A similar review is made for fuel economy. Once vehicles have been produced, EPA uses the information to support various enforcement actions including assembly line audits and in use compliance testing. In addition, fuel economy reports are prepared by EPA for the Departments of Energy, Transportation, and Treasury. Those reports rely on information gained via EPA's emission and fuel economy compliance programs. Some information is also used by various state and local governments in running their vehicle Inspection and Maintenance ( I/ M) programs.

Relevant portions of the above statutes can be found in Attachment I. The regulations dealing with motor vehicle emission control and fuel economy can be found in 40 CFR Parts 85, 86 and 600. The regulations are not attached to this statement due to their length and general technical nature.

2( b) Practical Utility/ Users of the Data Motor vehicle manufacturers must submit an application for emission certification prior to production. The application describes the major aspects of the proposed product line and technical details of the emission control systems. The application and supporting test results are reviewed and, if appropriate, a certificate of conformity is issued. EPA will conduct a limited number of confirmatory tests at its laboratory to verify the manufacturer's results. The decision to require a confirmatory test is dependent on many factors, including the manufacturer's past performance on previous confirmatory tests and the degree of similarity to previously tested vehicles and engines.

An initial step in the certification process is to divide a manufacturer's product line into groups of vehicle designs which are expected to have similar emission control characteristics. For each group a deterioration factor is established either by testing, or by " carrying over" a factor from a previously  5 certified similar group. Results from low mileage test vehicles ( worst case selections from " test groups") are adjusted by the deterioration factor to determine a " useful life" emission level.

Information gathered for purposes of emission certification is also used by EPA in the fuel economy program ( 15 U. S. C. 2000, et seq) as well as the assembly line emission testing ( 42 U. S. C. 7525) and emission recall programs ( 42 U. S. C. 7541). Some of the product information used to verify emission compliance is also used, in conjunction with projected sales, to establish fuel economy ratings. Assembly line and recall testing are targeted, in part, using certification test results and product descriptions in the application. Past performance of similar vehicles is also an important factor in selecting vehicle classes for assembly line and recall testing. For example, when a particular vehicle type is discovered to exceed emission standards the manufacturer's application is reviewed to determine the cause of the failure. ( Typically, application part specifications are much more detailed than those in the service literature.) Once a cause is established, other vehicle types with the same ( or similar) parts can also be considered for enforcement action.

Section 3: Nonduplication, Consultations, and Other Collection Criteria 3 ( a) Nonduplication Efforts have been made to eliminate duplication in this information collection. The fuel economy and emission compliance programs have been highly integrated to precisely for this reason; the same information serves two purposes. In addition, information collected during the certification phase is then subsequently used for assembly line testing and recall. 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, it 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 October 9, 2001, 66 Federal Register 51428; a copy can be found in Attachment III.

3 ( c) Consultations In preparing this ICR, EPA consulted with the following individuals working in the regulated industry:  6 Individual Firm Telephone Brian Gill American Honda ( 310) 783 3414 Randy Harvey General Motors ( 248) 685 6976 Bob Holycross Ford ( 313) 594 0738 Jerry Steffy Harley Davidson ( 414) 616 1101 These individuals have experience with various aspects of EPA's current programs. Their comments have been reflected in the burden estimates discussed below. EPA wishes to thank them and their colleagues for their assistance in preparing this report.

3( d) Effects of Less Frequent Collection As required by the Clean Air Act ( 42 USC 7525( a)), emission and fuel economy information is submitted on a yearly basis coinciding with the manufacturer's " model year." EPA allows applicants to define their own " model year", thus granting some flexibility in this regard. Major product changes typically occur at the start of a model year. For these reasons, a collection frequency longer than a model year is not possible. However, when a vehicle design is " carried over" to a subsequent model year, the amount on new information required is substantially reduced.

3 ( e) General Guidelines Manufacturers are required to keep some records for periods longer than three years. This requirement stems from the statutory requirement that manufacturer warrant some items for periods longer than 3 years. Manufacturers must also recall vehicle classes failing to meet emission standards during their useful life; typically 5 to 11 years depending on vehicle type. In order satisfy these obligations, manufacturers must retain product information, with particular emphasis on the emission control systems. This information is vital in assuring that repairs and replacement parts properly. Accurate product information is also required so that recall campaigns can be directed at the appropriate vehicles. EPA believes that this recordkeeping requirement does not impose an unreasonable burden given the warranty and recall obligations. In fact, manufacturers would probably retain this information to support their normal business of supplying replacement parts.

This information collection activity complies with the remaining guidelines in 5 CFR 1320.5 3 ( f) Confidentiality  7 Information submitted by manufacturers is held as confidential until the specific vehicle to which it pertains is available for purchase. After vehicles are available, most information associated with the manufacturer/ importer's application is available to the public. Under section 208 of the Clean Air Act ( 42 USC 7542 ( c) ) all information, other than trade secret processes or methods, must be publically available. This 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/ SIC Codes The respondents are motor vehicle and motorcycle manufacturers, SIC codes 3711 and 3751.

( b) Information Requested ( i) Data items Manufacturers are required to submit descriptions of their planned product line, including detailed descriptions of the emission control system, and test data. This information is organized into various groups with similar emission or fuel economy characteristics. Manufacturers supply test data to verify that their products will comply with the emission standards, test data is also used to establish fuel economy ratings. Manufacturers also supply information to support recall and assembly line testing, They are also required to notify EPA of in use defects experienced by their vehicles. Given the diversity of vehicles produced and the complicated nature of the regulations, in certain instances, manufacturers may also find it advantageous to request variances from standard EPA procedures.

A list of detailed information requirements and their corresponding regulation citation appears in Attachment II.

( ii) Respondent Activities  8 The emission and fuel economy compliance programs are, of necessity, quite complex given the diversity of products available. These programs have evolved over the past three decades to balance testing and reporting burdens against the risk of unnecessary air pollution and inaccurate fuel economy information. While there is no " typical" respondent, all manufacturers must describe their product and supply test data to verify compliance. EPA will conduct a limited number " confirmatory tests" to audit manufacturer results, this requires test vehicles be shipped to EPA's laboratory. Manufacturers must also retain records. These tasks are repeated for each model year, typically previous data and information can be " carried over" when no significant changes have occurred. If, during the course of a model year a product change is made (" running change"), EPA must be notified. Under some circumstances additional test data may be required.

During production various reports must be submitted; and, after a given model year production has ended, a final report must be submitted. Manufacturers must also submit reports concerning defects that are discovered, they may also be requested to review various aspects of in use testing that EPA may elect to conduct. Manufacturers are also required to conduct in use testing; In Use Verification Program ( IUVP).

Section 5: The Information Collected Agency Activities, Collection Methodology, and Information Management 5( a) Agency Activities A significant portion of EPA's emission and fuel economy compliance activity is spent reviewing applications to verify that the correct vehicle tests have been conducted. A part of this process involves determining if " carry over" of data from a previous model year is appropriate or if new testing will be required. EPA will also select a number of tests for confirmation at EPA's own laboratory. Selections for confirmatory testing are based on a combination of random selection and other factors including past performance on other confirmatory tests.

EPA prepares an annual report of emission test results and reviews annual fuel economy reports submitted by the manufacturers. EPA also conducts a limited number of in use tests for various reasons, one of the most significant as surveillance for potential recalls.

5( b) Collection Methodology and Management EPA currently makes extensive use of computers in collecting information from vehicle  9 manufacturers. Essentially all routine information ( test results and vehicle descriptions) is electronically transmitted directly from the manufacturers. Remaining information, including diagrams and narrative descriptions, is submitted on optical disc. ( Some smaller manufacturers rely on paper submissions.)

All information received by EPA is subject to audit. Data submitted electronically is automatically screened; test results which are close to emission standards are reviewed in more detail. Narrative descriptions of the proposed product line are checked to verify that the appropriate vehicles have been tested. ( The emission and fuel economy programs rely on a combination of " worst case" and representative data to accomplish their goals.) Except for projected sales and a very limited amount of proprietary product information ( typically catalyst formulations), all information is available to the public as soon as the vehicle is offered for sale. Emission and fuel economy data is available on the Internet, other information is available upon request.

5( c) Small Entity Flexibility EPA established special procedures for small volume manufacturers; i. e. those whose total sales are less than 10,000 units per year. These special procedures allow the small volume manufacturer to submit a simplified application for certification as compared to the applications submitted by larger volume manufacturers. For example, the application may include the manufacturer's sales brochure in place of an extended technical description of the manufacturer's product line. These manufacturers also have reduced testing and reporting requirements ( 40 CFR 86.084 14). Further, by the very nature of there size, small volume manufacturers typically have very limited product lines. This characteristic both reduces the amount of information which must be submitted and also simplifies the process of selecting the correct test vehicle( s).

5( d) Collection Schedule Information must be submitted for each " model year" that a manufacturer intends to build ( or import) vehicles. A " model year" is usually about one calendar year long; it typically begins prior to January 1st of the calendar year. 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 product plans. However, as required by law, some submission is required for each model year's production.

Section 6. Estimating the Burden and Cost of the Collection 6( a) Estimating Respondent Burden  10 The burden estimates below are based on those developed several years ago as part of the Compliance Assurance Program ( CAP 2000) project. ( CAP 2000 was designed to reduce the amount of testing EPA required prior to production; in return manufacturers were required to conduct testing on " in use" vehicles.) The CAP 2000 burden estimates were established after a number of meetings with the regulated industry.

The burden estimate presented below has been modified to include several aspects of EPA's compliance program that were formally treated separately. As these other aspects have relatively minor burdens and have the same respondents, it is logical to include them here. ( The activities included are Exclusions and Exemptions of test vehicles, the voluntary National Low Emitting Vehicle Program, assembly line testing, Emission Defect Reporting and Verification of Test Parameters.) This consolidation is discussed in the solicitation of comments, 66 Federal Register 51428, 9 October 2001; no comments were received concerning the proposed consolidation. Except for assembly line testing, the burden for these activities has been added to the burden estimate for each test group. Assembly line testing is treated as separate item.

Since these burden estimates are intended, in part, as a management tool, they are structured to reflect data that can be easily retrieved. Recent changes in how EPA process data ( coinciding with the implementation of CAP 2000) necessitate changes in how burden is estimated. For example, EPA no longer tracks the number of individual vehicle tests which are used to generate certification and fuel economy data. Instead, it is assumed that each test group will have an average of 6 tests per year over the life of the test group; new test groups will have more testing, those that are carried over less. Motorcycle engine families are assumed to have one half test per year due to extensive carry over of previous data and the lack of fuel economy regulations. The remaining activity levels are based on 2001 model year data, the latest available.

In revising the previous burden estimates, a number of individuals in the regulated industry were consulted.; see section 3( c). These individuals, and their colleagues, provided significant insight from an industry perspective; their assistance in this endeavor is most appreciated. In trying to test the accuracy of the previous burden factors, they were asked the following question: " If EPA were to cease to exist, but your firm were still mandated to meet all substantive requirements, e. g. emission standards and fuel economy, how much labor could be saved?" ( This question is believed to succinctly define the burden the Paperwork Reduction Act, and this ICR, addresses.) The response to this question was compared to the burdened predicted by using information from EPA's database and the CAP 2000 burden factors.

One conclusion became readily apparent: Predicted motorcycle burdens were too high. EPA's data simply indicates how many motorcycle engine families are certified ( or licensed) as complying with emission standards; it does not distinguish between " new" and " previously certified." There is far less burden associated with " carrying over" a previously certified design ( or one with minor changes) than with meeting requirements for a new vehicle. As it turns out, the underlying motorcycle design has a significant life even if styling and other factors have significant changes. After consultations with  11 the industry, the burden has been adjusted to reflect an average four to five year design life.

For passenger car and light truck manufacturers, conclusions about the accuracy of EPA's burden estimates were not consistent. One industry representative indicated that estimating how much would be saved " if EPA disappeared" was not easy, the estimate covered a range of 1: 2; i. e. his high limit was twice the lower. ( In this case the EPA prediction was in the middle of the range.) Another manufacturer stated that " not much" would be saved in the absence of EPA required submissions; thus EPA's burden estimate would be significantly higher than any potential savings. Finally, another manufacturer estimated savings much greater than EPA's prediction. Finally tally: three different industry opinions with EPA estimate in the middle.

In discussing this matter further, several explanations were offered. As been pointed out earlier, estimating the paperwork burden for a complicated, long standing program can be difficult. In some instances, the manufacturers ( or EPA) may adapt processes to reflect what the other party needs/ has. ( While it is may no longer be true, a number of years ago one manufacturer structured its application to EPA so that it could be used internally to define the vehicles its assembly plants were authorized to produce.) The distinctions between " product development", " regulatory compliance" and " reporting burden" can become blurred. Similar activities, at different manufacturers, might be classified differently. For example, compliance with statutory fuel economy standards requires much the same testing and product information as preparing the annual report to EPA; how should that effort be classified?

Another factor is the level of " comfort" that a particular organization requires. If compliance is highly regarded ( to avoid potential future issues), one firm may spend more resources and have a higher burden than its competitors. ( It probably would not be accurate to assume that a firm with a cautious approach to compliance would suddenly change its philosophy even if EPA no longer required paperwork submissions.) Some manufacturer's have a separate internal group that duplicates some EPA's functions regarding their " development" organization. Other manufacturers use an " integrated" approach in which development flows into regulatory compliance. The choice in how a particular firm reacts to the same requirements depends on organizational philosophy. One comment received indicated that if EPA disappeared, staff associated with that burden might be shifted to product " verification".

One other point was made during discussions with the regulated industry: Even without an EPA presence, very little  if any  burden reduction would occur unless the California Air Resources Board also reduced its burden. While California has always run its own vehicle air pollution control program, other states have recently been permitted to adopt its standards and procedures. ( EPA, the manufacturers and states established a voluntary National Low Emitting Vehicle standard to reduce the complexity of a patchwork of state standards.) Again, attributing burden is not a clear cut process.

In light of the forgoing, EPA believe that the original projections developed several years ago are still valid and represent as good an estimate as is possible. As discussed in section 5( c), EPA has  12 established special procedures for small volume manufacturers, the reduced burden factors are set forth in the table below. Applying those factors to the model year 2001 activity levels yields the following burden estimate:

LIGHT DUTY AND MOTORCYCLE INDUSTRY BURDEN Activity #/ Year Burden/ Total Activity Test groups Light duty  Large Manufacturer 300 980 294,000 Light duty  Small Manufacturer 40 375 15,000 Motorcycle engine family 185 200 37,000 Evaporative Families Light duty  Large Manufacturer 120 375 45,000 Light duty  Small Manufacturer 40 65 2,600 Vehicles Emission/ Fuel economy/ motorcycle 1,800 10 18,000 In use 3100 2 6,200 Tests Emission/ Fuel economy/ motorcycle 2,000 In use 3,100 5,100 12 61,200 Fuel economy Labels 1,050 5 5,250 Car lines 600 8 4,800 Assembly line tests 0 120 0 Record storage Large manufacturers 25 1,000 25,000 TOTAL 514,000 The table above includes an item for assembly line testing but with no activity. EPA does not intend on using this enforcement tool except in very unusual circumstances which are unlikely to occur. About the only time an assembly line test would be productive would be if EPA had other information indicating that a particular manufacturer had very poor quality control; this would probably only  13 occur for a new small volume manufacturer/ importer. ( With new vehicles the catalyst is extremely active, unless there is an extreme problem all vehicles would likely meet emission standards.) EPA estimates that the 4 emission tests and management overhead would consume approximately 120 hours.

6( b) Estimating Respondent Costs ( i) Estimating labor costs.

The estimated cost for labor is $ 100 per hour for engineers/ technicians. EPA used cost estimates provided in consultations with the industry. The labor cost rates provided by the Bureau of Labor Statistics were not used; those rates are an average for all manufacturing industries and do not reflect the higher costs for the engine and motor vehicle industries.

Using an estimated average cost of $ 100/ hr ( including overhead), annual respondent cost is approximately $ 51.5 million. The labor required has not been broken down into various classifications ( secretarial, technician, senior management) for two reasons. First, an industry survey in the early 1980' s did not obtain such information; EPA has no basis to make finer distinctions. Second, most of the labor required is supplied by skilled engineers and technicians; additional classification would not yield useful information.

( ii) Estimating Capital and Operations and Maintenance Costs The major operating expense for the regulated industry is vehicle mileage accumulation. ( In use vehicles will not require additional mileage accumulation.) EPA estimates that these test vehicles accumulate approximately 4 million miles. Assuming an average cost of $ 0.30 per mile, the total cost is about $ 1.2 million.

To perform the required testing a combination of " environmental" and standard test cells are required. ( A portion of the testing must be done at cold and warm temperatures to verify that emission controls remain effective.) Approximately 650 light duty emission tests will require an environmental test cell; the remaining light duty and motorcycle tests ( approx 4500/ yr) can be performed in standard cells. Environmental cells cost $ 8 million each and have a capacity of 300 tests/ year; standard cells cost $ 4 million with a capacity of 750 tests/ year. Consequently, this testing will require 2.2 environmental and 6 standard test cells with a total cost of $ 41.6 million. With a ten year life and an 7% interest rate, this yields an annualized cost of approximately $ 5.9 million.  14 ( iii) Start up Costs As this is an on going collection, there are no start up costs.

6( c) Estimating Agency Burden The emission and fuel economy compliance programs are administered by EPA's Certification and Compliance Division. Approximately 29 full time employee equivalents are directly involved in the emission and fuel economy programs; their cost is approximately $ 2.9 million, including benefits but not overhead. Overhead percentage for the entire division is approximately 45 yielding an estimated total agency cost of $ 4.2 million.

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 motor vehicle industry, there is no typical or average respondent. Respondents can be large manufacturers with many products such as General Motors; they can also be small importers of a few specialized motorcycles per year.)

6( e) Bottom Line Burden Hours and Cost ( i) Respondent Tally INDUSTRY RESPONDENTS 70 BURDEN HOURS 514,000 LABOR COST $ 51.5 million OPERATING COST $ 1.2 million C A P I T A L I Z E D C 0 S T $ 5.9 million  15 ( ii) Agency tally EPA EMPLOYEES 29 COST $ 4.2 million 6( f) Reasons for change in burden The slight change in estimated burden ( 16,000 hours) is probably not significant; i. e. the process is incapable of making an estimate with that precision. To the extent that there has been any actual change it should be attributed to " adjustment"; EPA has not made any program changes.

6( g) Burden Statement The table in Section 6( a) presents the total estimated burden for the motorcycle and light duty emission and fuel economy compliance programs; approximately 514,000 hours/ year. Annual operating and capitalized costs are approximately $ 1.2 million and $ 5.9 million respectively. Because the universe of vehicle manufacturers is quite diverse, there is no " typical" respondent. However, the burden estimates for the various individual activities in section 6( a) can be used to estimate the burden for a particular respondent. These estimates include time to review applicable regulations and guidance documents, generate and gather the necessary information and submit documents.

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.

Send comments on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including through the use of automated collection techniques to the Susan Auby, U. S. Environmental Protection Agency, Collection Strategies Division ( Mail Code 2822), 1200 Pennsylvania Avenue, N. W., Washington, DC  16 20460 0001; and to Office of Information and Regulatory Affairs, Office of Management and Budget ( OMB), Attention: Desk Officer for EPA, 725 17thStreet, N. W., Washington, DC 20503. Include the EPA ICR number 0783.42 and OMB control number 2060 0104 in any correspondence.  17 Attachment I Legal Authority & Regulatory Citations Energy Policy and Conservation Act 15 U. S. C. 2003 Calculation of average fuel economy ( a) Method of calculation.

"( 1) Average fuel economy for purposes of section 2002 ( a) and ( c) of this title shall be calculated by the EPA Administrator..."

( d) Testing and calculation procedures.

"( 1) Fuel economy for any model type shall be measured, and average fuel economy of a manufacturer shall be calculated in accordance with testing calculation procedures established by EPA Administrator, by rule..."

15 U. S. C. 2005. Information and reports ( c) Tests, reports, etc., which may be required of manufacturers.

"( 1) Every manufacturer shall establish and maintain such records, make such reports, conduct such tests, and provide such items and information as the Secretary or EPA Administrator may, by rule, reasonably require to enable the Secretary or the EPA Administrator to carry out their duties under this subchapter and under any rules prescribed pursuant to this subchapter..."

15 U. S. C. 2006. Labeling ( a) Label required on automobile; contents.

"( 1) Except as otherwise provided in paragraph ( 2), each manufacturer shall cause to be affixed, and each dealer shall cause to be maintained, on each automobile manufactured in any model year after 1976, in a prominent place, a label ...

( 3) The form and content of the labels required under paragraphs ( 1) and ( 2), and the manner in which such labels shall be affixed, shall be prescribed by the EPA Administrator by rule..."  18 Clean Air Act 42 U. S. C. 7525. Motor Vehicle and Motor Vehicle Engine Compliance Testing and Certification ( a) Testing and issuance of certificate of conformity.

"( 1) The Administrator shall test, or require to be tested in such manner as he deems appropriate, any new motor vehicle or new motor vehicle engine submitted by a manufacturer to determine whether such vehicle or engine conforms with regulations prescribed under section 7521 of this title. If such vehicle or engine conforms to such regulations, the Administrator shall issue a certificate of conformity upon such terms, and for such period ( not in excess of one year) as he may prescribe...

45 U. S. C. 7542. Records and Reports ( a) Manufacturers responsibility.

" Every manufacturer shall establish and maintain such records, make such reports, and provide such information as the Administrator may reasonably require to enable him to determine whether such manufacturer has acted or is acting in compliance with this part and the regulations thereunder and shall, upon request of an officer or employee duly designated by the Administrator, permit such officer or employee at reasonable times to have access to and copy such records."

CODE OF FEDERAL REGULATIONS 40 CFR Part 85: Control of Air Pollution from Mobile Sources.

40 CFR Part 86: Control of air pollution from new and in use highway vehicles and engines.

40 CFR Part 600: Fuel economy of motor vehicles  19 Attachment II Data Items List 40 CFR citation Description 85.1504 Application for conditional admission, imported motor vehicle or engine.

85.1505 Application for final admission, imported motor vehicle or engine.

85.1507 Recordkeeping; vehicle descriptions and compliance of imported vehicles and engines.

85.1508 Recordkeeping; owner identification, imported vehicles and engines.

85.1509 Application for final admission of conditionally admitted imported motor vehicles and engines.

85.1511 Application for exemptions/ exclusions from importation requirements.

85.1512 Application for final admission of previously certified or previously imported motor vehicle or motor vehicle engine.

85.1514 Request for confidential treatment of information.

85.1515 Election to use Nox averaging, banking or trading provisions, supporting information.

85.1705 Application for testing exemption, motor vehicle or motor vehicle engine.

85.1706 Application pre certification exemption, motor vehicle or motor vehicle engine.

85.1708 Application for national security exemption, motor vehicle or motor vehicle engine.

85.1712 Application for confidential treatment of submitted information, applications for exemptions/ exclusions.  20 85.1802 Remedial plan required, nonconforming motor vehicle or motor vehicle engine class.

85.1803 Remedial plan contents and requirements.

85.1806 Remedial plan progress reports, recordkeeping of owner notifications.

85.1903 Emission defect reports, motor vehicles and motor vehicle engines.

85.1904 Voluntary emission recall report; motor vehicle and motor vehicle engines.

85.1905 Request to use alternate report format.

85.1906 Recordkeeping requirements, defect reports.

85.1908 Disclaimer of production warranty applicability.

85.1909 Request for confidential treatment of information.

85.2208 Application for alternative short test procedure, light duty vehicle and light duty truck.

86.107 Gas chromatograph records required for evaporative emission test.

86.113 Availability and use of alternate fuels in use.

86.129 Records required, fuel temperature profile determination.

86.142 Records required, exhaust emission test.

86.155 Records required, refueling test.

86.162 Request for alternate air conditioning test simulations.

86.163 Substantiation of alternate air conditioning test simulation correlation.

86.412 Submission of motorcycle maintenance instructions.

86.414 Submission of motorcycle vehicle identification numbers, description of numbering system.

86.415 Submission of annual motorcycle production reports.  21 86.416 Application for motorcycle certification.

86.421 Election to test additional vehicles.

86.423 Submission of optional test data.

86.427 Motorcycle emission testing.

86.428 Request for additional scheduled motorcycle maintenance.

86.429 Request for unscheduled motorcycle test vehicle maintenance.

86.431 Motorcycle test data submission 86.432 Election to use optional method to determine deterioration factor 86.434 Request for additional testing.

86.435 Election for additional service accumulation.

86.437 Certification of motorcycle compliance.

86.438 Amendments to the motorcycle application.

86.439 Amendments to the motorcycle application; alternate method.

86.440 Recordkeeping, motorcycle certification.

86.513 Availability of alternate fuels.

86.542 Recordkeeping, motorcycle certification testing.

86.603 Assembly line data 86.604 Request for reconsideration on use of EPA data.

86.605 Recordkeeping, submission of vehicle production data.

86.607 Request for alternate procedures, description of production changes.

86.609 Submission of test results and supporting information.

86.612 Report on nonconformance, corrective action.  22 86.615 Request for confidential treatment of information submitted.

86.709 Request to use alternate production figures.

86. 908 Request for fee waiver/ refund.

86.909 Applicant, product identification, fee category 86.1003 Assembly line data 86.1004 Request for reconsideration on use of EPA data.

86.1005 Recordkeeping, submission of vehicle production data.

86.1007 Request for alternate selection method.

86.1009 Submission of test results and supporting information.

86.1012 Report on nonconformance, corrective action.

86.1015 Request for confidential treatment of submitted information.

86.1106 Production compliance audit information, recordkeeping.

86.1107 Request for reconsideration on use of EPA data.

86.1108 Maintenance of records.

86.1110 Request for alternate test procedures.

86.1113 Nonconformance penalty calculation.

86.1114 Report on nonconformance, corrective action.

86.1427 Request for alternate short test procedure.

86.1442 Short test reports.

86.1542 Idle test reports.

86.1705 Manufacturer election of NLEV program.

86.1707 Manufacturer's decision to opt out of NLEV program.  23 86.1712 Production reports, maintenance of records.

86.1721 Identification and production information, NLEV vehicles.

86.1723 Emission data, NLEV vehicles.

86.1734 Notification of production vehicle changes.

86.1805 Petition for alternative useful life definition.

86.1806 Request for alternative on board diagnostic system requirements.

86.1809 submission of detailed calibration information.

86.1811 Election of alternate standards and phas in requirements.

86.1817 Election of emission limits, submission of annual report.

86.1823 Description of durability demonstration program.

86.1826 Election of assigned deterioration factors.

86.1829 Request for waivers, data substitution.

86.1839 Substantiation of data substitution.

86.1840 request for special test procedures.

86.1842 Notification of production changes.

86.1843 General information requirements.

86.1844 Product description, test data requirements.

86.1845 In use testing verification requirements.

86.1847 Recordkeeping, in us testing verification.

86.1862 Nox averaging recordkeeping requirements.

600.005 Recordkeeping, fuel economy data vehicles.

600.006 Information requirements, fuel economy data vehicles.  24 600.007 Fuel economy data requirements, imported vehicles.

600.010 Minimum fuel economy data requirements.

600.113 Fuel analysis required.

600.206 Fuel economy data requirements, dual fuel vehicles. 600.207 Model type fuel economy calculations, data requirements.

600.209 Information requirements, fuel economy label calculations.

600.306 Fuel economy label, information requirements.

600.307 Fuel economy label, information requirements.

600.310 High altitude fuel economy label, manufacturer request.

600.311 Range of fuel economy, reporting requirements.

600.312 Reporting of label calculations, recordkeeping requirements.

600.313 Submission of fuel economy information.

600.314 Correction of fuel economy labels.

600.507 Submission of revised fuel economy data.

600.509 Submission of voluntary fuel economy data.

600.510 Calculation of average fuel economy, adjustments.

600.512 Model year report, submission required.