-COST ANALYSIS-
COMPLIANCE ASSURANCE PROGRAM FOR LIGHT-
DUTY VEHICLES AND LIGHT-DUTY TRUCKS

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2
Cost Analysis for the Cap 2000 Final Rule
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 adopted. 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 in-use
verification testing. We expect that the 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 finalizing this rule because it will be
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

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3
expected costs for the CAP 2000 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 final rule is the transfer of control
over the timing of the certification review process from EPA
to the manufacturer. This was accomplished by delegating
most Agency decisions to the manufacturers (with appropriate
Administrative oversight for the quality of the manufacturer
decision). This rule also allows 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 ah initio) . For manufacturers who plan their
certification programs closely to their production
schedules, such a benefit is clearly quite valuable but not

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easily quantifiable.
4
A. Durability Program Savings
One of the principal areas of cost savings is the 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 new durability grouping procedures will
result in most manufacturers performing 75 to 80% fewer
durability demonstrations.1
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. CAP 2000 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-
*To be conservative, a 75% percent reduction is used in
the cost calculations. A study of ihe 1997 vehicle fleet
indicates that the overall savings are 80% for the 10
largest manufacturers.

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5
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 nave 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
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 allows manufacturers to
bypass the process of calculating deterioration factors by
installing the bench-aged components described iri*°t)ption 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 $4 5 million annually depending on the
assumptions used.

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6
B. Emission Data Vehicle (EDV) Reductions
Cost savings are being claimed which will result from
replacing the current "Engine Family" concept with "Test
Groups" for the purposes of emission testing and certificate
coverage. The Agency estimates that this change will reduce
the number of certifications required by about 20% compared
to the number of the current engine families2. Also, the
Agency is requiring that only one vehicle per test group
undergo emission testing rather than the current two per
engine family. The rule also allows a greater opportunity
to reconfigure and re-use test vehicles by removing some
restrictions present in the current program. The rule 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 finalizing a manufacturer-conducted confirmatory
testing program which will eliminate the need for some
agency confirmatory testing4. The cost analysis accounts
for the costs saved by net 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
2Based on confidential projections submitted by
individual manufacturers for 1997 vehicles.
development vehicles are vehicles currently used by
the manufactures to develop their calibrations. The
provision allowing the use of development vehicles for
emission data purposes saves the manufacturer the cost of
building a unique EDV.
4The 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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7
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
CAP 2000 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, CAP 2000
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.
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 the proposed rule (see 63 FR 39653) contains a
more detailed discussion about EPA's information
requirements. Some manufacturers have questioned EPA's
conclusion that information kept by the manufacturer will

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8
result in large recordkeeping and submittal cost savings.
They contend that they will still be expending 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 3 5 percent and the maximum cost estimate uses an
estimated savings of 20 percent.
1. Highlighted Areas of Information Costs and Savings
Test Groups: The adoption of test groups as the unit of
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 rule, which results
in a corresponding information savings related to durability
tests and durability vehicles. It should be noted that
manufacturers are required 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.

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9
In-Use Testing: The current certification program contains
an optional element of in-use testing (known as RPD-1). The
CAP 200 0 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 rule 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 practice which frequently
results in redundant submissions), EPA is requiring 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 last updated 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 CAP 2000. 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

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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
ICR reporting burden-hours for running changes, which are
currently estimated at 110 burden-hours per action, would be
more accurately stated at 2 0 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
manufacturers' 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 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 coxes 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 requirements 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 CAP 2000. The box on the
left headed "Minimum Cost Estimate" reflects burden-hours
per action revised according to EPA staff's Le;=t 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
$35 million depending on the assumptions used. The
revisions to the ICR reflecting these changes have been
approved by OMB under OMB number 2060-0104.
In the ICR which accompanies this proposal, the Agency
used the figures from the "EPA Estimate" column of the
information cost analysis table.

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D. Cost of New In-Use Verification Program
The Agency is requiring 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 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
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
5Small volume manufacturers may be exempt depending on
sales levels

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13
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 requiring
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 capped 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 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
anal^ois 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 reducing the amount of EDV testing, it
is not reducing 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

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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 CAPE 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.
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 cf 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 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

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15
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
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 per
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 	 _
Net Durability Savings
$35,701,176
$22,775,760
$24,573,478
$45,791,125
Net Emission Vehicle Savings*
$2,487,890
$4,044,683
* accounts for the added cost of the


new mfr confirm test program


Costs
Cost of New In-use Verif Program
$6,442,447
$16,154,428
Cost of In-use Conf Program
$0
$604,000
Cost of New FEDV's
$249,951
$1,629,975
Cost of Submission of CAFE to NHTSA
$900
$900
Total Annual Savings
$56,069,245
$54,222,265

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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%
$6,250
$8,000
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 	
AMA: DDV Vehicle cost
Cost range for accumulation: AMA100k
Percent using AMA 	
Small Volume: DDV Cost & Mi Accum
$6,250
$6,400
10%
Assume 75% recovery on $25,000 outlay
Max: estimate Min: from a mfrs 4k accumulation estimate
Estimate, based on 1997 Data
$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
$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 Enqine 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
$25,000
$25,000
Assume $25,000 vehicle cost completely lost
Cost range for accumulation: Accelerated
$125,000
$160,000
Estimate
Percentage accumulation: Accelerated
25%
25%
Estimate
Tests per DDV
4
20

Optional Backups Vehicles
14
128
1 -2 Backups per Durability Group
Bench Procedures:



Engine Aging plus mi accum cost/DDV
$6,400
$8,000
Max: estimate Min: from a mfrs 4k accumulation estimate
Percentage using Bench procedures
75%
75%
Estimate
DFcalculated for EDV's



Cost of DDV
$6,250
$6,250
75% recovery because car does not lose all of its value
Tests per DDV
2
8
1 -4 tests before and after aging
Percent of Bench aging with DF calc
50%
50%
Initial estimate, less as program matures and mfrs switch to less expensive aged componi
No DPs - Aged components on EDVs



Cost of DDV (or components for Min)
$1,500
$6,250
No DDV necessary if only aging components; Component cost for min
Tests per DDV
0
2
Don't need tests if sole purpose is aged catalyst
Number of aged catalysts / Dur group
1
3
May need to age several catalysts in Dur Group
Percent of Bench aqinq w/o DF's
50%
50%
Initial estimate, higher as program matures & mfr switch to less expensive aged compone
Test Costs
1 Cost per test for FTP (No SFTP for DF)
$800
$1,200|| Estimate |
Number of Vehicles
# of Large volume Dur Groups
70
80
Based on 75% - 80% reduction from current families, less for small volume
Percent of Durability carryover
80%
20%
80% is current estimate based on 1997 data, 20% is worst case
# of Large volume Vehicles/year
14
64
#Families x (1 • percent C/O)
# of Small Volume Dur Groups
10
20
Estimate
# Small volume Vehicles /yr
0
0
Use assigned DPs so no vehicle or test cost

Required Cost
$652,488
$5,000,000
Prorated costs based on type of durability, LDT vs LDV and rate of occurance
Optional backup for Track Procedures
$536,200
$6,688,000
No backups for Bench tests
Total Annual Cost
$1,188,688
$11,688,000


|Net Annual Durability Savings
I $24,573,478
$45,791,125
| Min-Min or Max-max |

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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

I TOTAL ANNUAL COST
$4,722,020
$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. M0
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

TOTALANNUALCOST
Net Annual EDV Savings
$2,235,030
$2,487,890
$4,008,488
$4,044,683
Mm-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
|FTP/SFTP
$1,440|
$2,7001
From SFTP rulemaking |
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/rejection
FTP/SFTP Testing
Total procur + FTP/SFTP testing Costs
Number of In-Use test groups
Number of In Use testing vehicles
Total for FTP/SFTP Tests
$2,440
300
2400
$5,856,000
$4,600
300
3000
$13,800,000
80% of 400 Families - Sm vol
8-10 test vehicles each
Test Cells
New Facility Cost - Tests/cell/yr
Total tests needed
% of Testing requiring new cells built
No of New cells
Cost of Test Cell
Total Cost
Cost/yr for 10 yr life
750
2160
50%
1.44
$2,000,000
$2,880,000
$410,047
750
2560
100%
3.41
$4,000,000
$13,653,333
$1,943,928
at 3 tests/day, 250 days/yr.
Tests-EDV saved — DDV savings would reduce further
estimate
estimate for FTP emission cell
Assume 10 years, 7% interest/year
Evap Testing
Enhanced Evap/ORVR
Evap/ORVR Tests
Total for Evap/ORVR
$2,100
80
$168,000
$5,000
80
$400,000
min: staff estimate; max: from a mfrs submittal
| Annual Cost of New In-use Progra $6,442,447 $16,154,428

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Annual In-Use Confirmatory Cost Analysis

Minimum
Maximum
Comments
Procurement Costs Per Vehicle inc/udina:
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
Testina Costs Per Vehicle
FTP/SFTP
$1,440
$2,700
From SFTP rulemaking
Data Reoortina 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
Annual Cost of In-use Confirm Program
$0 |j $604,0001

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Annual Information Cost Analysis
Current Information Process
Current EPA Estimates
Reporting
Number of
Actions
Burden-hr
per action
Total
Burden-hr
Total $
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 (DD
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
ICR 2060-0104 (199S)
Number of Burden-hr
Total
Actions per action Burden-hr Total S
380 i
2440
927,200!
$64,904,000!
20 j
620
12.4001
$868,000|
190:
575
109,250!
$7,647,5001
20!
100
2.000!
$140,0001
8001
110
88,0001
$6,160,000 j
761
76
5,776
$404,320!
304!
10
3,040
$212,800 j
685:
76
52,0601
$3,644,200 j
912 i
2 i 1,824
$127,680 j
16951
2i 3,390
$237,300!
3001
4
1,200!
$84,000 j


1,206,140 j
$84,429,8001
-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
Large manufacturers
Test vehicles				
Totaffor Recordkeeping
25
761
o o
°
CM
30,000
30,440
$2,100,000
$2,130,800

60,440
$4/230,800
I ANNUAL TOTALS
I 938,6001 $65,702[000l
25;
781'
1500
50
37,500; $2,625,000]
38,050 j $2,663,500!
75,5501	$5,288^5001
1,281.690 j $89,718,300;
Labor Cost S/Hr: $70
Number
of Actions
inimum Cost Estimate
Burden-hr Total
CAP 2000 Information Process
Maximum Cost Estimate
Total
Test Groups (TGHarge
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 Vehicle
56
10
560
$39,200
Emission Data Vehicles
360
10
3,600
$252,000
In-Use Vehicles
2400
2
4,800
5 336,000
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 forReporting


397,115
$27,798,064
Recordkeeping
Large manufacturers
Test vehicles
25
374
780
32
19,500
11,968
$1,365,000
$837,760
Total for Recordkeeping

I 31,4681 $2,202,760
Number
of Actions
Burden-hr Total
Total
-Numbers of actions taken from other spread sheets
-MIN S MAX are based on current estimates of burden-hrs
304
1,464
445,056
$31,153,9201
Burden-hr; MIN- 50% smaller based on staff estimate. MAX- 25%
20
422
8,432
$590,240 j
Burden-hr: MIN- 25% smaller based on staff estimate, MAX- 15%
190
460
87,400
$6,118,000)
Burden-hr: MIN-save 20%, MAX-0%
20
80
1,600
$112,000}
Burden-hr: MIN-save 20%, MAX-0%
800
8
6,400
$448,000]
Burden-hr: Savings in both MIN & MAX
64
76
4,864
$340,480
# of Actions: see Dura: Max & Min. Burd-hr: Min: 20% less, Max: 0%
16
10
160
$11,200;
# of Actions: see Durability Sheet: Max & Min. Burden-hr 0%
360
10
3,600
$252,000]
# of Actions: See EOV sheet
3000
2
6,000
$420,000:
# of Actic is; set In-Use Verifc Sir et, MIN & MAX
620
2
1,240
$86,800 i
Burden-hr Staff Estimate
660
2
1,320
$92,400 [
From EDV tests (Ma*)=1 FTP /EDV-M Evap/EvF+1 Cold CO/Dur Grot
3100
2
6,200
$434,000!
Pr01?1 In-Use Verification ant) Confirmatory using MAX numbers


572,272
$40,059,MO;

25
424
960
40
24,000
16,960
$1,680,0001
$1,187,200
Burden-Hr
Burden-Hr
MIN: save 35%, MAX: 20%
MIN; save 20%, MAX: 0%


40,960
$5,8677200!
—
I ANNUAL TOTALS
428,583 [ $30,000,8241 £
613,232] $42,926,240!
Net Annual Info Savings
| | 510,017| $35,701,176

I I 326,3681 $22,775,7601
Percent Savings
i I 54% | S4%

~ i 1 25% | 25% 1

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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

| Total Annual Cost
| $249,951
| $1,629,975
I
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 postage

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EPA-420-R-99-104

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