| Type |
Regulatory citation |
Labor Hours |
Notes |
Forms (not already included under EV-CIS) |
| Production Reports |
86.415-78(b) |
|
Due 45-days after the end of the model year |
5900-90 |
| Certification Application |
86.416-80 |
|
Appropriately describe the vehicle, all emissions control devices, adjustable parameters, certification data |
5900-464, 5900-NEW |
| Certification/durability Test |
86.427-78 |
|
Service accumulation, (1/2) useful life deterioration and certification testing |
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| Confirmatory test |
86.434-78 |
|
Requested by the EPA and performed at the direction and location of the EPA test order. |
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| Production testing |
86.415-78(a) |
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Requested by the EPA. Manufacturers may be requested to provide service accumulation to some minimal test distance before providing the production vehicle to the EPA for testing. |
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| Amendments to the Application |
86.438-78, 86.439-78 |
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As requested by the manufacturer for various purposes, i.e. add models or alter certified configurations. |
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| Maintain certificaiton and testing records |
86.440-78 |
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| ABT end-of-year report |
86.449 |
|
Prepared only by manufacturers that are utilizing the averaging flexibility for an averaging set of engine families. |
5900-339 |
| Evaporative testing and standards |
86.410-2006(g) |
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| Emissions Defect Reporting |
85.1903 |
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Defect information reports required under paragraph (a) of this section shall be submitted not more than 15 working days after an emission-related defect is found to affect twenty-five vehicles or engines of the same model year. |
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Comment:
This VERR does not include an ordered recall by the EPA under Part 85, Subpart S. These instances of an ordered recall are rare and would constitute a compliance action by the Agency.
Voluntary Emissions Recall Report |
85.1904 |
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Quarterly submission of a report describing the manufacturer's voluntary emissions recall plan as prescribed by this section within 15 working days of the date owner notification was begun. The manufacturer shall report on the progress of the recall campaign by submitting subsequent reports for six consecutive quarters commencing with the quarter after the voluntary emissions recall campaign actually begins. |
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| Maintenance of Records |
86.440-78 |
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Comment:
A properly completed application, following the format prescribed by the U.S. EPA for the appropriate year of production, fulfills each of the requirements of this paragraph.
(1) General Records(A) Identification and description of all certification vehicles for which testing is required under this subpart. |
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(B) A description of all emission control systems which are installed on or incorporated in each certification vehicle. |
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(C) A description of all procedures used to test each such certification vehicle. |
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(2) Individual records. (i) A brief history of each motocycle used for certification under this subpart including: |
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(A)(1) In the case where a current production engine is modified for use in a certification vehicle, a description of the process by which the engine was selected and of the modification made. |
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(2) In the case where the engine for a certification vehicle is not derived from a current production engine, a general description of the build-up of the engine (e.g., experimental heads were cast and machined according to supplied drawings, etc.) |
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(3) In both cases above, a description of the origin and selection process for the carburetor, fuel system, emission control system components, and exhaust after treatment device shall be included. |
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(B) A complete record of all emission tests performed (except tests performed by EPA directly) including test results, the date and purpose of each test, and the distance accumulated on the vehicle. |
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(C) The date of each service accumulation run, listing the distance accumulated. |
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(E) A record and description of all maintenance and other servicing performed, giving the date of the maintenance or service and the reason for it. |
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(F) A record and description of each test performed to diagnose engine or emissions control system performance, giving the date and time of the test and the reason for it. |
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(H) A brief description of any significant events affecting the vehicle during any time in the period covered by the history, not described by an entry under one of the previous headings, including such extraordinary events as vehicle accidents or dynamometer runaway. |
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(3) ...retained by the manufacturer for a period of six (6) years after the issuance of all certificates of conformity to which they relate. Routine emission test records shall be retained by the manufacturer for a period of one (1) year after issuance of all certificates of conformity to which they relate. |
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Information Collection Activity |
Respondents |
Responses (Engine Families) |
Julian Maurice Davis:
Legal assistance was excluded from this category because certification and compliance reporting and recordkeeping rarely require the assistance of legal aid unless a violation to the regulations occurs.
Managerial/$86.55 |
Technical/ $37.95 |
Administrative/ $29.15 |
Total Hours |
Respondent Hours/ Year |
Labor Cost/ Year |
Capital/ Startup Cost |
O&M Cost |
Total Capital Cost/ year |
Total O&M Cost/ Year |
Total Capital and O&M Cost/ Year |
Total Cost/ Year |
| 86.416-80 |
Prepare and Submit application for certification |
55 |
282 |
2 |
173.1 |
4 |
151.8 |
16 |
466.4 |
22 |
6204 |
223146.6 |
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| 86.427-78 |
Perform emissions testing on the EDV, including service accumulation and deterioration factor testing. |
17 |
42 |
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0 |
|
0 |
|
0 |
0 |
0 |
0 |
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Capital Cost for test facility, or |
8 |
16 |
5 |
432.75 |
245 |
9297.75 |
10 |
291.5 |
260 |
4160 |
160352 |
Julian Maurice Davis:
Represents a 10 year amortized rate that should not be altered until 2027.
5333 |
2335 |
42664 |
37360 |
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Contract Cost per emissions test |
9 |
26 |
1 |
86.55 |
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0 |
1 |
29.15 |
2 |
52 |
3008.2 |
|
Julian Maurice Davis:
Estimated cost of a contract to run one compliant EPA Part 86 FTP.
4500 |
0 |
117000 |
Julian Maurice Davis:
Total O&M and Capital Costs
197024 |
|
| 86.438-78, 86.439-78 |
Amendments to the application ("running changes" requiring the issue of a new certificate revision number) |
18 |
183 |
|
0 |
1 |
37.95 |
4 |
116.6 |
5 |
915 |
28282.65 |
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0 |
0 |
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| 86.416-80 |
Certify Using Previous Year Cert Data |
38 |
240 |
|
0 |
1 |
37.95 |
4 |
116.6 |
5 |
1200 |
37092 |
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0 |
0 |
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| 86.410-2006(g) |
Permeation Testing (if applicable) |
55 |
140 |
|
0 |
1 |
37.95 |
1 |
29.15 |
2 |
280 |
9394 |
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0 |
0 |
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0 |
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| 86.415-78(a) |
Production testing |
9 |
9 |
|
0 |
1 |
37.95 |
1 |
29.15 |
|
0 |
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0 |
0 |
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| 86.434-78 |
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Comment:
We assume the manufacturer must prepare and ship the test engine to EPA's designated test facility. Little labor should be needed for a drain and package of a vehicle.
EPA Confirmatory Testing |
6 |
6 |
|
0 |
1 |
37.95 |
1 |
29.15 |
|
0 |
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0 |
0 |
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| 86.415-78(b) |
Production vehicle test reports (45-day report) |
55 |
282 |
|
0 |
1 |
37.95 |
Julian Maurice Davis:
We estimate four quarters of compiling sales and production reports to account for the total number of hours spent each year reporting production to the EPA.
4 |
116.6 |
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0 |
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0 |
0 |
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| 86.449 |
Averaging report (end-of-year report) |
4 |
61 |
|
0 |
1 |
37.95 |
4 |
116.6 |
5 |
305 |
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0 |
0 |
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| 85.1903 |
Emissions Defect Reporting |
4 |
4 |
1 |
86.55 |
1 |
37.95 |
1 |
29.15 |
3 |
12 |
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0 |
0 |
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| 85.1904 |
Voluntary Emissions Recall Report |
4 |
4 |
1 |
86.55 |
4 |
151.8 |
4 |
116.6 |
9 |
36 |
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0 |
0 |
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| 86.440-78 |
Julian Maurice Davis:
Every respondent must maintain their own records for the activities reported here.
Record Keeping requirements: General records of vehicles, history of engine family certification, routine emissions test records, and all other records related to certification and testing to be kept for 6-years. |
55 |
282 |
|
0 |
Julian Maurice Davis:
Compiling all the test records for storage per engine family, including models under the engine family.
4 |
151.8 |
Julian Maurice Davis:
Filing and maintaining in a database on a quarterly basis.
4 |
116.6 |
8 |
2256 |
|
Julian Maurice Davis: Represents the amortized expense of a database purchase over a ten-year period.
1000 |
Julian Maurice Davis:
Represents the cost to utilize and maintain the database for this recordkeeping requirement per year.
100 |
55000 |
28200 |
Julian Maurice Davis:
Total Recordkeeping O&M and Capital costs
83200 |
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929 |
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Per engine family application |
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Totals |
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321 |
15420 |
$461,275 |
$6,333 |
$6,935 |
$97,664 |
$182,560 |
$280,224 |
$741,499 |
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280 |
$1,635.73 |
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13164 |
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NAICS classification: 336991 |
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Motorcycle and motorcycle parts manufacturers |
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336310 |
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Motor Vehicle Gasoline Engine and Engine Parts Manufacturing |
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Labor: |
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NAICS 336000: |
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Transportation Equipment Manufacturing |
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Category- |
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NAICS cost |
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Comment:
We have used this multiplier as a reflection of teh total labor cost (wages + all benefits) from the BLS Employer total cost dataset ( 2018).
BLS Employer Tptal Cost Multiplier |
Total |
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Management (11-0000) |
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66.58 |
1.3 |
86.55 |
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Engineering/Technical (17-3029) |
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29.19 |
1.3 |
37.95 |
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Administrative (43-0000) |
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22.42 |
1.3 |
29.15 |
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Information Collection Activity |
Agency Activity |
Total Hours |
Responses |
Mangerial/ Technical ($137.94) |
Admin ($35.87) |
Total Labor/ Cost |
Total Labor Hours |
| 86.416-80 |
Prepare and Submit application for certification |
Review Applications |
6 |
282 |
275.88 |
2 |
143.48 |
4 |
118259.52 |
1692 |
| 86.427-78 |
Perform emissions testing on the EDV, including service accumulation and deterioration factor testing. |
Review Emissions Test Data |
0 |
|
0 |
|
0 |
|
0 |
0 |
|
Capital Cost for test facility, or |
|
0 |
|
0 |
|
0 |
|
0 |
0 |
|
Contract Cost per emissions test |
|
0 |
|
0 |
|
0 |
|
0 |
0 |
| 86.438-78, 86.439-78 |
Amendments to the application ("running changes" requiring the issue of a new certificate revision number) |
|
0 |
|
0 |
|
0 |
|
0 |
0 |
| 86.416-80 |
Certify Using Previous Year Cert Data |
Review Applications |
3 |
282 |
137.94 |
1 |
71.74 |
2 |
59129.76 |
846 |
| 86.410-2006(g) |
Permeation Testing (if applicable) |
Review Permeation information |
0 |
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0 |
|
0 |
|
0 |
0 |
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0 |
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0 |
|
0 |
|
0 |
0 |
| 86.415-78(a) |
Production testing |
Select for testing and assess compliance of test article |
11 |
9 |
1379.4 |
10 |
35.87 |
1 |
12737.43 |
99 |
| 86.434-78 |
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Comment:
We assume the manufacturer must prepare and ship the test engine to EPA's designated test facility. Little labor should be needed for a drain and package of a vehicle.
EPA Confirmatory Testing |
Select for testing and assess certification vehicle for compliance |
11 |
6 |
1379.4 |
10 |
35.87 |
1 |
8491.62 |
66 |
| 86.415-78(b) |
Production vehicle test reports (45-day report) |
Receive and review reports |
2 |
282 |
137.94 |
1 |
35.87 |
1 |
49014.42 |
564 |
| 86.449 |
Averaging report (end-of-year report) |
Receive and review reports |
2 |
4 |
137.94 |
1 |
35.87 |
1 |
695.24 |
8 |
| 85.1903 |
Emissions Defect Reporting |
Receive and review reports |
2 |
|
137.94 |
1 |
35.87 |
1 |
0 |
0 |
| 85.1904 |
Voluntary Emissions Recall Report |
Assess validity of VERR plan, approve or consult until approval |
2 |
|
137.94 |
1 |
35.87 |
1 |
0 |
0 |
| 86.440-78 |
Julian Maurice Davis:
Every respondent must maintain their own records for the activities reported here.
Record Keeping requirements: General records of vehicles, history of engine family certification, routine emissions test records, and all other records related to certification and testing to be kept for 6-years. |
Receive and review reports |
n/a |
0 |
0 |
0 |
0 |
0 |
0 |
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39 |
865 |
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$248,328 |
3275 |
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Level |
Rate |
Rate Increase by 1.6 |
Response obligations |
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| Engineer |
GS-13/6 |
$86.21 |
$137.94 |
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| IT and Admin Support |
|
$22.42 |
$35.87 |
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$173.81 |
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