This collection
is approved in part and disapproved in part. The portion of the
collection relating to investigations into possible noncompliance
with federal emissions standards of light-duty vehicles and
light-duty trucks is approved until June 30, 2002. That portion of
the collection relating to identification of trucks for
participation in tests using EPA's Realtime Onroad Vehicle
Emissions Reporter (ROVER) technology or a similar portable device
is also approved until June 30, 2002. The remainder of the
collection -- relating to procurement of heavy-duty trucks for
engine-based dynamometer tests -- is disapproved. In resubmitting
this collection for approval, EPA may wish to consider dividing
this collection into separate collections for light-duty and
heavy-duty engines. ***Light-Duty Vehicles and Trucks*** The
portion of the proposed collection relating to light-duty vehicles
and trucks is approved until June 30, 2002 to allow EPA to continue
this collection for a minimal amount of time while it prepares
revisions in accordance with these terms of clearance. Each form or
instrument used in the collection shall be clearly marked with this
expiration date. Notwithstanding this limited approval, OMB
believes that the collection is in need of substantial revision.
EPA should take immediate steps to revise the collection in
accordance with the following terms of clearance so as to permit
sufficient public notice of the proposed revisions and timely
submission of an ICR to OMB in spring 2002. EPA may wish to consult
with OMB during preparation of a successor ICR. In resubmitting
this ICR, EPA should address the following concerns: --Clarity and
Completeness of Submission OMB notes generally that the current ICR
fails to provide a transparent explanation of the program structure
and design. In revising the ICR in preparation for its next
submission, EPA should ensure that the ICR is transparent and can
be easily understood by a member of the general public who has no
specific knowledge of EPA's program. EPA should also ensure that
the submission contains all documents relevant to the collection,
including, for example, a copy of any instructions given to EPA
employees or contractors relating to the collection of information,
and copies of any waivers or other documents that respondents are
asked to complete upon surrendering their vehicle for testing. OMB
notes that the documents included in the submission contain
numerous spelling, grammatical, and typographical errors. EPA
should ensure that all documents conform to professional standards
of quality. --Need and Purpose of Collection EPA should clearly
explain the need for and purpose of the individual elements of the
collection as they relate to statutory and regulatory mandates. For
example, EPA should clarify the relationship of the individual
questions asked of respondents to the terms of Clean Air Act
section 207(c)(1) and any regulations promulgated pursuant to this
section. --Use of Data Collected EPA should ensure that the ICR
explains clearly the various program elements, the relationship
among these elements, and the specific intended use for any forms,
surveys, or other attachments included with the supporting
statements. For example, EPA should specifically describe the
confirmatory and surveillance testing programs, and the
relationship between these programs. Moreover, EPA should examine
whether its current use of these two programs represents the most
cost-effective means of meeting its statutory obligations with
respect to in-use testing, and make any needed revisions to its
program design. As noted above, in redesigning this collection, EPA
should clarify how each data element collected will be used by the
Agency in conformance with statutory duties. --Consultations with
Outside Parties In preparing the ICR, EPA should consult with
parties knowledgeable about the process, including if possible,
past participants in the collection. --Use of Incentives Provided
to Respondents OMB understands that EPA currently provides cash
incentives as high as a few hundred dollars, as well as access to a
loaner vehicle, and other incentives, such as a full tank of gas.
From discussions with EPA staff, however, it appears that these
incentives are awarded in some cases on an ad hoc basis. In
revising the collection, EPA should provide a full and complete
description of the incentives proposed to be used, and the basis
that will be used for determining the value of the incentive if
different incentives are provided to different respondents. In
particular, EPA should limit the incentives provided, in
conformance with OMB guidance on this matter, to the minimum
inducement necessary to generate an adequate number of vehicles to
be tested. --Confidentiality/Privacy Issues EPA should provide a
more complete description of the methods used to assure
confidentiality of data collected, including any restrictions
placed on use and storage of the data by contractors, engine
manufacturers, or other parties with access to the data. EPA should
incorporate in its submission specific verification of compliance
with the Privacy Act of 1974 and OMB Circular A-130. This includes
clarification as to whether the information collected is covered by
one or more systems of records, and if the information is so
covered, a copy of the Federal Register notice or notices
describing the system(s) of records. --Burden Estimates EPA should
review and revise the burden estimates for each instrument used in
the collection based on consultation with past or potential
respondents. Each form or instrument used for the collection should
contain an accurate estimate of the burden associated with
completion of that form. The ICR should identify the aggregate
respondent time and cost burden associated with the collection.
--Cost to Federal Government of the Collection EPA should provide a
complete accounting of the cost to the federal government of the
collection and use of the data collected, including an itemization
of the labor hours and cost and non-labor costs associated with the
various federal activities needed to conduct the collection.
--Statistical Methodology EPA should provide a clear and complete
description of the statistical methodologies used to conduct the
collection. This should begin with a clear description of the
universe of respondents to be sampled, a justification of this
sampling frame in reference to the goals of the collection, and a
step-by-step explanation of how EPA will collect information at
various stages of the collection. EPA should specifically address
the geographic limitations on the sampling frame as it relates to
the statutory basis for the collection. This discussion should also
include a detailed explanation of the approach used to identify
certain engine families for investigation in a given calendar year,
including a description of any sampling protocol that is used for
this purpose. The ICR should discuss the expected response rate and
decompose the number of expected responses by type (e.g.,
respondent interested and/or eligible) at each stage of the
collection, including the postcard used for initial screening, the
telephone survey, and contact with the respondent at the testing
facility. The ICR should also explain any follow-up that will be
conducted at each stage to increase the response rate, as well as
any expansion of the sampling frame that may be anticipated in the
event that the number of responses is inadequate to provide
sufficient vehicles for testing. --Survey Instruments OMB believes
that the survey instruments in current use by EPA should be
substantially redesigned to minimize burden on the respondents,
make use of current technology, and ensure greater accuracy of
responses. In particular, OMB is concerned that the telephone
surveys contained in the collection are cumbersome and ask a number
of questions -- such as detailed queries about each of the
respondents' previous oil changes -- that are burdensome, may lack
practical utility, and if appropriate at all, should be asked in a
written rather than verbal format. EPA should therefore review the
content of the survey to eliminate unneeded questions, reorder
questions to make the most efficient use of respondents' time, and
consider assigning some questions to a separate written instrument.
EPA may consult with OMB in conducting this evaluation. In
addition, EPA should consider using a Computer-Assisted Telephone
Interview (CATI) design to improve the efficiency of the survey
implementation and consistency of survey responses. EPA should
ensure that all survey instruments and associated documents (e.g.,
instructions to survey clerks or respondents) are included in the
ICR submission. Finally, EPA should ensure that each form or other
survey instrument included in the collection has a specific purpose
that is clearly identified in the supporting statement and on the
form or instrument. ***Heavy Duty Trucks*** OMB understands that
EPA has a small program in place for testing of heavy-duty truck
in-use emissions using EPA's ROVER technology or similar portable
devices, which functions as a screening or surveillance testing
program. This program requires a limited solicitation of
information, which EPA has described in supplemental materials
submitted during review of the collection, and appears to be
conducted in a manner that is voluntary and minimally intrusive. It
does not make use of incentives, and therefore does not raise the
concerns raised by some other elements of this ICR with respect to
OMB's guidance relating to incentives. Furthermore, it appears to
have practical utility that justifies the minimal burden on
respondents. Therefore, this portion of the collection, described
in the supplemental materials submitted during OMB review, is
approved until June 30, 2002. EPA may not make a material change to
this collection without authorization from OMB. OMB understands
that the information collected under the ROVER or portable device
program will be used by EPA to monitor compliance with consent
decrees between the Department of Justice and several heavy-duty
engine manufacturers, but will not actually be used as the basis
for any enforcement action without additional in-use testing
performed by the engine manufacturers or their agents. If EPA
intends to renew this portion of the collection beyond June 30,
2002, the Agency should include in its request for approval a
sampling protocol that explains how engine families will be
selected for testing. EPA should also review the burden associated
with this portion of the collection and ensure that the next
information collection request accounts for all aspects of burden.
The collection relating to heavy-duty engines described in the
supporting statement of this ICR is not approved, however. OMB
understands that EPA does not currently have a program in place to
conduct confirmatory testing of heavy-duty truck engines using an
engine dynamometer. With a few exceptions, the concerns identified
above in the context of the light-duty program also apply ot the
portion of the submission relating to the heavy- duty engine
program. Some of these concerns are heightened by the size of the
incentives that EPA has proposed to use for this program. In light
of these flaws, and given that this program is not currently
operational, there is no basis for approving this aspect of the
proposed collection, even for a limited period of time. Therefore,
with the exception of the ROVER- or portable-device-based program
described in the preceding paragraph, the portion of the proposed
collection relating to heavy-duty trucks and the related
instruments (Attachments A1 and A3) are disapproved. EPA may wish
to resubmit an ICR to OMB requesting approval for such information
collection activities once an appropriate plan exists that would
guarantee such a collection would have practical utility, could be
implemented with technology available to EPA or its contractors,
and otherwise conform to OMB guidelines. In doing so, EPA should
refer to the comments above relating to the light-duty program.
Unless and until OMB approves such a collection, EPA may not
collect information for purposes of determining compliance of
heavy-duty trucks with federal emission standards, or for research,
testing, or procurement of engines, trucks, or other equipment,
except as specifically described in the supplemental submission of
June 5, 2001 that OMB is approving today or in another information
collection with current OMB approval. (EPA should consult with OMB
if there are questions about the applicability of these terms to a
pilot testing program that involves nine or fewer engines.)
Inventory as of this Action
Requested
Previously Approved
10/31/2002
10/31/2002
06/30/2001
985
0
17,100
587
0
2,575
0
0
0
EPA's in-use testing program provides
a satisfactory measure of manufacturers' compliance with the
provision of the Clean Air Act. Classes of vehicles or engines to
be evaluated are generally selected from a ranking of vehicle
classes. Voluntary vehicle owners are required to provide
information regarding their vehicle before it is eligible to be
accepted for testing. The required information includes
identification of the vehicle, scheduled maintenance records,
problems of the vehicles, etc. This allows the Agency to procure
properly maintained and used vehicles for testing.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.
Investigation into Possible Noncompliance of Motor Vehicles with Federal Emission Standards