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

-------
                                  -2-
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.

-------
      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

-------
                                  -4-
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.

-------
                                                 01 to
                                                                            rot usz azsim>« i-a
                                                                                                    -5-
             READ INSTRUCTIONS BEFORE CBHETlNG FORM.  00 HOT USE THE SAKE SF 83 TO SIMULTANEOUSLY REQUEST  AH
             j5ttUTIVE ORDER 12291  REVIW AMD APPROVAL IXCER THE PAPERWORK REDUCTION ACT.

             WSWER ALL QUESTIONS IN PART I. IF THlS**S AKO TELEPHONE DUMBER OF PERSON
              CAfl 8«ST AHSVER QUESTIONS REGARDING
              THIS REQUEST


              Cliff Tyree   374-8310
    4. TITLE OF INFOfiKATIC* CDLLECTIC* OR ..	
     Applications  for Motor  Vehicle Emission Certification and  Fuel  Econony
            Labeling	
    5.  LEGAL AUTHORITY FOR (NFORftATIC* COUECTICfl OR RULE
       (CITE (.KITE3 STATM CAS. PUBLIC LAV, OX
       OSQQ)
I5_  use 2005;
                              k  42  USC 7525,75 4 2
    8. A/FECTEO PU3L1C (CHSCX AU, THAT A??'.T)
           1. IXDtVZDUAU 01
           2. STATS Oa LOCAL
           3. TAKXA
           4. Bususssis on oiun Foa-?xoriT
           S. rZDUAL ACUCIZS 01 Qt?LOYZZS
           6. SON-P807IT iMstrrwrioaa
           7. SMALI. BUSINESSES. OR ORGANIZATIONS
 PART II.  COMPLETE THtS PART ONLY  IF THE REQUEST IS FOR 0*8 REVIEW UNDER EXECUTIVE ORDER 122Sfl.
      .  REGULATORY  INFORMATION HtttER (RlN)




      .  TYPE OF SUBMISSION

        CLASSIFICATION

          a 1. KAJO«
          £7 2. 80WAJO*

      '  STAGE OF CfVELCPXXT
          O i.  noposro ox CUR
          O 2.  ruuL a* umxa ruui., vira
   C7 3. 7CUL ca urraa ?ctu.. VTTSOJT
         PZOPOUL
                                              mot
TYPE OF
                     RECUESTI9
          CI I-  STAWBAM
          C7 2.  FDTOiyQ
          £7 )•  OU3CZBCT
          C7 *.  STATUTOW 01
                                                    9, CFR SECTION AFfECTED

                                                               CP»
                                                    .. DOES THIS  REGULATION CONTAIN HEPORTIftG OR RECORD-
                                                      K£EPIN« REQUlREMeNTS THAT REQUIRE C*B APPROVAI..U8K
                                                      THE PAPEBWRX SEOLtTIW ACT AND 5 CFR 1223?
U. IF A WMC* RULE, IS THEM A REGULATWY IMPACT
    ANALYSIS ATTACHED?

       I. res d    2. HO  C3 — i? so. ow CKS «AIVZ
                                TBZ MtALYSIST

                                3. Y« £7  4. SO ^7
                                                  12, OOES THIS REGUUTICN AFFECT ANY TRACE SENSITIVE
                                                      ACTIVITY?
                                                            res £7
                         £7
CERTIFICATION  FOR REGULATORY SUpfflSSICMS:
CONTACT AKO THE PROGRAM OFFICIAL CERTIFY THAT THE
BEEN COMPLIED WITH.
                                       I» SU8MITTIM  THIS REQUEST FOS CM3 REVIEW, TKS. AUTHORIZES PE'ULATCPY
                                       REQUI?.£.M£ffTS OF £.0. 12291 A.HO WY APPLICABLE WLIC7  DIRECTIVES M"~
SI&KATUZZ 07 ?UC2AM 077ICIAL
                                           QAIZ
SICKATlfiU Of AiTJCSIZD R2CUUSOW CD>JTAC7    3.

-------
PArtTTFT,  CO«Kt7£~7HIS PARr^LYJlFl"TH£1flEQ^'sTlTsl''?6RnAP?rtl'vALltJo)""A1 COLLECT -.
  .      •  REDUCTION ACT AflO S CF3 1320.	
  '  >T~A3SlRACT - DXSCms NUBS,  I'S'lS AM) AJFECTED PUBUC  III 50 WORDS 01 LSSS          "         "	
       Project  information runnlied  by  manvfactursra  is  uecCl to verify      _6_
       that  test requirements  have been satisfied.   Test  results  are re-
       viewed  to determine if  emission  standards  have been met  and to  establish
H.TYP5 Of INFORHATKJJl COLLECTION (CSKX OMt^OHLT)

   INFORMATION COLLECTIONS NOT CONTAINED IN RULES
     £7 1.  RZCTUi SUSHIS31W
     £7 2.  ceacacr suausstov
            (CQTITiaTICa ATTACB2D)
   INFORMATION COLLECTIONS CONTAINED IN RUUS
     £7 3.  DUSTING RSGUUTIOS (J!0 C3A.SCJ PROPOSED)
     £•74.  HOTXCZ OF PX070SXO RUI9UXCBS (5FTM)
     £7 5.  FIHAL, Hm HAS PUVIOCStt PU1LI23ZO
         6.  FtHAL OR INTZXCt 7IXAL WITHOUT PRIOR
            £7 A. RSCOUU
            a».
           DATE OF EXPECTSO 01 ACTOAt rtOPAI.
           PUBUCATJOM AT T3LS SIACZ 0? SULSiAXIM —

                                 . 19JB3 ,
             R£VI£y REQL'ESTEO (C22a 0« ONLY)
         £7  i. raw
         Q  2. R£V1SI0.1 OF A aiUam.! AmOVZD COUZCTIOJ1
         C7  3. KTEUIOSI 07 THE OfflRAtlOH DATS OT A
               anuL£3rn.Y /APPROVED cotucrxoM WITHOUT AKY
               CBANCZ  IH TR2 SV3STAMC2 OX in TBZ KSTBOD
               OF COLLICTIOJt
         O  *• aUWSTATEKBIT OF A PSEVIOUSW APPROVED
               COU.ECTICN FOR WHICH APPROVAL HA3 O7IX20
         £7  5. EXISTING COOZCTION IN USJ WITSJflin Ail CH3
                                                            NUMBER
                                                                    (WST'RECENtycm COMTWl HiJM8£a CR C(>ME«T

                                                                      2000-0390
                                                         21 . REQUESTED EIPIRAHOM OATS
                                                        22. PURPOSE OF INFCWATION COLL£CTICM (C3ZCC AS
                                                            AS A??LT)
                                                                                  1

                                                            £7 1. APPtiatlOH FOR MHETITS
                                                            £7 2. PROCTUH EVALUATION
                                                            £7 3. CZXUAL ?WP03X STATISTICS
                                                            £2 4. &2CUUTOH Oi CCtOLUHCZ
                                                            £7 S. ?Rcct,Mt ?uunaw OR >WUCSGQ-ficWL c^
 "AL-r-iOQ;ZE3_«EPaESENTATrvE. CERTIFIES THAT THE RF^lilSEVE'iTS 0? THE ?«:v,\:V ACT AflO OHi
                                                                          OH3 DIReCTIVcS HAVE :£:H CC^'.IES
WITH INCLUDING PAPERWORK REGULATIONS, STATISTICAL STANCARCS CR DIRECTIVES. AND AflY OTHES INFOWATICJC POLICY DlPiC^vn
""       JJNDEa THE PAPERMRK SEruCTiai ACT 0? 1330.	[	
                                                 "OAIE  T  SICSAi'VRE OF ACEMCf SEAO OR  fdS SS.NIOR      CATS
 s::.NArjHE CF PSOCXAK OITICIAL
                                                           crr:ci\. oa

-------