Burden and Cost Calculations

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Overview

HWY MTC Manufacturers
IC Reporting Obligations
Respondent Burden
.02 Respondent Burden
Agency Burden
EPA Wages
Industry Wages

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Sheet 1: HWY MTC Manufacturers

Year 2019
Total Number of Manufacturers	55
Small Manufacturers	10
Foreign Manufacturers	?
Large Manufacturers (>10,000 sales)/ non-SVM	45

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Sheet 2: IC Reporting Obligations

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
Confirmatory test	86.434-78		Requested by the EPA and performed at the direction and location of the EPA test order.
Production testing	86.415-78(a)		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.
Amendments to the Application	86.438-78, 86.439-78		As requested by the manufacturer for various purposes, i.e. add models or alter certified configurations.
Maintain certificaiton and testing records	86.440-78
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)
Emissions Defect Reporting	85.1903		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.
Voluntary Emissions Recall Report	85.1904		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.
Maintenance of Records	86.440-78		(1) General Records(A) Identification and description of all certification vehicles for which testing is required under this subpart.
			(B) A description of all emission control systems which are installed on or incorporated in each certification vehicle.
			(C) A description of all procedures used to test each such certification vehicle.
			(2) Individual records. (i) A brief history of each motocycle used for certification under this subpart including:
			(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.
			(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.)
			(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.
			(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.
			(C) The date of each service accumulation run, listing the distance accumulated.
			(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.
			(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.
			(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.
			(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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Sheet 3: Respondent Burden

	Information Collection Activity	Respondents (manufacturers)	Annual Occurrences of Activity	Managerial/$104.94		Engineer/ $71.53		Technologist/ 46.23		Administrative/ $38.17		total hrs per activity	total labor cost per activity	Total Hours per yr	Total Labor Cost/ Year	total hours per respondent (manufacturer) per year	total labor costs per respondent (manufacturer) per year	Capital & Startup per Activity per respondent (manufacturer)	O&M per Activity per respondent (manufacturer)	Total Capital Cost/ year	Total O&M Cost/ Year	Total Non-Labor Cost/ Year	Total Cost/ Year
86.416-80	Prepare and Submit application for certification	95	314	2	$210	4	$286	4	$185	16	$611	26	$1,292	8,164	$405,555	86	$4,269						$405,555
86.427-78	Perform emissions testing on the EDV, including service accumulation and deterioration factor testing.
	Internal Test facility	3	4	5	$525	10	$715	250	$11,557	10	$382	275	$13,179	1,100	$52,714	367	$17,571	$5,333	$2,335	$15,999	$9,340	$25,339	$78,053
	Contract Cost testing	16	17	1	$105	2	$143	3	$139	1	$38	7	$425	119	$7,222	7	$451		$5,000	$-	$85,000	$85,000	$92,222
	Electric Motorcycle manufacturers	27	40								$-	-	$-	-	$-	-	$-					$-	$-
86.438-78, 86.439-78	Amendments to the application ("running changes" requiring the issue of a new certificate revision number)	18	183		$-	1	$72	1	$46	4	$153	6	$270	1,098	$49,488	61	$2,749			$-	$-	$-	$49,488
86.416-80	Certify Using Previous Year Cert Data	49	253		$-	1	$72	0	$-	4	$153	5	$224	1,265	$56,722	26	$1,158			$-	$-	$-	$56,722
86.410-2006(g)	Permeation Testing (if applicable)	55	140		$-	1	$72	1	$46	1	$38	3	$156	420	$21,829	8	$397			$-	$-	$-	$21,829
86.415-78(a)	Production testing	9	9		$-	1	$72	1	$46	1	$38	3	$156	27	$1,403	3	$156			$-		$-	$1,403
86.434-78	EPA Confirmatory Testing	6	6		$-	1	$72	5	$231	1	$38	7	$341	42	$2,045	7	$341			$-	$-	$-	$2,045
86.415-78(b)	Production vehicle test reports (45-day report)	95	314		$-	1	$72	1	$46	4	$153	6	$270	1,884	$84,914	20	$894			$-	$-	$-	$84,914
86.449	Averaging report (end-of-year report)	4	61		$-	1	$72	0	$-	4	$153	5	$224	305	$13,676	76	$3,419			$-	$-	$-	$13,676
85.1903	Emissions Defect Reporting	4	4	1	$105	1	$72	1	$46	1	$38	4	$261	16	$1,043	4	$261			$-	$-	$-	$1,043
85.1904	Voluntary Emissions Recall Report	4	4	1	$105	4	$286	5	$231	4	$153	14	$775	56	$3,099	14	$775			$-	$-	$-	$3,099
86.440-78	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.	95	314		$-	1	$72	1	$46	4	$153	6	$270	1,884	$84,914	20	$894	$1,000	$120	$95,000	$11,400	$106,400	$191,314
	Unique Respondents:	95	1663										total	16,380	$784,626				Total	$110,999	$105,740	$216,739	$1,001,365			Total non-labor per response
		Engine families	314										Reporting	14,496	$699,712					Reporting	$15,999	$110,339	$110,339			351.3980891719750
		Average annual activites per respondent	17.5052631578947										Recordkeeping	1,884	$84,914					Recordkeeping	$95,000	$106,400	$106,400			338.8535031847130
														Hrs	Labor Costs	O&M	Capital	Total Non-Labor Costs	Total Costs
													Total Average Annual	16,380	$784,626	$105,740	$110,999	$216,739	$1,001,365
														Hrs	Labor Costs	O&M	Capital	Total Non-Labor Costs	Total Costs
													Per Respondent (95 manufacturers) per Year	172	$8,259	$1,113	$1,168	$2,281	$10,541
Color Legend	Certification
	Reporting													Hrs	Labor Costs	O&M	Capital	Total Non-Labor Costs	Total Costs
	Record Keeping												Per engine family (314 total)per Year	52	$2,499	$337	$354	$690	$3,189
													Change between .03 and what .02 should have been									Delta from .03 to what was in .02 ICR
	NAICS classification: 336991			Motorcycle and motorcycle parts manufacturers										Hrs	Labor Costs	O&M	Capital	Total Non-Labor Costs	Total Costs			RESPONDENTS	40
	336310			Motor Vehicle Gasoline Engine and Engine Parts Manufacturing									Total Average Annual	(480)	$190,123			$(44,805)	$145,318			BURDEN HOURS	960
	Labor:																					LABOR COST	$323,351
	NAICS 336000:													Hrs	Labor Costs	O&M	Capital	Total Non-Labor Costs	Total Costs			OPERATING COST	$(76,820)
	Category-												Per Respondent per Year	(134)	$(2,550)			$(2,474)	$(5,024)			CAPITAL COST	$13,355
			Multiplier (130%)																			non-labor costs	$(63,465)
	Mangement	$80.72	$104.94											Hrs	Labor Costs	O&M	Capital	Total Non-Labor Costs	Total Costs			total cost	$259,886
	Legal Asstsance	$72.11	$93.74										Per engine family (282 to 314 total)per Year	(8)	$391			$(237)	$153
	Engineer	$55.02	$71.53
	Engineer technologist	$35.56	$46.23
	Administrative Support	$29.36	$38.17

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Sheet 4: .02 Respondent Burden

	Information Collection Activity	Respondents (manufacturers)	Responses (Engine Families)	Managerial/$104.94		Engineer/ $71.53		Technologist/ 46.23		Administrative/ $38.17		total hrs per activity	total labor cost per activity	Total Hours per yr	Total Labor Cost/ Year	total hours per respondent (manufacturer) per year	total labor costs per respondent (manufacturer) per year	Capital & Startup per Activity/respondent (manufacturer)	O&M per Activity/response	Total Capital Cost/ year	Total O&M Cost/ Year	Total Non-Labor Cost/ Year	Total Cost/ Year
86.416-80	Prepare and Submit application for certification	55	282	2	$177	0	$-	4	$152	16	$466	22	$795	6,204	$224,275	113	$4,078						$224,275
86.427-78	Perform emissions testing on the EDV, including service accumulation and deterioration factor testing.
	Internal Test facility	8	16	5	$443	0	$-	245	$9,298	10	$292	260	$10,032	4,160	$160,512	520	$20,064	$5,333	$2,335	$42,664	$18,680	$61,344	$221,856
	Contract Cost testing	9	26	1	$89	0	$-	0	$-	1	$29	2	$118	52	$3,060	6	$340		$4,500	$-	$117,000	$117,000	$120,060
	Electric Motorcycle manufacturers	0	0								$-	-	$-	-	$-							$-	$-
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	$38	4	$117	5	$155	915	$28,283	51	$1,571			$-	$-	$-	$28,283
86.416-80	Certify Using Previous Year Cert Data	38	240		$-	0	$-	1	$38	4	$117	5	$155	1,200	$37,092	32	$976			$-	$-	$-	$37,092
86.410-2006(g)	Permeation Testing (if applicable)	55	140		$-	0	$-	1	$38	1	$29	2	$67	280	$9,394	5	$171			$-	$-	$-	$9,394
86.415-78(a)	Production testing	9	9		$-	0	$-	1	$38	1	$29	2	$67	18	$604	2	$67			$-		$-	$604
86.434-78	EPA Confirmatory Testing	6	6		$-	0	$-	1	$38	1	$29	2	$67	12	$403	2	$67			$-	$-	$-	$403
86.415-78(b)	Production vehicle test reports (45-day report)	55	282		$-	0	$-	1	$38	4	$117	5	$155	1,410	$43,583	26	$792			$-	$-	$-	$43,583
86.449	Averaging report (end-of-year report)	4	61		$-	0	$-	1	$38	4	$117	5	$155	305	$9,428	76	$2,357			$-	$-	$-	$9,428
85.1903	Emissions Defect Reporting	4	4	1	$105	0	$-	1	$38	1	$29	3	$172	12	$688	3	$172			$-	$-	$-	$688
85.1904	Voluntary Emissions Recall Report	4	4	1	$105	0	$-	4	$152	4	$117	9	$373	36	$1,493	9	$373			$-	$-	$-	$1,493
86.440-78	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	$-	4	$152	4	$117	8	$268	2,256	$75,689	41	$1,376	$1,000	$100	$55,000	$28,200	$83,200	$158,889
		55	1253										Total:	16,860	$594,503				Total:	$97,664	$163,880	$261,544	$856,047
		Engine families	282										Reporting	14,604	$518,814				Reporting	$42,664	$135,680	$178,344	$697,158
		Average annual activites per respondent	22.7818181818182										Recordkeeping	2,256	$75,689				Recordkeeping	$55,000	$28,200	$83,200	$158,889
														Hrs	Labor Costs	Non-Labor Costs	Total Costs
													Total Average Annual	16,860	$594,503	$261,544	$856,047
														Hrs	Labor Costs	Non-Labor Costs	Total Costs
													Per Respondent per Year	307	$10,809	$4,755	$15,564
Color Legend	Certification
	Reporting													Hrs	Labor Costs	Non-Labor Costs	Total Costs
	Record Keeping												Per engine family (282 total)per Year	60	$2,108	$927	$3,036
													From .02 SS
	NAICS classification: 336991			Motorcycle and motorcycle parts manufacturers									RESPONDENTS	55
	336310			Motor Vehicle Gasoline Engine and Engine Parts Manufacturing									BURDEN HOURS	15,420
	Labor:												LABOR COST	$461,275
	NAICS 336000:												OPERATING COST	$182,560
	Category-												CAPITALIZED COST	$97,644
			Multiplier (130%)										total non-labor costs	$280,204
	Mangement	$80.72	$88.55										total cost	$741,479
	Legal Asstsance	$72.11	$93.74
	Engineer	$55.02	$71.53
	Engineer technologist	$35.56	$37.95
	Administrative Support	$29.36	$29.15

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Sheet 5: Agency Burden

	Information Collection Activity	Agency Activity	Hours per activity	Responses	EPA Employee Average Wage ($158.00)		Admin ($20.35)		Total Labor/ Cost	Total Labor Hours
86.416-80	Prepare and Submit application for certification	Review Applications	6	314	$316.00	2	$81.41	4	$124,785.08	1884
86.427-78	Perform emissions testing on the EDV, including service accumulation and deterioration factor testing.	Review Emissions Test Data	n/a	274	$-	0	$-	0	$0.00	0
86.438-78, 86.439-78	Amendments to the application ("running changes" requiring the issue of a new certificate revision number)		n/a	139	$-	0	$-	0	$0.00	0
86.416-80	Certify Using Previous Year Cert Data	Review Applications	n/a	253	$-	0	$-	0	$0.00	0
86.410-2006(g)	Permeation Testing (if applicable)	Review Permeation information	n/a	0	$-	0	$-	0	$0.00	0
86.415-78(a)	Production testing	Select for testing and assess compliance of test article	11	12	$1,579.98	10	$20.35	1	$19,204.03	132
86.434-78	EPA Confirmatory Testing	Select for testing and assess certification vehicle for compliance	11	12	$1,579.98	10	$20.35	1	$19,204.03	132
86.415-78(b)	Production vehicle test reports (45-day report)	Receive and review reports	2	314	$158.00	1	$20.35	1	$56,002.01	628
86.449	Averaging report (end-of-year report)	Receive and review reports	2	4	$158.00	1	$20.35	1	$713.40	8
85.1903	Emissions Defect Reporting	Receive and review reports	2	0	$158.00	1	$20.35	1	$0.00	0
85.1904	Voluntary Emissions Recall Report	Assess validity of VERR plan, approve or consult until approval	2	0	$158.00	1	$20.35	1	$0.00	0
86.440-78	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	$0.00	0
				1322					$219,909	2784
	Level	Rate	Rate Increase by 1.6
Engineer	Average EPA Employee wage with 1.6% mulitplier	$98.75	$158.00
IT and Admin Support	Administrative Assistance	$12.72	$20.35

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Sheet 6: EPA Wages

SALARY TABLE 2022-DCB (opm.gov)
		Multiplier (1.6%)
GS-14	74.8495192307692	119.759230769231
GS-13	59.9163461538462	95.8661538461539
GS-12	50.3884615384615	80.6215384615385
Admin (2)	12.72	20.352
Average EPA	98.7489743589744	157.998358974359

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Sheet 7: Industry Wages

Motor Vehicle Manufacturing - May 2022 OEWS Industry-Specific Occupational Employment and Wage Estimates (bls.gov)
		Multiplier (130%)
Mangement	80.72	104.936
Legal Asstsance	72.11	93.743
Engineer	55.02	71.526
Engineer technologist	35.56	46.228
Administrative Support	29.36	38.168