EPA-AA-CPSB-83-03
Technical Report
Reporting and Recordkeeping Burdens
Associated with EPA's Fuel Economy Program
Clifford D. Tyree
May 1983
NOTICE
Technical Reports do not necessarily represent final EPA
decisions or positions. They are intended to present technical
analysis of issues using data which are currently available.
The purpose in the release of such reports is to facilitate the
exchange of technical information and to inform the public of
technical developments which may form the basis for a final EPA
decision, position, or regulatory action.
U. S. Environmental Protection Agency
Office of Air, Noise, and Radiation
Office of Mobile Sources
Certification Division
Certification Policy and Support Branch
2565 Plymouth Road
Ann Arbor, Michigan 48105
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I. Purpose
This report estimates the reporting and recordkeeping
burdens associated with the Environmental Protection Agency's
(EPA) fuel economy program. This assessment was undertaken to
fulfill the requirements of the Office of Management and Bud-
get's (OMB) Form SF 83 for the proposed rulemaking entitled
"Revisions to Improve Fuel Economy Labeling and the Fuel Econ-
omy Data Base." In particular, this assessment responds to
question numbers 17, 18, and 19 of Part III.
II. Background
This report relies upon the information submitted to the
OMB in September of 1981 to obtain Clearance No. 2000-0390
which applies to the EPA Motor Vehicle Certification and Fuel
Economy Program.1 The reporting and recordkeeping burdens
for the Fuel Economy program are only a part of the materials
covered by Clearance No. 2000-0390. This report only discusses
the burdens attributable to the Fuel Economy program. The data
of the 1981 submission was provided to EPA by eight manufac-
turers. The manufacturer's estimates were combined to develop
composite reporting burden estimates for the entire industry.
The resources requirements associated with each particular
function are based on -the September document because the regu-
lations pertaining to the fuel economy program have not changed
since the date of the original submission. The number of test
vehicles, labels for a given model year, etc., have changed
slightly since the 1981 model year and, appropriate adjustments
have been made.
Ill. Annual Reporting/Recordkeeping Burden
Questions 17 and 18 of Part III deal with the reporting
burden and recordkeeping burden respectively. Data submitted
by the manufacturers were not of sufficient detail that would
allow a meaningful separation of reporting and recordkeeping
burdens. Therefore, this assessment will describe the overall
reporting/recordkeeping burden.
1. "Reporting and Information Collection Burdens Associated
with EPA's Motor Vehicle Emission Certification and Fuel
Economy Program," September 1981.
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The areas associated with recordkeeping and reporting a^e
in 40 CFR Part 600:
1. Vehicle Information Books
2. ' Labeling Requirements
3. Interior Volume Calculations
4. Relabeling
5. Final CAFE Data
Each of these items is discussed below:
1. The proposed regulation has deleted the requirements
for routinely submitting the vehicle data description books.
The manufacturers must, however, maintain these data in their
files. The resources estimated by the manufacturers for the
1981 model year was 73 hours per vehicle. By eliminating the
requirement of submitting actual vehicle books EPA estimates
that this resource requirement has been reduced by 40 percent.
1983 model year data indicate that yOl fuel economy data vehi-
cles were actually tested. However, of these 901 vehicles, 300
of the vehicles are unique vehicles. The remaining 601 vehi-
cles are tests conducted on the original 300 vehicles. The
information currently submitted on these 601 vehicles is min-
imal and is estimated to be 10 hours per vehicle. Thus, the
resource requirement for vehicle data books is:
(73 hours per vehicle x .6) x 300 vehicles = 13,400 hours
(10 hours per vehicle ) x 601 vehicles = 6,010 hours
Total = 19,150 hours
2. The manufacturers estimated that it required 6 hours
per label to process the data and submit the required informa-
tion to EPA. The proposed regulation establishes a standard
format which will be adhered to by all manufacturers. The in-
formation on the label has been reduced as well as the need to
obtain prior EPA approval before using a label. The fuel econ-
omy data depicted on the label must still be provided to EPA.
EPA estimates the label reporting burden will be reduced from 6
hours per label to 1 hour per label. The 1983 label data base
indicates there were 1,915 labels approved for the 1983 model
year. The estimated resource burden is:
1,915 labels x 1 hour per label = 1,915 hours
3. The interior volume is calculated for each car line
configuration. The changes made in the interior volume calcu-
lation methodology ha^e not changed. The composite industry's
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estimated resource requirement for this area was 8 hours per
car line. For 1983 there were 251 car lines. The resource
requirement is:
251 car lines x 8 hours per car line = 2,008 hours
4. The relabeling requirement is a new requirement. EPA
has estimated that it will take 1,144 hours to recalculate and
update sales projection for the industry.2
5. The proposed rules will eliminate the need for preli-
minary CAFE and will retain only the final CAFE data require-
ments. EPA estimates that it will take the 7 major manufac-
turers 4-person weeks to satisfy the recordkeeping reporting
burden and the remaining 25 manufacturers 2-person weeks each.
The resource requirement is:
(7 x 40 x 4) + (25 x 40 x 2) = 3,120 hours
IV. Summary
The Annual Report/Recordkeeping Burden
Vehicle Information 19,150
Labeling 1,915
Interior Volume Calculations 2,008
Relabeling 1,144
CAFE 3,120
Total 27, 337 hours
Question 19 of Part III ask.s for the difference between
the annual burden in the current OMB inventory and the explana-
tion of the difference. The current annual burden is 32,125
hours. The net difference is a decrease of 4,788 hours of
annual recordkeeping/reporting burden. This decrease comes
about because of the elimination of the preliminary CAFE
requirements, reduced vehicle information reporting require-
ments, and by incorporating a standardized label format.
2. Tyree, C.D., "Cost Analysis of Proposed Changes to 40 CFR
Part 600 to Improve Fuel Economy Labeling and the Fuel Economy
Data Base," September 1982, EPA Report IN"O. EPA-AA-CPSB-82-03.
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