-DRAFT COST ANALYSIS-
PROPOSED COMPLIANCE ASSURANCE PROGRAM
FOR LIGHT-DUTY VEHICLES AND LIGHT-DUTY
TRUCKS
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Cost Analysis for the Cap 2000 Proposal
I. Emission Benefits
The Agency is not quantifying or claiming direct
emission benefits as a result of this rule because no new
emission standards are being proposed. Nevertheless, the
Agency expects that the new compliance procedures will
result in fewer noncomplying vehicles in use, thereby
reducing, to some degree, ambient emission levels. Such a
reduction is virtually impossible to quantify. The reason
for this potential reduction is linked to the proposed in-
use verification testing. We expect that the proposed
requirement for manufacturers to provide EPA with in-use
emission data will have the effect of motivating
manufacturers to design cleaner, more durable vehicles in
order to avoid potential recall situations. This in-use
data will also allow the Agency to better target recall
investigations and to help identify in-use emissions
problems earlier in the vehicle's life, thus making recalls
more effective. Consequently, the Agency believes that
there are several indirect emission benefits associated with
this rulemaking.
II. Cost Analysis
The Agency is proposing this rule because it will be
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both more effective in controlling emissions from light-duty
vehicles and trucks and also because it will achieve these
benefits at a lower cost for the regulated industry.
The cost analysis is broken into six areas. In each
area the current program is evaluated and compared to the
expected costs for the proposed CAP 2 000 program. Both a
maximum and minimum projection of costs are calculated.
Savings are calculated using the associated costs of
the current procedures and the CAP 2000 procedures. The
savings under the "Using Maximum Costs" heading are
calculated as maximum current costs minus the maximum CAP
2000 costs. The savings under the "Using Minimum Costs"
heading are calculated as minimum current costs minus the
minimum CAP 2000 costs. A cross product calculation of
savings using the maximum minus minimum and minimum minus
maximum costs was not calculated since these calculations
would either overstate savings or overstate costs beyond a
reasonable basis.
A summary is provided which combines the costs from
all the separate areas. In total, the Agency has calculated
an annual cost savings of about $55 million (depending
whether high or low projections are used). Details of the
calculations in the six areas are explained below.
Beyond the numbers, a key intangible benefit for
manufacturers of the proposal is the transfer of control
over the timing of the certification review process from EPA
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to the manufacturer. This was accomplished by delegating
most Agency decision to manufacturers (with appropriate
Administrative oversight for the quality of the manufacturer
decision). The proposal will also allow manufacturers to
obtain a certificate of conformity based on manufacturer-
generated test data while an Agency confirmatory test is
pending (with the proviso that if the Agency test fails the
manufacturer must recall any vehicles produced and the
certificate becomes void ab initio). For manufacturers who
plan their certification programs closely to their
production schedules, such a benefit is clearly quite
valuable but not easily quantifiable.
A. Durability Program Savings
One of the principal areas of cost savings is the
proposed new durability process. The cost savings will be
achieved by allowing manufacturers to reduce the number of
durability demonstrations (by means of changing the grouping
procedures from "engine families" to "durability groups").
The agency estimates that the proposed new durability
grouping procedures will result in most manufacturers
performing 75 to 80% fewer durability demonstrations.1
To be conservative, a 75% percent reduction is used in
the cost calculations. A study of the 1997 vehicle fleet
indicates that the overall savings are 80% for the 10
largest manufacturers.
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Savings are also achieved by replacing the costly and
somewhat outdated AMA mileage accumulation procedures with
less costly and more effective alternative types of
durability demonstrations. The CAP 2000 proposal allows
manufacturers to design their own durability process to
simulate the emission deterioration they expect their
vehicles to experience in actual use. This provision allows
manufacturers to use any of the following durability
demonstration options:
(1) Accelerated whole-vehicle track procedures, where the
mileage accumulation is faster than the AMA, thereby
reducing labor costs;
(2) Compressed whole-vehicle track procedures where a fewer
number of miles accumulated under more severe conditions
would be equivalent to the full useful life (e.g., 40,000
miles run on the severe schedule equals 100,000 miles in-
use). The severity could be achieved by a combination of
such driving techniques as extreme accelerations and
decelerations, extremely high speed, and other techniques
which have the effect of rapidly aging the emission
components; or
(3) Bench-aging procedures where key emission components
(such as the catalyst and oxygen sensor) are removed from a
stabilized test vehicle, aged on an engine dynamometer for
the equivalent of 100,000 miles of use, then re-installed on
the same vehicle. This vehicle is tested both before and
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after the bench aging to obtain the rate of emissions
deterioration. The bench-aging approach significantly saves
the cost and time of either of the whole-vehicle mileage
accumulation methods (accelerated or compressed). It also
saves the cost of mileage accumulation past the stabilized
mileage point (e.g. 4000 miles) and leaves the test vehicle
with more residual value.
Another cost savings option which is being proposed
would allow manufacturers to bypass the process of
calculating deterioration factors by installing the bench-
aged components described in option 3 above on emission data
vehicles, which, when tested with these components,
represent vehicles at their full useful lives. This approach
saves the cost of building a DDV. It also saves the cost of
the mileage accumulation required on the DDV.
The attached analysis estimates the savings using both
a high and low line of assumptions. The sources of the cost
and activity numbers used in the analysis are explained in
the comments accompanying the table. The analysis estimates
the savings associated with the durability process to be
between $24 to $45 million annually depending on the
assumptions used.
B. Emission Data Vehicle (EDV) Reductions
Cost savings are being claimed which will result from
the proposal to replace the current "Engine Family" concept
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with "Test Groups" for the purposes of emission testing and
certificate coverage. The Agency estimates that this
proposal will reduce the number of certifications required
by about 20% compared to the number of the current engine
families2. Also, the Agency is proposing that only one
vehicle per test group undergo emission testing rather than
the current two per engine family. The proposal also allows
a greater opportunity to reconfigure and re-use test
vehicles by removing some restrictions present in the
current program. The proposal also allows the expanded use
of development vehicles3 as EDV's.
Another cost of the certification process is the cost
of shipping a vehicle to EPA for confirmatory testing. The
Agency is proposing a manufacturer-conducted confirmatory
testing program which will eliminate the need for some
agency confirmatory testing4. The proposed cost analysis
Based on confidential projections submitted by
individual manufacturers for 1997 vehicles.
Development vehicles are vehicles currently used by the
manufactures to develop their calibrations. EPA's proposal
to allow the use of development vehicles for emission data
purposes saves the manufacturer the cost of building a
unique EDV.
The Agency will retain a confirmatory test program to
assure the validity of manufacturer test results and conduct
testing on vehicles of concern.
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accounts for the costs saved by not shipping vehicles to the
Agency's test facility and the added cost to the
manufacturer of running the confirmatory test program.
The attached analysis estimates the savings using both
a high and low line of assumptions. The sources of the cost
and activity numbers used in the analysis are explained in
the comments accompanying the table. The analysis estimates
an annual savings of $2 to $4 million for emission testing
requirements depending on the assumptions used.
C. Information Submission
The CAP 2000 proposal contains requirements for
manufacturers to collect and report information to support
their requests for certification and for fuel economy
compliance. The same types of information are required in
the current certification and fuel economy programs.
However, the CAP 2000 proposal significantly reduces the
amount of information which manufacturers are required to
submit in the application for certification. Most
information would only be submitted by the manufacturer upon
Agency request. EPA estimates that about 75 percent of the
information required to be submitted currently will not be
required to be submitted under CAP 2000. However some of
this information may be requested by the Agency at a later
time. EPA conservatively estimates the net information
reporting, including the later Agency requests for
information, to be 50 percent of the current level.
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Although manufacturers may be required to submit
certain information upon request, recordkeeping costs will
be reduced since EPA is not requiring manufacturers to
compile or retain the information in a specified format.
Moreover, the type of information which EPA would request is
information that the Agency believes the manufacturer would
have for reasons other than for emission compliance. The
Preamble to this proposal contains a more detailed
discussion about EPA's proposed information requirements.
Some manufacturers have questioned EPA's conclusion that
information kept by the manufacturer will result in large
recordkeeping and submittal cost savings. They contend that
they will still be expending the nearly the same effort to
maintain information which EPA may or may not request. EPA
acknowledges that there may be some information which the
Agency may later request that requires specific
recordkeeping costs for the manufacturer. In most cases the
information that the Agency may request is normal business
information that will be retained by the manufacturer for
other reasons. Consequently, the reduction in recordkeeping
costs used in this analysis is less than the proportional
reduction based on the savings of reporting requirements.
The minimum cost estimate uses an estimated savings of 35
percent and the maximum cost estimate uses an estimated
savings of 20 percent.
1. Highlighted Areas of Information Costs and Savings
Test Groups: The proposal for test groups as the unit of
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testing and certification has a number of ramifications for
information savings. First, there are fewer test groups
than the current number of engine families this fact alone
will reduce the number of reports. Also, the reduced number
of tests per test group (as compared to number of tests per
engine families) will reduce that reporting burden.
Durability Groups: Significantly fewer durability
demonstrations will be required in this proposal, which
results in a corresponding information savings related to
durability tests and durability vehicles. It should be
noted that EPA's proposal requires manufacturers to submit
only one application per durability group. However, since
much of the information is likely to be specific to each
test group, EPA's cost analysis assumes that manufacturers
will submit applications on a test group basis.
In-Use Testing: The current certification program contains
an optional element of in-use testing (known as RPD-1). The
CAP 2000 program takes this element and makes it mandatory
for all manufacturers except for the very smallest.
Therefore there are added costs for reporting in-use
vehicles and in-use tests.
Running changes: The CAP 2000 proposal includes changes to
the requirements for reporting running changes and
application updates which are expected to result in
significant savings in burden-hours. Rather than requiring
updated application pages with each running change (a
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practice which frequently results in redundant submissions),
EPA is proposing to require that manufacturers submit
updates to the Application twice during the model year.
2. Discussion of Modifications to EPA's Information
Collection Request (ICR) 2060-0104.
Two actions concerning EPA's ICR 2060-0104 are
occurring which impact EPA's information cost analysis. The
first is an ICR update, which is required every three years
in accordance with the Paperwork Reduction Act, 44 U.S.C.
3501 et seq. EPA is scheduled to update ICR 2060-0104 in
1998. (The purpose of regular ICR updates is to account for
any changes which may have occurred in the interim period
regarding information collection.) The second action is the
amendment of the ICR to account for changes in information
collection specifically brought about by the CAP 2000
proposal. During the process of updating the current ICR,
EPA identified several areas in the current certification
process where reporting burdens appear to be generally
overstated. This conclusion was based on EPA's assessment of
the current information submittal practices, which indicates
that, in general, reporting burdens are less than those
stated in the current ICR. The burden-hours for large and
small engine families and large and small evaporative
families are reduced by 20%.
In addition, three areas have been identified where EPA
believes even larger reductions are appropriate: First, the
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ICR reporting burden-hours for running changes, which are
currently estimated at 110 burden-hours per action, would be
more accurately stated at 20 hours per running change
action. This conclusion is based on the running change
information which manufacturers have submitted to EPA in the
past few model years. Second, the current ICR reporting
burden of 4 hours per test for the in-use tests required by
the Alternate Durability Program ("ADP"), would more
accurately be estimated at 2 hours per test. At the time
that the 1995 ICR was approved, EPA and industry had little
or no experience with in-use testing requirements. In the
intervening years, more experience in this area has been
gained which has led EPA to reach this new estimate. Third,
the reporting burden hours for an emission data vehicle
(EDV) which is estimated in the current ICR as 76 hours per
vehicle, would be more accurately represented at 10 hours
per vehicle. Again, EPA bases this conclusion on
manufacturers1 EDV information submitted over the past few
model years.
EPA believes it is important that the certification ICR
reflect as much as possible the current actual reporting
burdens so that savings brought about by the CAP 2000
proposal are not artificially overstated. Because a major
goal of this program was to reduce burden to manufacturers,
EPA was particularly concerned that any savings shown would
be overstated by comparing the current ICR figures to those
EPA estimated for CAP 2000. Therefore, in its cost
analysis, EPA has chosen to use the revised figures, as
discussed above, for a comparison basis.
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3. Explanation of "Annual Information Cost Analysis" table
The table "Annual Information Cost Analysis" is
organized as follows. At the top are 2 joined boxes labeled
"Current Information Process". Within this, the box on the
right headed "ICR 2060-0104 (1995)" contains burden-hours
per action from that ICR. This information is included for
informational purposes, and is not used in the actual
analysis. The box on the left headed "Current EPA Estimates
(To be listed in 1998 ICR)" contain the burden-hours per
action which reflect the changes discussed in paragraph 2.
above. The bottom boxes are headed "CAP 2000 Information
Process". The right box, "Maximum Cost Estimate", reflects
the maximum cost, using only minor burden-hours reductions
from the "Current EPA Estimates". It is included to reflect
the industry contention that certain aspects of EPA's
information collection proposal present much less savings in
burden-hours per action than would be predicted based on the
amount of information which is no longer required to be
submitted under the CAP 2000 proposal. The box on the left
headed "Minimum Cost Estimate" reflects burden-hours per
action revised according to EPA staff's best estimates. The
number of actions are based on the minimum estimates from
the corresponding program cost table as listed in the
comments section of the information cost table.
The sources of the cost and activity numbers used in
the analysis are explained in the comments accompanying the
table. The analysis estimates an annual savings of $22 to
$3 5 million depending on the assumptions used. The
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revisions to the ICR reflecting these changes are being
submitted to OMB for approval concurrently with this
proposal.
In the ICR which accompanies this proposal, the Agency-
used the figures from the "EPA Estimate" column of the
information cost analysis table.
D. Cost of New In-Use Verification Program
The Agency is proposing to require that all
manufacturers5 perform an in-use verification test program.
This program will require the manufacturer to procure and
test a number of customer owned vehicles for the purpose of
determining the level of actual emission performance in use.
Currently there are about 40 engine families certified to
the revised durability (RDP-1) procedures which require up
to 15 in-use vehicles per engine family (some carryover of
in-use test data is currently permitted) for a total of
about 600 vehicles. In order to present worst-case cost
estimates, the cost analysis does not subtract the cost of
these vehicles from the total cost of the proposed in-use
verification program.
The analysis considers high and low estimates for all
the inputs. Although the higher test cost assumes the use
of a contractor testing facility, both levels of the
5Small volume manufacturers may be exempt depending on
sales levels
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analysis consider the costs for building new testing cells.
The number of testing cells required is based on a
contractor supplying the service, consequently the number of
cells needed assume full utilization. Smaller utilization
rates would increase the number of cells built and their
cost but would have minimal effect on the overall analysis.
The attached analysis estimates the costs using both a
high and low line of assumptions. The sources of the cost
and activity numbers used in the analysis are explained in
the comments accompanying the table. The analysis estimates
an annual cost of $6 to nearly $16 million depending on the
assumptions used.
E. Cost of New In-Use Confirmatory Program
If the results of the in-use verification program reach
a trigger point which shows a significant level of
noncompliance with the standards in use, EPA is proposing to
require the manufacturer to conduct a recall-quality testing
program called the In-Use Confirmatory Program. There is a
wide spread in cost estimates, because of the uncertainty of
how much of this type of testing will be performed. At
best, no testing will be required, hence a low estimate of
$0. EPA has proposed to cap a manufacturer's potential
annual confirmatory testing liability at 50% of the number
of that manufacturer's test groups. This assumption was used
as the worst-case cost estimate. In actuality, EPA believes
that very few test groups will reach the trigger point, so
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the cost estimates will likely fall on the lower side.
The vehicle procurement costs are based on EPA's 1997
recall test costs. The attached analysis estimates the
costs using both a high and low line of assumptions. The
analysis estimates an annual cost of $0 to about $600,000
depending on the assumptions used.
F. Fuel Economy Program Costs
1. Costs to Replace Emission Data Vehicles for the
Fuel Economy Program.
Some emission data vehicle (EDV) tests are ultimately
used in the CAFE calculations performed at the end of the
year. While EPA is proposing to reduce the amount of EDV
testing, it is not proposing to reduce the required fuel
economy testing. Consequently a reduction in EDV testing
would lead to an increase in testing for fuel economy (that
is, the data no longer collected for emissions purposes may
still be needed for fuel economy purposes.) However, since
manufacturers make production changes throughout the course
of the year, some EDV configurations are not actually put
into production and their tests are not used in the CAFE
calculations. Furthermore, manufacturers have complete
discretion to determine which vehicles they will test to
meet the 90% data coverage requirements of the CAFE
calculation regulations, so several EDV calibration tests
may not need to be replaced in some cases if a single higher
selling calibration is tested in their place.
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This analysis quantifies the cost of replacing the EDVs
saved in the certification program in the CAFE calculation.
The minimum and maximum values are based on assumptions of
50 to 100 percent replacement of EDVs and the minimum and
maximum number of EDVs saved according to the EDV cost
analysis described above. The effects of the use of
analytically derived data (data which is calculated on a
theoretical, rather than actual test vehicle basis) are
considered. The costs of confirmatory EPA testing and
shipping test vehicles are considered as well.
The attached analysis estimates the cost of running
fuel economy vehicles to replace the EDVs saved in the
certification program to be between $250 thousand and $1.6
million per year, depending on the assumptions used.
2. CAFE Reporting to NHTSA
The cost of the proposed requirement for manufacturers
to submit their annual CAFE reports to the National Highway
Traffic and Safety Administration as well as to EPA has been
included in the analysis, and is estimated to be $900
annually for the entire automotive industry. This amount
covers the cost of reproducing and sending the report to
NHTSA. The cost of developing the CAFE report and
submitting it to EPA is not accounted for in the analysis
because that cost is unchanged from the current ICR.
General Assumptions:
In the attached cost analysis for information
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requirements, the number of units given for the current
compliance program information process (e.g. number of
tests, vehicles, engine families, etc.) are taken from
actual 1996 model year numbers. The labor cost of $70
hour is taken from EPA's ICR 2060-0104.
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Estimates of Annual CAP 2000 Savings
Savings Using Minimum Costs Using Maximum Costs
Net Information Savings
$35,701,176
$22,775,760
Net Durability Savings
$24,573,478
$45,791,125
Net Emission Vehicle Savings*
* accounts for the added cost of the
new mfr confirm test program
$2,487,890
$4,044,683
Costs
Cost of New In-use Verif Program
$6,461,605
$16,245,249
Cost of In-use Conf Program
$0
$604,000
Cost of New FEDVs
$249,951
$1,629,975
Cost of Submission of CAFE to NHTSA
$900
$900
Total Annual Savings
$56,050,088
$54,131,444
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Durability Annual Cost Analysis - Current Program
Minimum Maximum Comments
Vehicle Buildup & Mi Accum
Accelerated Track Proc: DDV Vehicle cost
Cost for mileage accumulation
Percentage using accel track proc
$25,000
$125,000
10%
$25,000
$160,000
10%
Assume $25,000 vehicle cost completely lost
Based on AMA estimates below and anticipated savings for accelerated accum
Estimate, based on 1997 Data
Bench: DDV Vehicle cost
Cost range for Mi accum + Bench
Percent using bench proc
$6,250
$6,400
10%
$6,250
$8,000
10%
Assume 75% recovery on $25,000 outlay
Max: estimate Min: from a mfrs 4k accumulation estimate
Estimate, based on 1997 Data
AMA: DDV Vehicle cost
Cost range for accumulation: AMAIOOk
Percent using AMA
$25,000
$152,000
80%
$25,000
$225,000
80%
Assume $25,000 vehicle cost completely lost
Max: estimate Min: from a mfrs submittal and RDP analysis
Estimate, based on 1997 Data
Small Volume: DDV Cost & Mi Accum
$0
$0
Use Assigned DF's, costs are information only
Test Costs
Cost per test for FTP (no SFTP)
Tests per DDV Vehicle
$800
4
$1,200
20
Estimates
Number of Vehicles
LDV-Large Volume
# of Vehicles/year
Optional Backup Vehicles for AMA
Optional backup for Accel Track
44
88
44
44
132
88
1996 Certification data, (large-sm vol) 235-14 = 221, assume 80% C/O = 44
(Manufacturers opt to build 2-3 backup vehicles)
1-2 backup vehicles
LDT-Large Volume
# of Vehicles/year
Optional backups
33
0
33
33
1996 Certification Data (large - sm volume) 173-6 = 167, 80% C/O = 33
Use 0-1 backups (LDT does not usually have any backups)
Small Volume Engine Families
20
70
Low 1996 Total, High 70 familes based on current ICR
Required Cost
Optional Backup cost
$12,402,005
$13,360,160
$18,782,225
$38,696,900
Prorated costs based on type of durability, LDT vs LDV and rate of occurance
TOTAL ANNUAL COST (current)
$25,762,165
$57,479,125
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Durability Annual Cost Analysis -- CAP 2000
Minimum Maximum Comments
Vehicle Buildup & Mi Accum
Full Mileage, Accelerated Procedures:
Cost per DDV vehicle Full Mi Acell
Cost range for accumulation: Accelerated
Percentage accumulation: Accelerated
Tests per DDV
Optional Backups Vehicles
$25,000
$125,000
25%
4
14
$25,000
$160,000
25%
20
128
Assume $25,000 vehicle cost completely lost
Estimate
Estimate
1-2 Backups per Durability Group
Bench Procedures:
Engine Aging plus mi accum cost/DDV
Percentaqe usinq Bench procedures
$6,400
75%
$8,000
75%
Max: estimate Min: from a mfrs 4k accumulation estimate
Estimate
DF calculated for EDV's
Cost of DDV
Tests per DDV
Percent of Bench aqinq with DF calc
$6,250
2
50%
$6,250
8
50%
75% recovery because car does not lose all of its value
1-4 tests before and after aging
Initial estimate, less as program matures arid mfrs switch to less expensive aqed compon
No Dfs - Aged components on EDV's
Cost of DDV (or components for Min)
Tests per DDV
Number of aged catalysts / Dur group
Percent of Bench aaina w/o DF's
$1,500
0
1
50%
$6,250
2
3
50%
No DDV necessary if only aging components; Component cost for min
Don't need tests if sole purpose is aged catalyst
May need to age several catalysts in Dur Group
Initial estimate, hiqher as program matures & mfr switch to less expensive aaed comoone
Test Costs
iCost per test for FTP (No SFTP for DF1 H $80011 $1.20011 Estimate I
Number of Vehicles
# of Large volume Dur Groups
Percent of Durability carryover
# of Large volume Vehicles/year
# of Small Volume Dur Groups
# Small volume Vehicles /vr
70
80%
14
10
0
80
20%
64
20
0
Based on 75% - 80% reduction from current families, less for small volume
80% is current estimate based on 1997 data, 20% is worst case
#Families x (1- percent C/O)
Estimate
Use assianed DF's so no vehicle or test cost
Required Cost
Optional backup for Track Procedures
$652,488
$536,200
$5,000,000
$6,688,000
Prorated costs based on type of durability, LDT vs LDV and rate of occurance
No backups for Bench tests
Total Annual Cost
$1,188,688
$11,688,000
|Net Annual Durability Savings'
1
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Emission Data Vehicle Annual Cost Analysis
Current Program
Vehicle Cost Minimum Maximum Comments
Cost range per EDV
# of Vehicles/year
% Vehicles reconfigured
Labor cost for reconfiguration
Total Vehicle Costs
$6,250
600
20%
$350
$3,000,070
$6,250
800
20%
$850
$4,000,170
Assume $25,000 vehicle 75% recovery
MIN: 1.5x, MAX: 2x families, 400 families based on 1997 data
Estimates
Test Cost
FTP/SFTP cost per test
FTP/SFTP tests performed
Cold CO cost per test
Cold CO tests performed
Evap/ORVR cost per test
Evap/ORVR tests performed
Cert Short Test cost per test
Cert Short Test tests performed
Total Test Costs
$1,440
600
$500
370
$2,100
200
$500
370
$1,654,000
$2,700
800
$700
370
$5,000
200
$700
370
$3,678,000
MIN: estimate MAX: from a mfrs submittal
1 per Emission Data Vehicle
MIN: estimate MAX: from a mfrs submittal
1 test per Engine Family
MIN: estimate MAX: from a mfrs submittal
1 test per Evap family
MIN: estimate MAX: from a mfrs submittal
1 test per Engine Family
Cert Confirmatory Costs
Domestic cost shipment
Domestic vehicles sent
Foreign cost per shipment
Foreign vehicles sent
Total Confirmatory Shipment Costs
$50
117
$1,000
63
$68,850
$250
156
$4,000
84
$375,000
Shipping costs from manufacturer to EPA: estimate
30% of tests (current confirm test rate), 65% Domestic
Shipping costs from manufacturer to EPA: estimate
30% of tests (current confirm test rate), 35% Import
ITOTALANNUAL COST
$4,722,920
$8,053,170
I
Vehicle Cost
CAP 2000
Cost of New EDV minus recovery
# of Vehicles/year
% of EDV that are reconfigured
Labor cost to reconfigure
Total Vehicle Costs
$6,250
360
50%
$350
$1,125,175
$6,250
360
25%
$850
$1,687,713
1 per Test group, Test group = 80% Engine Family, EF=400
Allows reconfig from existing EDV and Develop vehicles
Estimates based on mfr discussions
Test Cost
FTP/SFTP cost per test
FTP/SFTP tests performed
Cold CO cost per test
Cold CO tests performed
Evap/ORVR cost per test
Evap/ORVR tests performed
Total Test Costs
$1,440
360
$500
100
$2,100
200
$988,400
$2,700
360
$700
100
$5,000
200
$2,042,000
MIN: estimate MAX: from a mfrs submittal
1 per Emission Data Vehicle
MIN: estimate MAX: from a mfrs submittal
1 test per durability group (75% reduction)
MIN: estimate MAX: from a mfrs submittal
1 test per Evap family
Cert Confirmatory Costs
Domestic cost shipment
Domestic vehicles sent
Foreign cost per shipment
Foreign vehicles sent
Cost of Confirm tests by Mfr
Total Confirmatory Costs
$50
35.1
$1,000
18.9
$100,800
$121,455
$250
35.1
$4,000
18.9
$194,400
$278,775
Shipping costs from manufacturer to EPA: Estimate
15% of vehicles tested. 65% domestic
Shipping costs from manufacturer to EPA: Estimate
15% of vehicles tested
20% of EF Tested FTP+SFTP, min $1440, max $2700/test
TOTAL ANNUAL COST
Net Annual EDV Savinas
$2,235,030
$2,487,890
$4,008,488
$4,044,683
Min-Min. Max-Max
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Annual In-Use Verification Costs
Minimum Maximum Comments
Procurement Costs per Car including:
Admin. Costs, Loaner cars & cash incentives
$1,000
$1,900
max1996 FY emission factors, min in-house recruitment
Difference is based on 100% overhead cost for contractor
Testing Costs
IFTP/SFTP
$1,440
$2.700II From SFTP rulemakina I
Rejected Vehicles
Vehicle Rejection Justification
Total for justification for rejection
$70
$8,400
$70
$10,500
1 hour at $70/hr
5% X total number of vehicles X the cost/reiection
Total procur + FTP/SFTP testing Costs
$2,440
$4,600
Number of In-Use test groups
300
300
80% of 400 Families - Sm vol
Number of In Use testing vehicles
2400
3000
8-10 test vehicles each
Total for FTP/SFTP Tests
$5,856,000
$13,800,000
Test Cells
New Facility Cost - Tests/cell/yr
750
750
at 3 tests/day, 250 days/yr.
Total tests needed
2160
2560
Tests-EDV saved — DDV savings would reduce further
% of Testing requiring new cells built
50%
100%
estimate
No of New cells
1.44
3.41
Cost of Test Cell
$2,000,000
$4,000,000
estimate for FTP emission cell
Total Cost
$2,880,000
$13,653,333
Cost/vr for 10 vr life
$429,205
$2,034,749
Assume 10 vears. 8% interest/vear
Evap Testing
Enhanced Evap/ORVR
$2,100
$5,000
min: staff estimate; max: from a mfrs submittal
Evap/ORVR Tests
80
80
Total for Evap/ORVR
$168,000
$400,000
lAnnual Cost of New In-use Program
$6,461,60511 $16,245,249
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Annual In-Use Confirmatory Cost Analysis
Minimum Maximum Comments
Procurement Costs Per Vehicle includiria:
Admin. Costs, loaner cars & cash incentives
$1,000
$2,000
Max 97 recall, Min: in-house recuitment
Restorative (set to spec) Maintenance Costs
$600
$1,200
Max: 97 recall, Min: in-house work
Note: our contractor has 100% overhead charge
IestLng_Costs PerJ/ehjcle
FTP/SFTP
$1,440
$2,700
From SFTP rulemaking
Data Reportina Per Vehicle
Labor
$140
$140
Min/Max: 2 labor hours at $70/hr
Total per vehicle In Use testing costs
Number of In Use testing vehicles
$3,180
0
$6,040
100
Min: estimate, Max = 20 test groups, 5 vehicles per TG
lAnnual Cost of In-use Confirm Program
$011 $604,000!
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Annual Information Cost Analysis
Current Information Process
Labor Cost (S/Hr): $70
Current EPA Estimates
(To be listed in new 1998 ICR)
Number of Burden-hr
Actions per action
Total
Total $
ICR 2060-0104 (1995)
Engine families (EF)-large
380
1,952
741,760
$51,923,200
Engine families-small
20
496
9,920
$694,400
Evaporative families (EvF)-large
190
460
87,400
$6,118,000
Evaporative families-small
20
80
1,600
$112,000
Running Changes (R/C)
800
20
16,000
$1,120,000
New Durability Data Vehicles (DDV]
76
76
5,776
$404,320
C/O DDVs
304
10
3,040
$212,800
Emission Data Vehicles (EDV)
685
10
6,850
$479,500
New Durability Tests
912
2
1,824
$127,680
Emission Tests
1695
2
3,390
$237,300
ADP In-use tests
300
2
600
$42,000
Total for Reporting
878,160
$61,471,200
Recordkeeping
Large manufacturers
25
1,200
30,000
$2,100,000
Test vehicles
761
40
30,440
$2,130,800
Total for Recordkeeping
60,440
$4,230,800
Number of Burden-hr Total
Actions per action Burden-hr
Total $
380:
2440:
927,200
$64,904,000
20:
620:
12,400:
$868,000
190
575
109,250;
$7,647,500
20:
100:
2,000"
$140,000
800 i
110
88,000:
$6,160,000
761
76!
5,776 :
$404,320
304!
io!
3,040:
$212,800
685 i
76|
52,060
$3,644,200
912:
2:
1,8241
$127,680
1695;
2!
3,390 j
$237,300
300!
4:
1,200;
$84,000
j
1,206,140;
$84,429,800
25!
1500:
37,500
$2,625,000
761 !
50:
38,050:
$2,663,500
75,550:
$5,288,500
IANNUAL TOTALS
938.6001 S65.702.0001
1.281.6901 $89.718.3001
-Max Costs using ICR #2060-0104 (1995 as modifed by SFTP)
-Numbers of actions are based on 1996 MY actual data
Burden-hr: 20% reduction from ICR
Burden-hr: 20% reduction from ICR
Assume 1 EvF per 2 EF-large; Burden-hr. 20% reduction from ICR
Assume 1 EvF per 1 EF-small; Burden-hr 20% reduction from ICR
MIN of 20 burden hours based on staff estimate
Assume 1 DDV per Engine Family, 80% carry-over
Assume 1.75 EDVs per EF; Burden-hr 10 hours -staff estimate
Assume 12 tests per new DDV
1 Test per vehicle: Evap+EDV+R/C. 1 vehicle per EvF and R/C
2 hours- staff estimate
CAP 2000 Information Process
Labor Cost $/Hr: £70
Reporting
Number
of Actions
Minimum Cost Estimate
Burden-hr Total
Maximum Cost Estimate
Total
Test Groups (TG)-Large
304
976
296,704
$20,769,280
Test Groups-small
20
372
7,440
$520,800
Evaporative families-large
190
368
69,920
$4,894,400
Evaporative families-small
20
64
1,280
$89,600
Running Changes
800
4
3,200
$224,000
New Durability Data Vehicles
14
61
851
$59,584
Carry-over Durability Data Vehicles
56
10
560
$39,200
Emission Data Vehicles
360
10
3,600
$252,000
In-Use Vehicles
2400
2
4,800
$336,000
Durability Tests
620
2
1,240
$86,800
Emission Tests
660
2
1,320
$92,400
In-Use Tests
3100
2
6,200
$434,000
Total for Reporting
397,115
$27,798,064
Number
of Actions
Burden-hr Total
per action Burden-hr
Total
304
1,464
445,056
$31,153,920
20
422
8,432
$590,240
190
460
87,400
$6,118,000
20
80
1,600
$112,000
800
8
6,400
$448,000
64
76
4,864
$340,480
16
10
160
$11,200
360
10
3,600
$252,000
3000
2
6,000
$420,000
620
2
1,240
$86,800
660
2
1,320
$92,400
3100
2
6,200
$434,000
572,272
$40,059,040
-Numbers of actions taken from other spread sheets
-MIN & MAX are based on current estimates of burden-hrs
-1995 ICR Numbers are not used in these calculations
Burden-hr MIN- 50% smaller based on staff estimate, MAX- 25%
Burden-hr MIN- 25% smaller based on staff estimate, MAX-15%
Burden-hr MIN-save 20%, MAX-0%
Burden-hr: MIN-save 20%, MAX-0%
Burden-hr Savings in both MIN & MAX
# of Actions: see Dura: Max & Min. Burd-hr: Min: 20% less, Max: 0%
# of Actions: see Durability Sheet: Max & Min. Burden-hr 0%
# of Actions: See EDV sheet
# of Actions: see In-Use Verific Sheet, MIN & MAX
Burden-hr Staff Estimate
From EDV tests (Max)=1 FTP /EDV+1 Evap/EvF+1 Cold CO/Dur Group
From In-Use Verification and Confirmatory using MAX numbers
Recordkeeping
Large manufacturers
25
780
19,500
$1,365,000
Test vehicles
374
32
11,968
$837,760
Total for Recordkeeping
31,468
$2,202,760
IANNUAL TOTALS
25
424
960
40
24,000
16,960
$1,680,000
$1,187,200
40,960
$2,867,200
428.5831 S30.000.8241 Q
Burden-Hr: MIN: save 35%, MAX: 20%
Burden-Hr: MIN: save 20%, MAX: 0%
613.2321 S42.926.240l
Net Annual Info Savinqs | I I 510,0171 $35,701,176
I I 325,3681 $22,775,760
Percent Savinqs I I I 54% | 54%
I I 25% | 25%
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Annual Fuel Economy Costs
Min Max Comments
Number of EDV tests Saved
% of EDVs which need to be replaced for FE
Number of FEDVs run to replace loss of EDVs
240
50%
90
440
100%
330
From EDV sheet
Estimate
Vehicle Cost
Cost range per EDV
# of Vehicles/year
% of EDV that are reconfigured
Labor cost to reconfigure
Total Vehicle Costs
$6,250
90
75%
$350
$140,888
$6,250
330
50%
$850
$1,031,675
Assume $25,000 vehicle 75% recovery
1/Test group, Test group = 80% EF, EF=400
Allows reconfig from existing FEDV and Develop vehicles
Estimates
Test Cost
FTP & Hwy
Number of Tests
Total Test Cost
$1,000
90
$90,000
$1,500
330
$495,000
Estimates
One set per vehicle
Cert Confirmatory Costs
Domestic cost shipment
Domestic vehicles sent
Foreign cost per shipment
Foreign vehicles sent
Cost of Confirm tests by Mfr
Total Confirmatory Costs
$50
8.78
$1,000
4.73
$18,000
$19,064
$250
32.18
$4,000
17.33
$99,000
$103,300
shipping costs from manufacturer to EPA: Estimate
15% of vehicles tested. 65% domestic
shipping costs from manufacturer to EPA: Estimate
15% of vehicles tested
20% of Vehicles Tested FTP, min $1000, max $1500/test
iTotal Annual Cost II $249.95111 $1.629.97511 1
Submission of CAFE Report to NHTSA
Submission of CAFE Report to NHTSA
$900
$900
Assume $.20 per page x 50 pages x 2 reports for 25 Mfrs
Plus $5 x 80 reports postaae
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EPA-420-D-98-100
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