INFORMATION COLLECTION REQUEST
SUPPORTING STATEMENT
Information Requirements for Nonroad Small SI and Marine SI Engines and Equipment
Winter 2006
Assessment and Standards Division
Office of Transportation and Air Quality
Office of Air and Radiation
U.S. Environmental Protection Agency
Information Collection Request
1(a). Title
Control of Emissions from Nonroad Spark-Ignition Engines and Equipment
ICR Tracking Number: 2251.01
1(b). Short Characterization
The Clean Air Act authorizes EPA to adopt emission standards for new nonroad engines. We need information to verify that manufacturers comply with emission standards—before production begins, and during production. In the rulemaking, we require manufacturers to generate or retain information to demonstrate that engines comply with emission standards.
Manufacturers generally send us the data they collected and keep these records and other pertinent information. We may request to see any of these records.
We and the regulated companies will use the data exclusively to ensure compliance with emission standards. Information such as engine family, total numbers of engines built, and emission rates for specific pollutants, are examples of what we require.
This ICR is submitted as a new submittal even though existing requirements exist. The revisions generally include new standards, testing, and reporting requirements for nonroad spark ignition engines.
2. Need For and Use of the Collection
2(a). Need/Authority for the Collection
The data we require in this ICR is necessary to comply with Title II of the Clean Air Act, as amended in 1990. The Act directs us to adopt regulations for nonroad engines if we determine those engines contribute significantly to air pollution in the U.S. Now that we have made this determination, the Act directs us to set emission standards for any category of nonroad engines that contributes to air quality nonattainment in two or more areas in the U.S. We can only meet the requirements of the Act by collecting data from the regulated industry. Also, we will only have an effective program if we know that these engines maintain their certified emission level throughout their operating lives.
2(b). Use/Users of the Data
We will oversee the certification process and maintain the program database. We will use the data items to verify compliance with the following requirements associated with the new emission standards.
• Determine whether or not a prototype engine or fuel system component may adequately represent an engine family.
• Ensure compliance of production-line engines.
• Issue a recall to correct a noncompliant family of engines or equipment.
• Confirm actual emission benefits gained by the program.
• Ensure proper maintenance and setting of physically adjustable parameters.
• Aid in the production projections to randomly select the engines and fuel system components which are to undergo testing.
• Determine whether a prototype or freshly manufactured engine or fuel system component should be issued a certificate of conformity.
• Ensure that durability of emission controls is consistent with the manufacturer’s stated useful life.
• Ensure control of emissions across the range of engine operation expected in the normal course of its lifetime.
• Manage the importation of engines and equipment that meet requirements.
3. Nonduplication, Consultations, and other Collection Criteria
3(a). Nonduplication
State and local governments are preempted from adopting emission standards for many of the engines covered by this rulemaking. The exception to this is California which has set its own exhaust and evaporative emissions standards for Small SI and exhaust standards for Marine SI. Where possible, we will accept information that has been generated by manufacturers that certify in California. In many cases, the engine and fuel system manufacturers do not certify in California. In those cases, the information requested under this ICR is not available from other sources.
3(b). Public Notice Required Prior to ICR Submission to OMB
We will publish a proposed rulemaking in the Federal Register regarding emission standards for nonroad Small SI and Marine SI engines. The proposed rule will include invitations to comment on the ICR.
3(c) Consultations
We have met with companies that will be subject to the new emission standards. These contacts are summarized in Tables 1 and 2.
Table 1
Industry Contacts Regarding Information Collection - Small SI Exhaust and Evap
Date |
Contact |
July 11, 2006 |
Small Entity Representative Outreach Meeting: James McNew, Outdoor Power Equipment Institute (OPEI), Gary Engen, Solar Plastics, Mike Felder, Tiger Trucks, Geoffrey Ward, Agri‑Industrial Plastics, George Kraemer, Kracor Inc., Bob Walker, Walker Manufacturing, Stan Guyer, Moridge Manufacturing (Grasshopper Mowers). |
August 22, 2006 |
OPEI/EPA Handheld Meeting: Bill Guerry, OPEI, James McNew, OPEI, Dan Ericsson, Husqvarna, Holger Lochmann, Stihl, Drew Hornick, Homelite, Dale Maradei, Robin America, Joe Gulden, Echo, Mark Swanson, Walbro, Rob Stegall, Echo, Ann Snyder, Solo. |
August 23, 2006 |
EPA/OPEI/EMA meeting: Bill Guerry, OPEI, Roger Gault, EMA. |
September 6, 2006 |
EPA/OPEI/EMA meeting: Bill Guerry, OPEI, Roger Gault, EMA, Ron Donahue, Tecumseh, Kurt Rottier, Kubota, Jimmy Eavenson, MTD, Don DeMaster, Kohler, Tom Bingham, Honda, Dale Maradei, Robin America, Brian Buchholz, Deere, Peter Hampton, ACS, Ron Lloyd, Toro, Jeff Shetler, Kawasaki, Dan St Martin, Briggs & Stratton, Ron Goldman, Husqvarna. |
September 11, 2006 |
OPEI Handheld Meeting: Buill Guerry (OPEI), Drew Hornick, Homelite, Holder Lochmann, Stihl, Rob Stegall, Echo, Joe Gulder, Echo, Dale Maradei, Robin America, Mike Bounds, Husqvarna. |
September 12, 2006 |
Small Entity Representative Outreach Meeting: James McNew, Outdoor Power Equipment Institute (OPEI), Geoffrey Ward, Agri‑Industrial Plastics, Robert Porter, Inca, Mike Felder, Tiger Trucks, George Kraemer, Kracor Inc., Bob Walker, Walker Manufacturing, Stan Guyer, Moridge Manufacturing (Grasshopper Mowers). |
September 13, 2006 |
EPA/OPEI/EMA: Bill Guerry, OPEI, Roger Gault, EMA, mailto:(rgault@emamail.org),Ron Donahue, Tecumseh, Tom Bingham, Honda, Pete Hampton, ACS, Jeff Shetler, Kawasaki, Dave Gardner, Briggs & Stratton, Ron Goldman, Husqvarna, Don DeMaster, Kohler, Dale Maradei, Robin America, Ron Lloyd, Toro, Singh Suchden, MTD, Brian Buchholz, Deere |
September 20, 2006 |
EPA/OPEI/EMA: Bill Guerry, OPEI, mailto:(wguerry@colliershannon.com), Roger Gault, EMA, mailto:(rgault@emamail.org),Ron Donahue, Tecumseh. |
November 29, 2006 |
OPEI/EPA Handheld Meeting: Bill Guerry, OPEI, James McNew, OPEI, Robert Stegall, ECHO, Holger Lochmann, Stihl, John Foster, Shindaiwa, Dale Maradei, Robin America. |
November 30, 2006 |
EPA Phase 3 Task Group Joint EMA/EPA Meeting: Roger Gault, EMA, Bill Guerry, OPEI, Tom Bingham, Honda, Brian Buchholz, Deere, Todd Carpenter, Tecumseh, Jimmy Eavenson, MTD, Dave Gardner, Briggs & Stratton, Peter Hampton, ACS, Jeff Shetler, Kawasaki, Masara Yamamoto, Honda, Ron Lloyd, Toro. |
Table 2
Industry Contacts Regarding Information Collection - Marine SI Exhaust and Evap
Date |
Contact |
January 24, 2006 |
National Marine Manufacturers Meeting, John McKnight, NMMA, Dan Ostrosky, Yamaha, Mark Riechers, Mercury, Rich Waggoner, Indmar, Harold Haskew, HH&A, Joe Klak, BRP, Dick Rowe, Indmar, Rich Kolb, Volvo-Penta, Bob Alsip, Suzuki, Neil Wallace, Ilmor, Tom Binham, Honda, Dick Penna, VNF, Dave Marlow, Brunswick Boat Group. |
July 11, 2006 |
Small Entity Representative Outreach Meeting: John McKnight, National Marine Manufacturers Association (NMMA), Gary Engen, Solar Plastics, Geoffrey Ward, Agri‑Industrial Plastics, George Kraemer, Kracor Inc., Jim Hardin, Grady White Boats Robert Porter, Inca, Tim Cushing, Sterling Performance, Rich Waggoner, Indmar, Marty Herigstad, KEM Equipment, Dennis Baccus, KEM Equipment, Josh Pietak, ECO LLC (representing KEM), Tom Tribue, Ebbtide Boats, Richard Anderson, Ebbtide Boats, Bill Shields, Trident Rubber. |
September 12, 2006 |
Small Entity Representative Outreach Meeting: John McKnight, National Marine Manufacturers Association (NMMA), Rich Waggoner, Indmar, Geoffrey Ward, Agri‑Industrial Plastics, Robert Porter, Inca, Tim Cushing, Sterling Performance, Mike D’Anniballe, Sterling Performance, Bob Holt, Trident Rubber, George Kraemer, Kracor Inc., Tom Fileman, Flagship, Chuck Thurman, Pleasurecraft Marine, Joe Hunter, Grady White Boats. |
October 26, 2006 |
National Marine Manufacturers Meeting, John McKnight, NMMA, Mark Riechers, Mercury, Rich Kolb, Volvo-Penta, Dan Ostrosky, Yamaha, Britt Fleming, VNF, Joe Klak, BRP, Fernando Garcia, BRP, Rich Waggoner, Indmar, Bob Alsip, Suzuki. |
December 4, 2006 |
National Marine Manufacturers Meeting: John McKnight, NMMA, Bob Alsip, Suzuki, Dan Ostrosky, Yamaha, Rich Kolb, Volvo Penta, Joe Klak, BRP, Mark Riechers, Mercury, Fernando Garcia, BRP, Dick Rowe, Indmar, Tom Fileman, Flagship, Brian Eminhizer, PCM, Rich Waggoner, Indmar, Alec Zackaroly, Volvo Penta, Tom Bingham, Honda, Britt Flemming, VNF, Ron Brown, Ilmor, Tim Cushing, Sterling Performance. |
3(d) Effects of Less Frequent Collection
Annual reporting for certifying engine families is necessary to align with the regulatory requirement to certify engine families every year. Quarterly reporting of test results from production-line testing is necessary to allow adequate response to any problem that may arise.
3(e) General Guidelines
This ICR complies with the general guidelines, except for the requirement to retain records for up to eight years, as described in 4(b)(ii) below.
3(f) Confidentiality
We hold information from the engine manufacturers as confidential until the associated engines are available for purchase. Manufacturers may submit proprietary information, consisting generally of sales projections and certain sensitive technical descriptions. We grant confidentiality in accordance with the Freedom of Information Act, EPA regulations at 40 CFR part 2, subpart B, and class determinations issued by our Office of General Council.
3(g) Sensitive Questions
We do not ask sensitive questions. This collection complies with The Privacy Act and OMB Circular A-108.
4. Respondents and Information Requested
4(a) Respondents/NAICS and SIC Codes
The respondents are generally involved in the industries shown in Table 3.
Table 3
NAICS and SIC Codes for Respondent Categories
Respondent Categories |
NAICS Codesa |
SIC Codesb |
Other Engine Equipment Manufacturing |
333618 |
3519 |
Boat Building |
336612 |
3732 |
All Other Transportation Equipment Manufacturing |
336999 |
3799 |
Hand and Edge Tool Manufacturing |
332212 |
-- |
Lawn and Garden Tractor and Home Lawn and Garden Equipment Manufacturing |
333112 |
3524 |
Motor and Generator Manufacturing |
335312 |
3621 |
aNorth American Industry Classification System (NAICS)
bStandard Industrial Classification (SIC) system code.
4(b) Respondents and Information Requested
(i) Data Items
Manufacturers must send us an application for certification, including emission data and other descriptive information. In addition, manufacturers create engine labels and send us information in some cases regarding engines that are exempt from emission standards or other specific requirements.
(ii). Respondent Activities
Companies retain records as hard copy and may also reduce the information to microfilm, computer disks, etc. We require very little submission of information to process applications for certification. This reduces the resource burden, both for the industry and for us. However, because we do not have the information on file, we depend on manufacturers to retain the records to allow us to verify compliance throughout the useful life of the engines. Eight years is sufficient time for this information for most engines. Any investigation of in-use engines generally does not start until three or more years after the manufacturer completes the application for certification.
The certification information includes records related to the deterioration of an engine’s emission controls with age. Some manufacturers also participate in emission-credit programs, in which they produce some engines with emissions above the standard and others with emissions below the standard. This is an optional program, so we don’t include specific estimates related to any additional reporting or recordkeeping for generating or using emission credits.
Manufacturers must also report to us if they learn that a substantial number of their engines have emission-related defects. This is normally not a requirement to collect information, but if manufacturers learn that there is or might be a substantial number of emission-related defects, then they must send us information describing the defects.
Many companies import engines. First, some companies import engines that are not subject to emission standards; they must, however, fill out a form documenting the status of their engine and the reason for their exemption. Since most engines are now covered by emission standards, this has become much less common. It is now generally limited to engines used for stationary, underground mining, and hobby applications. Second, some companies import engines as Independent Commercial Importers, meaning that they do their own testing instead of importing engines that have been certified by engine manufacturers.
We have also adopted special provisions that allow equipment manufacturers to sell equipment with uncertified engines (or engines certified to less stringent standards). This involves a one-time notification before using this flexibility and annual reporting to document compliance with these provisions. This is a voluntary program that substantially reduces the costs of compliance for engine manufacturers, so we have not included specific costs related to these reporting or recordkeeping activities here.
All reports, submissions, notifications, and requests for approval must be addressed to: Manager, Engine Programs Group (6405-J), U.S. Environmental Protection Agency, 1200 Pennsylvania Ave., Washington, DC 20460. Respondents must submit information in an approved EPA information format.
5. The Information Collected--Agency Activities, Collection Methodology, and Information Management
5 (a) Agency Activities
Our certification and tracking process involves reviewing applications and emission data from engine and equipment manufacturers. From this data, we issue certificates of conformity, and may confirm that production and in-use engines continue to comply with standards. We may also select families to be tested in a given production year and require additional testing, based on an analysis of the submitted data.
5 (b) Collection Methodology and Management
We currently use computers extensively to collect information from engine manufacturers. Based on this approach as a model, much routine information (test results, projections) can be electronically transmitted directly from the manufacturers to our computer database. We expect to publish this information on our website once certified engines go into production (www.epa.gov/otaq/).
5 (c) Small-Entity Flexibility
Exhaust Emissions: We have included provisions to ease the compliance burden on small businesses. For instance, some small manufacturers of small SI engines will be allowed the option to delay compliance with emission standards for two years. They also will be able to use an assigned deterioration factor which saves them the expense of service accumulation and additional testing to measure deteriorated emissions levels at the end of the regulatory useful life. Small engine manufacturers will also be exempt from Production Line Testing and can use a broader definition of “Engine Family” such that they have a smaller number of engine families for certification.
Small SI equipment manufacturers will have two extra years beyond the implementation dates for the Phase 3 standards to continue using Phase 2 engines in their Class II equipment. In addition, simplified engine certification for equipment manufacturers who must certify the engine due to redesign of the muffler system with catalyst.
Evaporative Emissions: Fuel tank manufacturers are largely small businesses. We have designed the evaporative emission control program to address the needs of these businesses including longer lead times for implementation of the fuel tank permeation standards. We have also included certification flexibility such as expanded emission family definitions, design-based certification options, limited compliance demonstration, and hardship provisions.
5(d) Collection Schedule
Table 4
Principal Reporting Start Dates
Category |
Principal Reporting Start Date |
Engine or Equipment Manufacturer |
SI Evaporative - Handheld |
2009 |
Engine/Equipment |
SI Evaporative - NHH |
2008 |
Engine/Equipment |
SI Exhaust - Class I |
2012 |
Engine |
SI Exhaust - Class II |
2011 |
Engine |
Marine Evaporative |
2009 |
Engine/Vessel |
Marine Exhaust |
2009 |
Engine |
The principal reporting requirements are associated with certification to the emission standards, which begin to apply in the time frames presented above, depending on the size/application of the engine. Reporting requirements therefore do not begin until the end of the preceding year at the earliest. Annual reporting is based on the beginning of the model year, which can vary for each manufacturer and for each engine family.
6. Estimating Burden and Cost of the Collection
Engine manufacturers comply with emission standards by submitting an application for certification, which obligates them to do a certain amount of testing to show they comply with the standards. The following discussion develops burden and cost estimates for the first three years of the program.
6 (a) Estimating Respondent Burden
The estimates of respondent burden utilize data from the affected industries or commercially available databases. Burden hours per engine family are based upon established hour amounts for engine families, as published in the “Application for Motor Vehicle Emission Certification and Fuel Economy Labeling” (OMB No. 2060-0104).
Small SI Exhaust:
The burden for certification testing is generally based on dynamometer aging and four engine tests for each engine family, then using that test data for several years. The useful life sales weighted estimated average annual cost for full certification testing, including durability demonstration testing, is $8,000 per engine test (combining labor and O&M expenses). The manufacturer’s application for certification involves an extensive effort the first year, followed by relatively little effort in subsequent years. We estimate that manufacturers will conduct new certification testing every five years; the costs have been estimated on an annual average basis.
In addition to testing, manufacturers must prepare the application for certification and maintain appropriate records. We have estimated the cost of these combined activities, which include engineering and clerical effort, to be $1500 per engine family per certification cycle. As with the testing costs, we are presenting annual average costs. Annual certification fees for engine manufacturers are included at $800 per engine family.
These burden estimates apply equally whether the manufacturer conducts the required activities, or if the manufacturer hires a third party for some of these activities.
In addition, engine manufacturers are expected to upgrade some analyzers in order to perform emission testing in compliance with upgraded test procedures.
Marine SI Exhaust
The burden for certification testing is generally based on conducting durability and emission tests for each engine family, then using that test data for several years. The estimated cost for full certification testing, including durability demonstration testing, is $90,000 per engine family (combining labor and O&M expenses). The manufacturer’s application for certification involves an extensive effort the first year, followed by relatively little effort in subsequent years. We estimate that manufacturers will conduct new certification testing every five years; the costs have been estimated on an annual average basis.
In addition to testing, manufacturers must prepare the application for certification and maintain appropriate records. We have estimated the cost of these combined activities, which include engineering and clerical effort, to be $10,000 per engine family per certification cycle. As with the testing costs, we are presenting annual average costs.
Manufacturers of OB/PWC are also expected to conduct testing on their engines after they have been placed into service to confirm that they continue to meet emission standards. Testing selected families using field-testing equipment instead of full laboratory equipment allows for substantial data collection for much lower costs than would be incurred by pulling engines out and testing them on a dynamometer. We base the estimated costs on testing 25 percent of engine families, at approximately $125,000 per family. This allows for testing multiple engines in each family.
These burden estimates apply equally whether the manufacturer conducts the required activities, or if the manufacturer hires a third party for some of these activities.
Evaporative
For the first year, we estimate fuel tank durability and certification testing to cost about $15,000 per fuel tank manufacturer with the expectation that the manufacturers will use the same materials and permeation control strategy for all of their fuel tanks to reduce costs. Low permeation fuel lines are largely an established technology. We include a cost of $1,000 per hose manufacturer to perform certification permeation testing on fuel lines. For the running loss, diffusion, and diurnal standards, we expect manufacturers to use the design-based certification options rather than testing. In addition, we estimate about $10,000 for engineering and clerical work for the equipment manufacturers.
6 (b) Estimating Respondent Costs
(i) Estimating Labor Costs
Labor rates on a per-hour basis, are taken from the Bureau of Labor Statistics web site at http://stats.bls.gov/news.release/ecec.t12.htm (accessed November 24, 2000). Technical labor is $43/hr, engineer labor is $65/hr, clerical labor is $27.11/hr. Labor rates were multiplied by 1.5 to account for fringe benefits and other overhead expenses.
(ii) Estimating Operations and Maintenance Costs
Operation and maintenance costs include expenses related to engine testing. Costs are for laboratory time, the use of test equipment, engine parts, fuel and other supplies, and fabrication of test tools and fixtures. Direct labor costs and operations and maintenance costs combine for the total test costs described above.
(iii)Capital/Start-up Costs
Companies required to conduct testing generally either have testing facilities or are expected to conduct testing at a contractor’s laboratory. However, the rulemaking will incorporate new test procedure guidelines as outlined in 40 CFR 1065. This may require upgrade of analyzers and related equipment for small SI engine manufacturers. Costs are estimated at $300,000 per test cell with two test cells per engine manufacturer for a total of $600,000 each. Engine manufacturers of handheld engines will also need to upgrade related equipment for 40 CFR 1065 requirements and this is also estimated at $600,000 per engine manufacturer. There are a large number of importers that do not have production facilities in the US and it is known that these engine manufacturers utilize commercial test labs for certification testing. One set of capital costs at $600,000 is included for this testing method.
Although there are no existing federal requirements for SD/I exhaust emissions, many of the SD/I manufacturers are performing exhaust emission testing to certify in California. For smaller manufacturers that do not certify in California, we anticipate that they would contract with outside laboratories for their exhaust emission testing rather than building test facilities on site.
(iv) Annualizing Capital Costs
Calculating $600,000 per handheld and nonhandheld engine manufacturer yields a total of $19,800,000. Annualizing these capital costs yields a total of $5,528,763 over 5 years.
6 (c) Estimating Agency Burden and Cost
Our Engine Programs Compliance Group administers emission certification programs. This group has approximately 17 full-time employees. We project 50 hours per week of staff time (at $40 per hour, loaded) to manage engine compliance programs related to new emission standards. This comes to approximately 2,500 hours or $100,000 per year to oversee the requirements of the final rule.
6 (d) Estimating the Respondent Universe and Total Burden and Costs
The following tables show the labor and other costs associated with meeting the new requirements for each engine family. This includes certification costs, plus the cost of any additional testing. Per-family costs are multiplied by the number of engine families and added to estimated capital costs (if any) to arrive at an estimated total cost.
Table 5
Annual Respondent Burden and Cost—Nonroad Spark Ignition Engine Manufacturers
Information Collection Activity |
Average annual burden and cost per family |
# of Families |
Annualized Capital & Startup cost |
Total Hours and Costs |
||||||
Mgr. @ $65/hr |
Tech. @ $43/hr |
Cler. @ $27/hr |
Hours per family |
Labor cost per family |
O&M Cost per family |
Total Hours/yr |
Total Cost/yr |
|||
Cert. application* |
1 |
3 |
0.8 |
4.8 |
$216 |
$800 |
210 |
$0 |
1,008 |
$213,276 |
Recordkeeping |
0.2 |
0.6 |
0.2 |
1 |
$43 |
$0 |
210 |
$0 |
210 |
$9,282 |
Cert./durability testing |
7.5 |
112 |
1 |
121 |
$4,825 |
$3,082 |
210 |
$5,529,000 |
25,356 |
$1,660,344 |
Selective enforcement audits |
0.02 |
0.48 |
0.05 |
0.55 |
$23 |
$73 |
2/industry |
$0 |
115 |
$20,120 |
PLT |
5 |
100 |
10 |
115 |
$4,895 |
$11,201 |
210 |
$0 |
24,150 |
$3,380,160 |
Defect reporting |
2 |
10 |
10 |
22 |
$830 |
$0 |
21 |
$0 |
462 |
$17,430 |
Total Cost (per year) = |
2,065,643 |
3,100,306 |
— |
$5,529,000 |
51,301 |
$5,300,612 |
$800 in O&M costs under cert application is the certification fee paid per engine family by the engine manufacturer.
Table 6
Annual Respondent Burden and Cost—Marine Spark Ignition Engine Manufacturers
Information Collection Activity |
Average annual burden and cost per family |
# of Families |
Annualized Capital & Startup cost |
Total Hours and Costs |
||||||
Mgr. @ $65/hr |
Tech. @ $43/hr |
Cler. @ $27/hr |
Hours per family |
Labor cost per family |
O&M Cost |
Total Hours/yr |
Total Cost/yr |
|||
Cert. application* |
2 |
36 |
6 |
44 |
$1,840 |
$800 |
132 |
$0 |
5,808 |
$348,480 |
Recordkeeping |
0.2 |
2.2 |
2 |
4.4 |
$162 |
$0 |
132 |
$0 |
581 |
$21,331 |
Cert./durability testing |
|
160 |
|
160 |
$6,880 |
$9,118 |
132 |
$0 |
21,120 |
$2,111,789 |
Selective enforcement audits |
0.04 |
0.76 |
0.08 |
0.87 |
$37 |
$569 |
1 |
$0 |
115 |
$80,000 |
Production line testing |
5 |
100 |
10 |
115 |
$4,895 |
$35,105 |
132 |
$0 |
15,180 |
$5,280,000 |
In-use testing |
25 |
725 |
35 |
785 |
$33,745 |
$91,255 |
25 |
$0 |
19,625 |
$3,125,000 |
Defect reporting |
2 |
10 |
10 |
22 |
$830 |
$0 |
13 |
$0 |
286 |
$10,790 |
Total Cost (per year) = |
$2,677,821 |
$8,299,569 |
-- |
$0 |
62,715 |
$10,977,390 |
*$800 in O&M costs under cert application is the certification fee paid per engine family by the engine manufacturer.
Table 7
Annual Respondent Burden and Cost—Small SI Equipment and Fuel System Manufacturers
Information Collection Activity |
Average annual burden and cost per family |
# of Families |
Annualized Capital & Startup cost |
Total Hours and Costs |
||||||
Mgr. @ $65/hr |
Tech. @ $43/hr |
Cler. @ $27/hr |
Hours per family |
Labor cost per family |
O&M Cost |
Total Hours/yr |
Total Cost/yr |
|||
Cert. application* |
1 |
3 |
0.8 |
4.8 |
$216 |
$250 |
1123 |
$0 |
5,390 |
$522,869 |
Recordkeeping |
0.2 |
0.6 |
0.2 |
1.0 |
$44 |
$0 |
1123 |
$0 |
1,123 |
$49,637 |
Cert./durability testing |
|
28 |
|
28 |
$1,204 |
$3,686 |
93 |
$0 |
2,604 |
$459,439 |
Selective enforcement audits |
0.003 |
0.02 |
0.01 |
0.03 |
$1 |
$1 |
1 |
$0 |
17 |
$1,195 |
Defect reporting |
2 |
10 |
10 |
22 |
$830 |
$0 |
112 |
$0 |
2,471 |
$93,209 |
Total Cost (per year) = |
$497,631 |
$624,067 |
-- |
$0 |
11,605 |
$1,126,349 |
*$250 in O&M costs under cert application is the certification fee paid per engine family by the engine manufacturer.
Table 8
Annual Respondent Burden and Cost—Marine SI Equipment and Fuel System Manufacturers
Information Collection Activity |
Average annual burden and cost per family |
# of Families |
Annualized Capital & Startup cost |
Total Hours and Costs |
||||||
Mgr. @ $65/hr |
Tech. @ $43/hr |
Cler. @ $27/hr |
Hours per family |
Labor cost per family |
O&M Cost |
Total Hours/yr |
Total Cost/yr |
|||
Cert. application* |
1 |
3 |
0.8 |
4.8 |
$216 |
$250 |
380 |
$0 |
1,824 |
$176,928 |
Recordkeeping |
0.2 |
0.6 |
0.2 |
1.0 |
$44 |
$0 |
380 |
$0 |
380 |
$16,796 |
Cert./durability testing |
|
28 |
|
28 |
$1,204 |
$3,686 |
78 |
$0 |
2,184 |
$385,336 |
Selective enforcement audits |
0.01 |
0.03 |
0.01 |
0.04 |
$2 |
$1 |
1 |
$0 |
17 |
$1,195 |
Defect reporting |
2 |
10 |
10 |
22 |
$830 |
$0 |
38 |
$0 |
836 |
$31,540 |
Total Cost (per year) = |
$224,871 |
$383,024 |
-- |
$0 |
5,241 |
$611,795 |
*$250 in O&M costs under cert application is the certification fee paid per engine family by the engine manufacturer.
6 (e) Bottom-Line Burden Hours and Cost Tables
(i) Respondent Tally
Bottom-line burden and cost for the first three years of the rulemaking are shown in Table 9. The table shows industry totals and average values for each respondent by category. These estimated costs include startup expenses (for example, the purchase of emission sampling equipment and new recordkeeping software).
Table 9
Summary of Bottom-line Burden Hours and Cost Per Year
Affected Entities |
Number of Respon-dents |
Industry Totals |
Average per Respondent |
|||||
Annualized Capital Costs |
Total Labor per Year |
Total O&M Costs per Year |
Total Hours per Year |
Total Costs per Year |
Total Hours per Year |
Total Costs per Year |
||
Small SI engine manufacturers |
58 |
$5,529,000 |
$2,065,643 |
$3,100,306 |
51,301 |
$5,300,612 |
885 |
$91,390 |
Marine SI engine manufacturers |
40 |
$0 |
$2,677,821 |
$8,299,569 |
62,715 |
$10,977,390 |
1,568 |
$274,435 |
Small SI evaporative |
623 |
$0 |
$497,631 |
$624,066 |
11,605 |
$1,126,349 |
19 |
$1,800 |
Marine SI evaporative |
380 |
$0 |
$224,871 |
$383,024 |
5,241 |
$607,895 |
14 |
$1,600 |
Total |
1,101 |
$5,529,000 |
$5,465,966 |
$12,406,965 |
130,862 |
$18,012,246 |
2,486 |
$369,225 |
(ii) Agency Tally
Our estimated burden is approximately 2,500 hours or per year (or $100,000) to oversee the requirements of the final rule, as described in Section 6(c).
6 (f) Burden Statement
The annual public reporting and recordkeeping burden for this collection of information is estimated to average 119 hours 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-2003-0012, which is available for online viewing at www.regulations.gov, or in person viewing at the Air and Radiation Docket and Information Center in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 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 (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-2003-0012 and OMB Control Number 2060-NEW in any correspondence.
6 (g) Reason for Change in Burden
We are proposing emission standards for nonroad Small SI and Marine SI engines and equipment. This information collection request updates the estimated burden to reflect the additional effort required to meet the new standards and consolidates all the various recordkeeping and reporting items for these engines.
File Type | application/msword |
File Title | • |
Author | ckerwin |
Last Modified By | ckerwin |
File Modified | 2007-04-09 |
File Created | 2007-03-27 |