1695ss15

U.S. Environmental Protection Agency

Information Collection Request

Title: Emissions Certification and Compliance Requirements for Nonroad Spark-Ignition Engines (Renewal)

OMB Control Number: 2060-0338

EPA ICR Number: 1695.15

Abstract: This supporting statement is a renewal of ICR Number 1695.14 and covers the burden associated with emission certification and compliance requirements affecting manufacturers of nonroad spark-ignition (SI) engines (small SI engines, large SI and marine SI engines), recreational vehicles, and SI evaporative components. For simplicity, these industries are collectively referred to as “nonroad SI engines” or “SI engines.” This ICR also incorporates Emissions Defect Information Report (EDIR) and Voluntary Emissions Recall Report (VERR) obligations for NRSI engines and vehicles.

Under Title II of the Clean Air Act (42 U.S.C. 7521 et seq.; CAA), the EPA is charged with issuing certificates of conformity for engine prototypes that comply with applicable emission standards. Such a certificate must be issued before engines produced after these prototypes may be legally introduced into commerce. Table 1 below lists EPA regulations pertaining to the industries covered by this ICR.

Table 1. EPA Regulatory Cites by Industry Sector

Industry	40 CFR Part
Large Spark-Ignition Engines (Large SI)	1048
Marine Spark-Ignition Engines (Marine SI)	1045
Recreational Vehicles	1051
Small Spark-Ignition Engines (small SI)	1054
Evaporative Components	1060
General Provisions – apply to most nonroad categories	1068

Certain programs contain Averaging, Banking, and Trading (ABT) provisions which allow manufacturers the flexibility of averaging the exhaust emissions from a set of engines or equipment in which emission credits may be exchanged with other engines (equipment) in the same averaging set, bank total credits earned by that averaging set under the emissions standard, or trade emissions credits with other manufacturers within the industry. The ABT provides manufacturers flexibility in choosing which mix of emissions technology and total sales of engines and equipment to satisfy EPA emissions standards.

Manufacturers electing to participate in ABT are also required to submit information regarding the calculation, actual generation, and use of credits in an initial report, end-of-year report within 90 days after the end of the model year, and a final report within 270 days after the end of the model year. We may waive the requirement to send an end-of-the-year report as long as you send a final report. These reports are used for certification and enforcement purposes. Manufacturers must also maintain records for eight years on the engine families included in the ABT program.

The CAA also mandates the EPA to verify that manufacturers have successfully translated their certified prototypes into mass produced engines, and that these engines comply with emission standards throughout their useful lives. Under the Production-line Testing (PLT) Program, manufacturers are required to test a sample of engines as they leave the assembly line. This self-audit program (referred to as the "PLT Program") allows manufacturers to monitor compliance with statistical certainty and minimize the cost of correcting errors through early detection. Through Selective Enforcement Audits (SEAs), the EPA verifies that test data submitted by engine manufacturers is reliable and testing is performed according to EPA regulations. Compliance with emission regulations throughout the useful life of an engine is verified through the In-use Testing (In-use) Programs under which manufacturers test SI engines after a number of years of use. Participation in the PLT program is mandatory for recreational vehicle manufacturers who are participating in ABT, Small SI, Marine SI, and Large SI manufacturers. The In-use Programs are voluntary for small SI engines, but mandatory for large SI engines. All manufacturers are subject to SEAs.

This information is collected by the Gasoline Engine Compliance Branch (GECB), Information, Analysis and Compliance Division (IACD), Office of Transportation and Air Quality (OTAQ), Office of Air and Radiation (OAR), U.S. EPA. Besides IACD, this information may be used by the Office of Enforcement and Compliance Assurance (OECA) and the Department of Justice for enforcement purposes. Non-confidential portions of the information submitted to the EPA may be disclosed in a public database and over the Internet https://www.epa.gov/compliance-and-fuel-economy-data/annual-certification-data-vehicles-engines-and-equipment. This information is used by trade associations, environmental groups, and the public. Respondents submit most of this information to EPA’s vehicle and engine compliance information system (EV-CIS).

Active ICRs must be renewed every three years. Before the EPA submits its ICRs to the Office of Management and Budget (OMB) for renewal, the Agency revises the burden estimates for each collection.

Supporting Statement A

1. NEED AND AUTHORITY FOR THE COLLECTION

The EPA's emission certification programs are statutorily mandated; the agency does not have discretion to cease these functions. Under Section 206(a) of the CAA (42 USC 7521):

"The Administrator shall test or require to be tested in such manner as he deems appropriate, any new motor vehicle or new motor vehicle engine submitted by a manufacturer to determine whether such vehicle or engine conforms with the regulations prescribed under §202 of this Act. If such vehicle or engine conforms to such regulations, the Administrator shall issue a certificate of conformity upon such terms, and for such period (not more than one year) as he may prescribe."

This provision also applies to nonroad engines, pursuant to §213(d) of the CAA. Also, under the authority of the CAA §217, engine manufacturers are required to pay a fee when applying for a certificate of conformity.

Therefore, vehicle and engine manufacturers may not legally introduce their product into U.S. commerce unless the EPA has certified that their vehicles and engines comply with applicable emission standards. To ensure compliance with these statutes, the EPA reviews product information and manufacturers' test results and may also test some vehicles and engines to confirm manufacturers' certification testing results. The EPA also conducts an ABT Program, which is one of the many regulatory features designed to enhance the compliance flexibility for and reduce the burden on the affected engine manufacturers, without compromising the expected emissions benefit derived from these emissions standards. Note that there is no ABT program for large SI engines.

Section 206(b)(1) of the CAA authorizes the EPA to inspect and require testing of new vehicles and engines to: (1) verify that manufacturer's final product complies with EPA standards; (2) assure that the correct parts are installed correctly in each engine; and (3) audit the manufacturer's testing process to ensure testing is being done correctly. The PLT Program and the SEA Program fulfill these requirements through the inspection and testing of engines taken directly from the assembly line and by auditing the engine manufacturer's testing procedures and facilities. Section 207(b), through Section 213(d), of the CAA mandates the establishment of methods and testing procedures to ascertain whether certified engines in actual use in fact comply with applicable emission standards throughout their useful lives.

2. PRACTICAL UTILITY/USERS OF THE DATA

The EPA uses the information requested to support various enforcement actions as mandated by the CAA. This information collection enables the EPA to ensure that SI engine manufacturers are complying with applicable emission regulations, measure the impact of nonroad engine emissions on air quality, and take corrective actions as needed.

The information will be received and used by GECB. Non-confidential portions of the information submitted to GECB are available to and used by importers, environmental groups, members of the public, and local, state and federal government organizations.

3. USE OF TECHNOLOGY

Engine, vehicle, and equipment manufacturers use the EPA's Engines and Vehicles Compliance Information System (EV-CIS), to report certification and compliance information for emissions. EV-CIS collects emissions and evaporative compliance information for all types of vehicles (mobile sources of air pollution) including nonroad SI engines. Additional information about EV-CIS and how manufacturers use the system can be found at https://www.epa.gov/vehicle-and-engine-certification/how-register-engines-and-vehicles-compliance-information-system-ev.

For compliance programs, such as ABT, PLT and In-use Testing, as well as for production reporting, the EPA has developed Excel-based forms. These forms can be downloaded from the EPA's website at https://www.epa.gov/vehicle-and-engine-certification/compliance-reporting-nonroad-spark-ignition-si-engines. Manufacturers submit these forms through the EV-CIS document module. SEA reports can be submitted electronically through EV-CIS to the EPA

Once the EPA receives the submitted data, the EPA certification representatives analyze the information to ensure compliance with the CAA and applicable regulations. The EPA also publishes annual certification data for vehicles and engines, which may be found at this site: https://www.epa.gov/compliance-and-fuel-economy-data/annual-certification-data-vehicles-engines-and-equipment.

4. EFFORTS TO IDENTIFY DUPLICATION

The information requested under this ICR is required by statute. Because of its specialized nature, the information collected is not available from any other source. Furthermore, some of the information, such as projected U.S. sales volume, is claimed as confidential business information (CBI) by manufacturers. Therefore, the EPA can only obtain this information from it if manufacturers when manufacturers submit it to the EPA.

5. MINIMIZING BURDEN ON SMALL BUSINESSES AND SMALL ENTITIES

SI regulations contain a series of opportunities to ease the burden on small entities. For example, participation in the small SI PLT program is optional for 'small volume engine manufacturers' and 'small volume engine families.' A 'small volume engine manufacturer' is, as defined at section 1054.801; "[f]or nonhandheld engines an engine manufacturer that had U.S.-directed production volume of no more than 10,000 nonhandheld engines in any calendar year." For handheld engines, the term 'small volume engine manufacturer' means "an engine manufacturer that had U.S.-directed production volume of handheld engines of no more than 25,000 handheld engines in any calendar year." A "small volume engine family" may have one of two definitions, depending on the emissions of the engine family. For requirements related to exhaust emissions for nonhandheld engines and to exhaust and evaporative emissions for handheld engines, small-volume emission family means any emission family whose U.S.-directed production volume in a given model year is projected at the time of certification to be no more than 5,000 engines. For requirements related to evaporative emissions for nonhandheld equipment, small-volume emission family means any equipment manufacturer's U.S.-directed production volume for identical fuel tank is projected at the time of certification to be no more than 5,000 units. Tanks are generally considered identical if they are produced under a single part number to conform to a single design or blueprint. Tanks should be considered identical if they differ only with respect to production variability, post-production changes (such as different fittings or grommets), supplier, color, or other extraneous design variables.

Small volume manufacturers of certain outboard and personal watercraft engines may exempt their engine families from PLT and in-use testing. They may also use surrogate data for certification, corporate average standards, multi-year averaging in ABT.

The provisions of 40 CFR part 1068 also provide flexibilities for engine and equipment manufacturers who find themselves in a difficult situation at the start of a new set of regulations. Section 1068.245, 1068.250 and 1068.255 provide additional time for manufacturers to comply with regulations if they meet certain criteria.

Under the other programs included in this ICR, the information being requested is the minimum needed to effectively maintain the programs' integrity and comply with the requirements of the CAA.

6. CONSEQUENCES OF LESS FREQUENT COLLECTION

The CAA states that emission certification must be done on a yearly basis (CAA 206(a)(1)), coinciding with the industry's 'model year.' Major product changes typically occur at the start of a model year. For these reasons, a collection frequency of less often than a model year is not possible. However, when an engine design is "carried over" to a subsequent model year, the amount of new information required is substantially reduced.

Engine manufacturers are required to submit PLT reports on a quarterly basis. They are required to test up to one percent of their production at random to ensure that mass produced engines comply with emission requirements. If a problem is found, manufacturers must correct it and may need to recall engines that have already been sold. Engine manufacturing companies are required to update their internal production volume reports every quarter. By conducting this quality control testing also on a quarterly basis, manufacturers can learn about and address any problems early, before the start of the next quarter's production, thus minimizing costs.

Engine manufacturers are required to submit in-use testing reports annually, within three months of the completion of the required testing. Providing this information to the EPA at a less frequent interval would compromise the EPA's ability to expeditiously evaluate the emissions results and determine, in a timely manner, whether in-use engines conform to the applicable emission standards. Any delay in making such a determination reduces the universe of engines which will be reached by a potential recall because both engine scrappage and owners' unwillingness to participate in recalls increase with the age of the engine.

The EPA conducts SEA testing on occasion, when the agency has reason to believe that an audit of a particular manufacturer is in order.

7. GENERAL GUIDELINES

Engine manufacturers must maintain emission test records must be maintained for eight years, except for routine emission test data such as those reporting the condition of the test cells. Engine manufacturers must retain test cell data for one year only. However, data records may be kept in any format and media, provided the manufacturer is able to provide organized, written records to the EPA upon request. This requirement stems from the CAA mandate that manufacturers recall engines failing to meet emission standards throughout their useful lives.

When audited by the EPA, manufacturers must submit test results and information within 30 working days after all testing ordered under notification of a SEA has been completed. The items requested are all readily available or generated during the SEA. The information is requested in this time frame so that the EPA can verify the accuracy and validity of the emission data and expeditiously reach a conclusive audit decision. An expeditious audit decision allows the manufacturer to quickly release the tested vehicles or engines for introduction into commerce.

Under this information collection, manufacturers submit information often claimed as CBI, such as sales projections. Furthermore, certain sensitive technical and proprietary information submitted during the certification process could be used during SEAs. This information is kept confidential in accordance with 40 CFR Part 2, and class determinations issued by the EPA's Office of General Counsel.

No other general guideline is exceeded by this information collection.

8. PUBLIC COMMENT AND CONSULTATIONS

8a. Public Comment

A notice was published in the Federal Register on Monday, May 5, 2025 (90 FR 18979) seeking comment on the renewal of this collection. Two comments were received from Textron Specialized Vehicles and Outdoor Power Equipment Institute (OPEI). A summary is provided below as well as our responses to these comments.

Textron Specialized Vehicles (“Textron”) comments that EPA’s annual certification process is time consuming and expensive and suggests either re-certification only when an (engine) design is significantly changed or the regulation changes. In the alternative, Textron would like the EPA to consider lengthening the time that a granted certificate is valid, e.g. 5 years, 7 years, etc. Similarly, Outdoor Power Equipment Institute (“OPEI”) comments that it is a burden for manufacturers to certify engine families annually even where no changes are made to the engine configuration from year to year. OPEI believes a “one and done” certification process similar to the type-approval process offered by the European Union (EU) is reasonable for the sector and would significantly reduce both manufacturer and EPA burdens related to carryover certifications. As an option to the EU type-approval approach, OPEI requests EPA consider forms/report/data non-model year specific for use over multiple model years (as applicable).

Both Textron and OPEI offer a similar comment regarding the burden of annual certification where there are little to no change in the certified product year-to-year. While we understand the burden of providing information to apply for a certificate of conformity, the method and applicability of the requirements for certification are not the subject of an ICR. With regard to the information we may consider for an ICR, the ICR limits comments to (i) evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the Agency, including whether the information will have practical utility; (ii) evaluate the accuracy of the Agency's estimate of the burden of the proposed collection of information, including the validity of the methodology and assumptions used; (iii) enhance the quality, utility, and clarity of the information to be collected; and (iv) minimize the burden of the collection of information on those who are to respond, including through the use of appropriate forms of information technology. The request for a reduction in the regulatory requirements, while appreciated, fall outside the scope of an ICR.

To the extent we may address some of the concerns expressed by Textron and OPEI, the EPA is obligated to certify engine families on an annual basis under CAA § 206(a), which reads in part “…[the EPA] shall issue a certificate of conformity upon such terms, and for such period (not in excess of one year), as [the EPA] may prescribe. The EPA is interested in streamlining the process for certification to the extent that it may reduce the burden of reporting and retaining information for certification and compliance and will review OPEI’s request for forms that apply over multiple model years and will work with the industry on an approach that further streamline this process.

In addition, OPEI argues has commented on the following:

Comment: Annual Production Report Burden: Part 1054.250 requires manufacturers to report annual production volumes. The rule requires reporting families for which PLT testing is not conducted and reported. However annual reports are still being requested (required) for families that undergo PLT testing.

Response: Production reporting should not be confused with Production Line Testing (PLT) for reporting purposes. The former is an account of your engine production/sales in the United States and has no tie to testing requirements. The latter, i.e. PLT, is compliance testing manufacturers must perform to ensure that the production under a certificate of conformity match the certification performance for which a certificate was issued. The reporting is not redundant but focuses on different requirements of the manufacturer under the Act and regulations promulgated thereunder.

Comment: Small-Volume Emission Family PLT Reporting Burden: Section 1054.301(a)(2) conditionally directs EPA to approve requests to exempt small-volume emission families from PLT testing requirements. OPEI has been advised that EPA is denying some manufacturers this request, despite them meeting the conditional requirements of the section.

Response: Under 40 CFR 1054.301(a)(2), EPA may exempt small-volume emission families from routine testing under this subpart. (emphasis added). However, we add “We will approve your request if we agree that you have made good-faith estimates of your production volumes. You must promptly notify us if your actual production exceeds 5,000 units during the model year. If you exceed the production limit or if there is evidence of a nonconformity, we may require you to test production-line engines…”. EPA is not “directed” to approve a request. Rather, small volume manufacturers have an obligation to make a good faith estimate and EPA must agree that a manufacturer’s estimates justify the relief offered in the otherwise applicable PLT that would apply.

• General Template Feedback

• OPEI Comment: 5900-131 NR Small SI ABT Report update to remove Phase 2 (Part 90) credits.

• EPA Response: Reference to Phase 2 (Part 90) credits has been removed.

• OPEI Comment: 5900-133 NR Small SI PLT Report update the template to remove date limits or otherwise extend the maximum limit beyond 2029.

• EPA Response: The NRSI ICR renews the ICR only three years from its acceptance, likely in the 2028 calendar year.

• OPEI Comment: 5900-455 Evaporative Fuel Tank Data Worksheet states redundancy for recording surface area for each subsequent tank used for testing.

• EPA Response: While we understand that the surface area may seem redundant. The regulations require measurement of the surface area of each test article. Manufacturers should provide a measurement of the actual surface area as small differences may be material to the evaporative capabilities of the design.

• OPEI Comment: Template Expiration Dates- In preparing these comments, OPEI found that the OMB approval has expired for some forms.

• EPA Response: EPA will ensure that all of the forms will be updated with the proper expiration dates once the OMB has approved the ICR.

• OPEI Comment: Many Forms Are in Outdated Microsoft Formats: OPEI notes many 5900 reports are in .xls format. The most current excel format is .xlsx.

• EPA Response: While many forms are saved in the .xlsx format, several forms contain macros, a way to program Excel to perform a sequence of steps automatically, saving time and reducing errors. Where possible, we have provided forms in the .xlsx format but maintain several others in the .xlsm format to preserve macros. In addition, we have one form that is in .pdf format but will update that file with input from industry at the time of ICR approval.

• OPEI Comment: “5900-New” Reports and Forms- The Federal Register announcement includes several “5900-New” reports and forms, including a “Replacement Engine Exemption Report” and “AECD Form” which will presumably be required for SSIE certification purposes. OPEI is interested in working with EPA to evaluate the subject (SSIE applicable) reports / forms prior to EPA requiring them. OPEI recommends EPA share draft reports / forms with industry stakeholders and consider industry feedback before implementing the documents.

• EPA Response: EPA will work with industry partners on the implementation of these additional forms and will issue additional guidance as needed.

8b. Consultations

The EPA consulted fewer than 10 past respondents regarding this information collection burden, including the following industry professionals:

Contact: Davin Weaver

Company: ECO

Email: dweaver@enginecert.com

Phone: 916-258-7347

Contact: Dave Oughton

Company Mercury Marine

Email: dave.oughton@mercmarine.com

Phone: 920-929-5688

Contact: Jean-Michel Desaulniers

Company: Bombardier

Email: jean-michel.desaulniers@brp.com

Phone: 450-532-6188

The consultants provided some useful information on estimating approximate time to complete certification and compliance testing as well as providing estimates on contract expenditures for testing and service accumulation.

9. PAYMENTS OR GIFTS TO RESPONDENTS

The Agency does not intend to provide payments or gifts to respondents as part of this collection.

10. ASSURANCE OF CONFIDENTIALITY

Manufacturers may assert a claim of confidentiality over information provided to the EPA by marking such information in their information submittals to the Agency. Confidentiality of all subject material is provided in accordance with the regulations at 40 CFR Part 2 (https://www.ecfr.gov/current/title-40/chapter-I/subchapter-A/part-2).

11. JUSTIFICATION FOR SENSITIVE QUESTIONS

No sensitive questions are asked in this information collection.

12. RESPONDENT BURDEN HOURS & LABOR COSTS

12a. Respondents/NAICS Codes

Respondents are manufacturers of nonroad engines within the following North American Industry Classification System (NAICS) code:

333618 Other Engine Equipment Manufacturing

336312 Gasoline Engine and Engine Parts Manufacturing

336999 Other Transportation Equipment Manufacturing

336991 Motorcycle, Bicycle and Parts Manufacturing

333112 Lawn & Garden Tractor and Home Lawn & Garden Equipment Manufacturing

335312 Motor and Generator Manufacturing

12b. Information Requested

Manufacturers must describe their products and supply test data to verify compliance. This information is organized by "engine family" groups, or “evaporative family” groups expected to have similar emission or evaporative characteristics. Manufacturers must also retain these records. All activities provided below in 12c should be submitted to the EPA using the EV-CIS system and document module previously described in Section 3 above. The EPA has also provided the below forms to assist manufacturers in submitting data to the EPA that may ease time and organization for the manufacturer and review by the EPA.

Table 2. Forms
Form Name	Form Number	Burden hours
Annual Production Worksheet	5900-90	.5 hours
Marine SI Production Line Testing Report	5900-91	12 hours
Marine SI Averaging, Banking, and Trading Report	5900-92	17 hours
Large SI In-Use Testing Report	5900-93	28 hours
Marine SI In-Use Testing Report	5900-93	28 hours
Large SI Production Line Testing Report	5900-130	12 hours
NR Small SI Averaging, Banking, and Trading Report	5900-131	26 hours
NR Small SI Production Line Testing Report	5900-133	12 hours
HDSI ABT Report	5900-134	4 hours
NR Small SI Bond Worksheet	5900-450	1 hour
NR Small SI Small Volume Bond Worksheet	5900-451	1 hour
Altitude Worksheet	5900-452	1 hour
Evaporative Fuel Cap Test Data	5900-453	4 hours
Evaporative Fuel Line Test Data	5900-454	4 hours
Evaporative Fuel Tank Data Worksheet	5900-455	4 hours
Marine and Large SI Diurnal System Data Worksheet	5900-456	2 hours
NR Small SI Equipment Worksheet	5900-457	1 hour
Marine SI Vessel Worksheet	5900-458	1 hour
Marine SI Engine Data Map Sheet	5900-459	1 hour
Snowmobile Production Line Testing Report	5900-460	12 hours
Snowmobile Certification Template	5900-463	10 hours
Rec Vehicle Catalytic Converter Checklist	5900-464	2 hours
Snowmobile Averaging, Banking, and Trading Template	5900-465	6 hours
Rec Vehicle Fuel Line Test Data Worksheet	5900-466	3 hours
Rec Vehicle Fuel Tank Test Data Worksheet	5900-467	6 hours
Recreational Vehicle PLT Report Final	5900-New	12 hours
HMC_RV_ABT_Template	5900-New	17 hours
ATV-UTV checklist	5900-New	2 hours
Replacement Engine Exemption Report	5900-New	10 hours
AECD Form	5900-New	8 hours

12c. Respondent Activities

A. Certification

Engine families must be certified each model year. Evaporative component families may be certified annually. A model year refers to the manufacturers' annual new model production period, or a calendar year if the manufacturer does not have a model year. Manufacturers may make changes to one or more engine models within a family at any time during the model year. These changes may significantly affect the engine models, and therefore, the engine family's emission levels. For this reason, all SI engine programs run on a model year basis.

The certification burden for a given engine family is reduced after the model's first production year, because data and information from previous years can be "carried over" when no significant changes have occurred. For instance, an engine family certified in model year 2019 can be certified in model year 2020 by "carry-over" of data and paperwork from model year 2019 if no significant changes have occurred to the engine family between model years. Allowing manufacturers to "carry-over" data and other information saves manufacturers the burden of duplication which would occur in the absence of such provisions.

A label identifying each engine and stating the engine family name, the fuels for which the engine is certified to run, the engine useful life and category, if applicable, must be affixed to each engine. Manufacturers are also required to provide warranties to consumers.

Equipment manufacturers who use Class II Small SI engines typically add on their own evaporative components on their equipment. Since engine manufacturers do not typically supply these components, equipment manufacturers must annually certify that they are using certified components for fuel tanks and fuel lines and that they have applied the running loss control. There is an optional ABT program for these equipment manufacturers.

An application fee must be paid per engine family per model year. This fee is required under the authority of Section 217 of the CAA and the Independent Offices Appropriation Act (31 U.S.C. 9701) to ensure that the motor vehicle emissions compliance program is self-sustaining to the extent possible. New fee schedules are published on the EPA’s website. See section 6(b)(ii) for details.

Manufacturers of small SI engines must also post a bond upon importation of engines manufactured abroad. This requirement is waived if the engine manufacturer owns enough assets in the US to cover its liability. SI bonding requirements are found at 40 CFR 1054.690. For more information on obtaining a Bond or for waivers please visit this website; https://www.epa.gov/vehicle-and-engine-certification/certification-materials-small-nonroad-spark-ignition-nrsi.

From time to time, the EPA may conduct confirmatory testing. When there is reason to believe that a compliance issue may exist with the emissions data submitted at certification, the EPA may, at its own expense, purchase or rent engines and test them. Manufacturers may be notified about this testing in advance or may be required to explain discrepancies found between EPA test data and that submitted by the manufacturer.

Information Items Required Under the Certification Program:

• Statement of compliance;

• Identification and description of the basic engine design including, but not limited to, the engine family specifications (fuel, cooling medium, etc.);

• Explanation of how the emission control system operates;

• Fuel system type and components;

• Useful life period;

• Deterioration factors;

• Intended service class;

• Projected sales;

• Estimated production period;

• Sales area;

• Plant contact and location;

• Program information;

• Family Emission Limit (FEL);

• Nonroad engine equipment types;

• Detailed description and justification of each auxiliary emission control device (AECD), and how they affect emissions;

• Description of all adjustable parameters, their adjustable ranges and methods employed to prevent tampering, etc.;

• Detailed drawings and descriptions of the various emission related components;

• Description of the test equipment and fuel to be used;

• Description of the test procedures to be used to establish the durability data or the exhaust emission deterioration factors;

• All test data obtained by the manufacturer on each test engine;

• Statement of the useful life;

• Statement of the alternative useful-life period and a brief synopsis of the justification, if applicable;

• Maintenance information;

• Description of the provisions taken to prevent tampering with emission control computer instructions;

• Proposed test fleet selection and the rationale for the test fleet selection;

• Special or alternate test procedures, if applicable;

• Period of operation necessary to accumulate service hours on test engines and stabilize emission levels;

• Fee filing form; and

• If the EPA submits a written request for an explanation of good engineering judgment, manufacturers must provide a written description of the judgment in question within 15 working days, unless otherwise specified.

Manufacturers must keep records for eight years except routine emission records. Manufacturers must keep routine emission records for only one year.

General Records:

● Identification and description of all engines for which testing is required;

● Description of emission control systems; and

● Description of test procedures.

Individual Records:

● Copies of all the applications submitted;

● A brief history of all test engines and running changes;

● A complete record of all emission tests performed;

● The date of each mileage accumulation run and the mileage accumulated;

● Record and description of all maintenance and other servicing performed;

● Record and description of each test performed to diagnose engine or emission control system performance;

● A brief description of any significant events affecting the vehicle;

● Actual U.S. sales volume; and

● Routine emission test data.

When a manufacturer needs to make changes to a certified engine, or to add an engine model to an already certified engine family, the following information must be submitted. Running changes are submitted using the same electronic format used to apply for a certificate of conformity. Data items requested:

● Notification of changes made to the application and/or request to amend the application;

● Description of change to be made;

● Engineering evaluations or data showing that engines as modified or added will comply with all applicable emission standards;

● Determination of whether the original test fleet selection is still appropriate, and proposed new test fleet selections, if applicable;

● Test data on engines changed or added, upon request; and

● Supporting documentation, test data and engineering evaluations as appropriate to demonstrate that all affected engines will still meet applicable emission standards.

If an engine is installed that has been rebuilt, emissions-related components must be checked. The following records must be kept for at least two years after rebuilding an engine and must be accessible for the EPA's review. Records may be based on engine families rather than individual engines if that is a normal business practice.

● Hours of operation (or mileage, as appropriate) at the time of the rebuild;

● Work completed on the engine or any emission-related control components, including a listing of parts and components used;

● Any engine parameter adjustments; and

● Any emission-related codes or signals responded to and any retests.

For manufacturers or rebuilders of aftermarket engine parts for large SI engines and recreational vehicles, information must be maintained that shows how their parts or service affect emissions. The EPA may test engines and equipment to investigate potential defeat devices or may require the manufacturer to complete this testing. Manufacturers may need to provide information regarding test programs, engineering evaluations, design specifications, calibrations, on-board computer algorithms, and design strategies. (see Section 1068.110)

Each manufacturer is also required to submit an annual production report identifying the number of engines produced by engine family, by gross power, by displacement, by fuel system, or by other categories as the Administrator may require. If the manufacturer requests a hearing on the Administrator's denial or revocation of a certificate of conformity, the request shall be filed within 30 days of the Administrator's decision, shall be in writing, and shall set forth the manufacturer's objections to the Administrator's decision and data to support the objection(s).

B. Averaging, Banking and Trading

Information Items Required Under the ABT Program:

● Intent to include the engine family in the ABT program;

● Declaration that participation in this program will not cause the applicable emission standard to be exceeded (i.e., result in a negative credit balance);

● FEL;

● Projected applicable production volumes for the model year;

● Values required to calculate credits;

● Projected number of credits generated/used; and

● Designated use of generated credits and/or source of credits used.

The following ABT records are to be kept for eight years:

● EPA engine family;

● Engine identification number;

● Engine build date and model year;

● Power rating;

● Purchaser and destination;

● Assembly plant;

● FEL;

● Useful life;

● Projected and actual production for each model;

● Applicable production/sales volume -- actual quarterly and cumulative (this is required quarterly for all families participating in trading);

● Values required to calculate credits;

● Resulting type and number of credits generated/required;

● How and where credit surpluses are dispersed; and

● How and through what means credit deficits are met.

C. Production-Line Testing (PLT) Program

Under PLT, each calendar quarter, participating manufacturers must test a sample of their engines taken directly from the assembly line. These tests must be performed unless the EPA approves a variation.

In the small SI, marine SI, and large SI engine sectors, only Phase 2 small SI engines are subject to PLT requirements. Phase 2 refers to a second, more stringent tier of emission regulations for small SI engines. The different provisions in these and other small SI emission control programs are designed to ease manufacturers' transition from Phase 1 to Phase 2 standards. Participation in PLT is optional for small volume engine manufacturers and small volume engine families; or engine families with limited production (see section 5(c) for details). Engine families, regardless of size, which the manufacturer opts to conduct in-use testing, are exempt from PLT requirements. All manufacturers and engine families, however, remain subject to SEAs. PLT is mandatory for all other small SI, large SI engines, marine SI, and recreational vehicles participating in the ABT program, subject to sample size limits on the number of vehicle(s) per PLT reporting period.

The EPA can require manufacturers to submit or retain additional information not specifically listed here. Within 45 days of the end of each quarter, manufacturers must report the following information (30 days for marine SI manufacturers):

● Location and description of the test facilities where testing was conducted;

● Total production and sample size for each engine family;

● Applicable standards and/or FELs;

● Description of the process used to obtain engines on a random basis; and

● Description of the test engine.

For each test conducted, manufacturers must submit the following information:

● Description of the test engine, including engine family and configuration, year, make, build date, engine ID number, and number of hours of service accumulated on the engine prior to testing;

● Location(s) where service accumulation was conducted and description of accumulation procedure and schedule;

● Test number, date, test procedure used, initial test results before and after rounding, final test results before and after rounding, and final deteriorated test results for all tests, etc.;

● Complete description of any adjustment, modification, repair, preparation, maintenance, and testing which was performed on the test engine, etc.;

● CumSum Analysis;¹

● Any other information the Administrator may request;

● For each failed engine, a description of the remedy and test results for all retests;

● Date of the end of the engine manufacturer's model year production for each engine family;

● A signed statement (e.g., see §1054.201(e) for small SI engines) and endorsement by an authorized representative of the manufacturer; and

● Submit, upon request: 1) projected production for each configuration within each engine family for which certification has been requested and/or approved; and 2) Number of engines, by configuration and assembly plant, scheduled for production or actually produced.

Record and maintain the following information for one year after completion of testing:

● Description of all testing equipment used and each test cell that can be used to perform PLT;

● Date, time, and location of each test or audit;

● Number of service accumulation hours on the test engine at the start and end of the test(s);

● Names of all supervisory personnel involved in the conduct of the test or audit;

● Record and description of any adjustment, repair, preparation or modification performed on test engines, including date, associated time, justification, name(s) of the authorizing personnel, and/or name(s) of supervisory personnel responsible for the conduct of the repair;

● If applicable, the date the engine was shipped from the assembly plant, associated storage facility or port facility, and the date the engine was received at the testing facility;

● Complete record of all PLT emission tests or audits performed (except tests performed directly by the EPA), including all individual worksheets and/or other documentation relating to each test, or exact copies; and

● Brief description of any significant events during testing not otherwise described, commencing with the test engine selection process and including such extraordinary events as engine damage during shipment.

If an engine family fails PLT, its certificate of conformity may be suspended, effective from the time testing was completed. Before suspending a certificate, the EPA will work with the affected manufacturer to achieve appropriate production line changes and try to avoid the need to halt engine production. Manufacturers with a suspended certificate must remedy the non-conformity, retest or re-audit. After a successful test is completed, the manufacturer must submit a report with the same information required during the initial test.

For the EPA to consider reinstating a suspended certificate of conformity, the manufacturer must submit another report with the following information:

● Description of the reason for noncompliance;

● Description of the proposed remedies, including a description of any proposed quality control measures to be taken to prevent future occurrences of the problem, and the date when the remedies will be implemented;

● Demonstration, through testing, that the failed engine family does in fact conform;

● Manufacturers may request a hearing; and

● Manufacturers may request conditional reinstatement of a revoked certificate while conducting further testing.

The manufacturer must submit a request for public hearing, if the reason for suspension of the certificate is being challenged. This request must be made in writing within 15 days of the revocation. Four copies of the request must be filed containing the following information:

● Statement regarding which engine family configuration(s) will be the subject of the hearing;

● Concise statement of the issues to be raised at the hearing;

● Statement specifying reasons why the manufacturer believes it will prevail on the merits of each of the issues raised; and

● Summary of the evidence which supports the manufacturer's position on each of the issues raised.

D. In-use Testing Programs

There are in-use testing requirements for large SI and marine SI engines. There is no in-use testing requirement at this point for recreational vehicles. In-use records, including data generated in the engine procurement process, must be generally kept for eight years. Under this program, EPA selects for testing a number of engine families, generally not to exceed 25 percent of that year’s certified families. Manufacturers must complete the required testing and submit the data.

While some of the details of the in-use program may vary from one type of engine to another, the information collected is very similar. Generally, SI engine manufacturers submit:

● Engine family;

● Model;

● Engine serial number;

● Date of manufacture;

● Estimated hours of use;

● Results of all emission testing;

● Summary of all maintenance and/or adjustments performed;

● Summary of all modifications and/or repairs; and

● Determinations of compliance or noncompliance.

E. Selective Enforcement Audits (SEAs)

While the EPA performs SEAs sparingly, all engine and vehicle manufacturers are potentially subject to audits. After a manufacturer has been selected, the EPA issues a test order specifying which engine models and configurations will be tested. When all required testing is completed, manufacturers submit a report containing all testing results. This "audit" information is then used to determine compliance with applicable emission standards.

Upon the EPA's request, engine manufacturers must submit the following information regarding engine production. The EPA uses these data to determine which engines will be audited.

● Projected U.S. sales data for each engine family and configuration;

● Number of engines, by configuration and assembly plant, scheduled for production within the time period designated by the EPA;

● Number of engines, by configuration and assembly plant, storage facility or port facility, scheduled to be stored during the time period designated by the EPA; and

● Number of engines, by configuration and assembly plant, produced during the designated period that are complete for introduction into commerce.

Within 30 calendar days of the end of each audit, nonroad SI manufacturers must submit a report to the EPA based on the requirements in Section 1068.450. Manufacturers' reports should include the following information:

● Testing facilities' location and description.

● U.S.-directed production volume and number of tests for each engine family.

● Applicable standards or compliance levels against which the engines were tested.

● Description of the engine and the method used to select its emission-related components.

● For each test conducted, the following information:

-- Test engine description;

-- Location where service accumulation was conducted and a description of the procedure;

-- Test information, raw results, which include emission figures for all measured pollutants, for both valid and invalid test results;

-- A complete description of any modification, repair, preparation, maintenance and/or testing performed on the engine not previously reported. This must include the results of any emission measurements, regardless of the procedure or type of equipment;

-- Reason(s) for removal of engines from the test sequence (as authorization by the EPA), if applicable; and

-- Any other information as requested by EPA.

• Statement of compliance and endorsement.

• For large SI and recreational engines, a report on each failed engine.

• Request for re-testing of failed engines, if applicable.

• Signed statement by an authorized manufacturer representative (for large SI and recreational engine manufacturers) as required under section 1068.450(c).

Records must be kept for one year after all ordered tests have been completed. Records may be kept in any media, according to the manufacturer's procedures, provided that in every case all the information contained in the hard copy is maintained. The EPA may review manufacturer records at any time.

• General records: a description of all test equipment used, including the information submitted with the audit report described above.

• Individual records for each audit:

• Date, time and location of each test;

• Number of hours accumulated in each engine when testing began and ended;

• Names of all supervisory personnel involved in the conduct of the audit;

• Detailed records of all repairs performed prior/after EPA's authorization;

• Any records related to an audit not in the written report;

• Date engine(s) shipped, associated port/storage facility and date received, if applicable;

• A complete record of all tests performed including worksheets and other documentation; and

• Brief description of any significant event(s) that occurred during the audit.

• Manufacturers must be able to provide projected or actual production for an engine family, by assembly plant.

• Description of the equipment in each test cell that can be used to perform SEA testing, where applicable.

The EPA can request manufacturers to submit additional SEA information or keep records not specifically listed in this section.

6. Defects and Recalls

All certificate holders “must investigate in certain circumstances whether engines/equipment that have been introduced into U.S. commerce under your certificate have incorrect, improperly installed, or otherwise defective emission-related components or systems. This includes defects in design, materials, or workmanship” (1068.501). Part 1068, Subpart F describes the process applicable to most certified engines/vehicles/equipment. For older engines/vehicles/equipment, a similar but slightly different process may apply under the applicable standard setting part. Manufacturers of defect HD engines used to submit their defects and recall reports under Part85, Subparts S and T using the following Adobe Reader-based forms:

• Form 590-301 – HD Defect Information Reports

• Form 590-300 – HD Voluntary Emissions Recall Reports VERRs, and

• Form 590-302 – HD VER Quarterly Reports

However, EPA recently created a module within EV-CIS where manufacturers can submit the

data using webforms (screens) or XML files in the same way as they submit their applications for certification. Therefore, the Adobe-Reader forms are no longer in use. Since the system is new and some manufacturers may still need/want to use the forms, we are not requesting discontinuing these forms just yet.

Investigation Reports

Manufacturers are required to start an investigation when their data indicates that an emission-related defect may exist in a substantial number of properly maintain engines. If the number of engines/equipment that have a possible defect reach a threshold specified in Section1068.501(e), the manufacturer must investigate. The thresholds are based on the family’s projected sales. Under Parts 85-94, the regulations generally trigger defect reporting requirement at 25 engines or more, and do not regulate the investigation phase. During the investigation phase, manufacturers must submit mid-year (by June 30) and end-of-year (by December 31) reports to describe the methods used and the status of the investigation. The reports must explain progress made and conclusions reached, including:

• Description of the defect and the engines that have it

• Estimates of the number or percentage of affected engines/equipment per class or category

• Estimate of the defect’s impact on emissions

• A plan for addressing the defect or an explanation of the reasons that the defect does not need to be addressed

Defect Information Reports (DIRs)

If the investigation shows that the number of defective engines/equipment in fact meet the threshold, the manufacturer most submit a Defect Information Report (DIR) within 21 days after learning that the threshold has been met. (Under Parts 85-94, the deadline is usually 15 working days.) These requirements apply only to engines that have already been sold to the public and remain in effect for five years after the model year in which the engine was certified. For engines subject to Part 1068, the requirements apply for the entire useful life of the engine or five years after the end of the model year, whichever is longer [40 CFR 1068.501(b)(4)].

Data items requested in Defect Information Reports include:

• The manufacturer's corporate name

• A description of the defect

• A description of the class or category of engines

• Number of vehicle or engines estimated or known to have the defect and explanation of derivation.

• The address of the plant(s) where they were produced

• Evaluation of the emissions impact and any driveability problems it might cause

• Available emissions data related to the defect

• Indication of any anticipated manufacturer follow-up

Recalls and Voluntary Recalls

After a manufacturer determines that the applicable threshold was met, the manufacturer may choose to recall the engines, or the EPA may order a recall. (For simplicity, we are referring to all recall reports as VERRs, a widely used name, regardless of whether the recall was voluntary or mandated. Note, the EPA has rarely mandated a recall as a matter of compliance, but recalls may still be mandated in the course of enforcement for violations of the CAA.) Under Part 1068.505(c), manufacturers have 60 days to submit a remedial plan (VERR). For other industries, if the recall involves 25 engines or more (one for locomotives), they must notify the EPA about the recall within 15 days of the date they first started to notify engine owners.

Information items requested in VERRs include:

• A description of the class or category of engines being recalled

• A description of the modifications or repairs made to correct the defects

• A description of the method being used to identify and contact the owners

• A description of any conditions for eligibility for repair and any reasons for the conditions

• A description of the procedure to be followed by the owner to obtain repairs and where the repairs can be obtained

• If repairs are not being performed at dealers, a description of who will perform the repairs and where the defect will be remedied

• Copies of the letters of notification to be sent to the vehicle owners

• A description of the system for assuring an adequate supply of parts is available for the repairs and that they are performed in a timely manner.

• Copies of all necessary instructions to be sent to the persons who are to perform the repairs

• A description of the impact of the proposed changes on fuel consumption, drivability, and safety of the engines

• A sample of any labels to be applied to the participant engines identifying the recall being performed

Recall Progress Reports

VERR Quarterly Progress Reports (VERR updates) document the progress of voluntary (or mandated) recalls. Manufacturers must submit VERR updates for six consecutive quarters following the beginning of any recall campaign, or until all engines have been inspected, whichever comes first (Part 1068.525(b)). These reports must be submitted no later than 25 working days after the end of each calendar quarter. For all industries, VERR updates generally include:

• Recall campaign number

• Date of owner notification and completion

• Number of engines known or estimated to be affected by the defect

• Number of or engines brought in and inspected as part of the campaign

• Number of engines found to have the defect after inspection

• Number of engines receiving repair

• Number of engines determined to be unavailable due to exportation, theft, scrapping or other reasons

• Number of engines determined to be ineligible because of improper maintenance or use

• Copies of any service bulletins sent to dealers which relate to the defect that had not previously been reported

• Copies of all communications transmitted to vehicle owners which relate to the defect to be corrected not previously submitted

• Revisions to any of the information previously submitted

• Vehicle owner contact information upon request

Defects & Recalls Recordkeeping Requirements

Defect and recall records must be kept for at least five years after the last report was submitted. Records may be kept in any format, as long as they are readily available, and the EPA can inspect them:

• A paper copy of written reports

• The names and addresses of vehicle or engine owners who were notified

• For every engine or piece of equipment state whether it was inspected, disqualified or repaired

Table 3. Summary Table of Regulatory Authority by Industry Sector
NRSI Industry Sector	Pre-Production		Production	Post-Production
	Certification	Confirmatory Testing	PLT	SEA	In-use Testing	Defects/ Recalls	ABT
Marine SI	X	X	X	X	X	X	X
Large SI	X	X	X	X	X	X
Small SI	X	X	X	X	X1	X	X
Off-Highway Motorcycles and Recreational Vehicles	X	X	X	X		X	X
Snowmobiles	X	X	X	X		X	X
Evaporative Components	X	X	X2		X1	X	X3

1. The EPA may perform the in-use testing of any engine or equipment subject to the Small SI standards under Part 1054 and the Evaporative Components standard under Part 1060. However, there is no obligation for manufacturers of Small SI engines to perform in-use testing. This differs from the programs for Large SI and Marine SI, which require manufacturers to procure and test in-use engines.

2. Evaporative component manufacturers must perform Production Verification Testing, which requires manufacturers to test finished products for verification with the certificate of conformity.

3. Manufacturers may use evaporative emission credits only to the extent allowed under the exhaust standard setting parts, i.e. Parts 1045, 1051and 1054.

12d. Respondent Burden Hours and Labor Costs

Burden estimates were taken from the previous ICRs and adjusted to reflect experience gained by the EPA and comments from respondents consulted by the EPA. These estimates are included in EPA’s NRSI Worksheet Computations_03062025 and is available as an Excel file under the All Certification and Reporting tab in the docket. In addition, we are consolidating defect and recall reporting (EDIR and VERR) into this ICR for nonroad engines and vehicles. We have been able to utilize our EV-CIS system to further evaluate the certification and compliance information submitted by the regulated community to better evaluate the burden of our regulatory programs.

To estimate labor costs, EPA used the Bureau of Labor Statistics' (BLS) National Industry-specific Occupational Wage Estimates (March 2025) for the Engine and Turbines Industry under Standard Industrial Classification (SIC) code 351 and increased by a factor of 2.1 to account for benefits and overhead. (see: http://www.bls.gov/oes/current/naics4_333600.htm). Mean, hourly rates were used for this estimate and are listed below.

	Table 4 (2023 estimates)
Occupation	Mean Hourly Rate (BLS)	Rate Increased by Factor of 2.1	Occupational Code Number
Mechanical Engineers	$53.67	$112.71	17-2141
Engineering Managers	$81.46	$171.07	Nov-41
Lawyers	$111.14	$233.39	23-1011
Secretaries, Except Legal, Medical and Executive	$23.72	$49.81	43-6014
Mechanical Engineering Technicians	$33.58	$70.52	17-3027

13. Respondent CAPITAL AND O&m CostS

Capital costs (associated with building emission testing facilities) were incurred by manufacturers as the industries became regulated for the first time. In the large SI sector, those respondents that control the vast majority of the market are companies which manufacture engines regulated under other programs (such as the small SI or marine SI regulations) and have already invested in developing their own test cells. The small production volume of the other respondents makes it more economical for them to use contract testing facilities for their testing needs than to build expensive test cells. The EPA does not expect any new engine manufacturers to build their own emission testing laboratories over the next three years. Other potential one-time capital costs were covered under the previous ICR estimates and renewals and do not need to continue as an estimate of cost in this ICR renewal. Therefore, capital costs are excluded from this ICR. Other emission testing expenses are included as operation and maintenance (O&M) costs and labor expenditures as explained below.

O&M costs associated with this information collection may include as applicable compact discs (CDs), photocopying, postage & shipping expenses, calls, maintenance of emission laboratories, and testing costs. CDs may still be used by manufacturers to submit their electronic applications and to keep records. Wherever possible, the EPA obtained and used current manufacturer costs. For other estimates, EPA used the Consumer Price Index Inflation Calculator on the BLS website to determine the updated cost (available at http://www.bls.gov/data/inflation_calculator.htm), with the estimated value rounded to the nearest one hundred.

Engine manufacturers that have in-house testing facilities use them for all their certification and compliance testing needs as well as for research and development. The cost of maintaining these laboratories has been estimated at $82,206.73 per year, per manufacturer. This estimate (which appears under the certification program estimates) includes the cost of test fuels, calibration gases and equipment, to name the most common expenses.

EPA has also accounted for the cost incurred by those manufacturers who hire an outside laboratory to conduct the necessary certification and compliance emission testing. The test costs used are based mainly on data received from testing laboratories and vary according to the type of engine. Certification and durability testing are a one-time expense per engine family since manufacturers can utilize previous certification data and “carry-over” emissions data from one model year to the next. We have annualized that cost burden in our estimates. For calendar year 2025, engine manufacturers are required to pay a fee of $563 for all SI engine certification and $509 for component certification when submitting an application for a certificate of conformity. For Heavy Duty SI engines, manufacturers are required to pay a fee of $66,477 for the 2025 calendar year. These fees are requested under the authority of the CAA Section 217. Additional information on how to pay a fee may be found at https://www.epa.gov/vehicle-and-engine-certification/fees-information-motor-vehicle-and-engine-compliance-program-mvecp. The fee is reduced when "the full fee exceeds 1.0 percent of the projected aggregate retail price of all vehicles or engines covered by that certificate." (69 FR 26226, Section F). The reduced fee must not exceed one percent of the aggregate retail price of the vehicles and engines covered by the certificate. Requirements for the various fee programs are covered under ICR 2080.07.

Table 5 Fees for Certification
Nonroad Spark Ignition Engines	Small SI: Small nonroad gasoline powered equipment, such as lawnmowers, string trimmers, chain saws, small compressors, pumps, utility vehicles < 25 mph, snow blowers, rammers, floor cleaners	$563
	Marine SI: e.g. Gasoline boats and personal watercraft	$563
	Large SI: Large nonroad gasoline powered equipment, such as forklifts, compressors, generators, and stationary equipment	$563
	Evaporative components (manufacturers certifying their own equipment under the standard setting part)	$509
Recreational Vehicles	Recreational Vehicles (All-terrain vehicles / utility vehicles/Snowmobiles/Off-Highway motorcycles)	$563
Heavy Duty Engines and Vehicles		Engine	$66,477
		Evap	$563

14. AGENCY COSTS

14a. Agency Activities

As part of the implementation of the certification programs, the EPA officials for Nonroad Spark-ignition engines and evaporative components carry out the following activities:

● Review and interpret regulations, provide guidance;

● Gather applications from the industry, enter data into the database;

● Review the applications for completeness and accuracy;

● Verify that the correct engines have been selected and tested;

● Answer questions from manufacturers and the public;

● Issue appropriate certificates of conformity;

● Periodically perform maintenance or enhance the database;

● Make data available to the public, including making it available through the Internet;

● Analyze and manage requests for confidentiality;

● Determining if "carry-over" of data from a previous model year is appropriate or if new testing will be required; and

● Store, file and maintain data.

Activities related to ABT involve:

● Reviewing requirements and providing guidance;

● Entering the data into the database;

● Receiving quarterly and final reports, reviewing calculations, making sure that the information submitted by manufacturers is accurate and complete;

● Audit manufacturers reports and files to make sure all participants have zero or positive credit balances at the end of the year; and

● Keep records.

The following are the EPA's activities associated with the implementation of the PLT and SEA Programs:

● Review and interpret applicable regulations;

● Answer questions from manufacturers and the public;

● Review submissions for format and completeness, input data into the database;

● Analyze data submitted in reports, compare results to standards and FELs;

● Request and review additional information as needed;

● Periodically perform maintenance or make enhancements to the database;

● Make data from completed test programs available to the public, including posting it on the Internet;

● Analyze and manage requests for confidentiality;

● Take any appropriate enforcement actions; and

● Keep records of the information submitted by manufacturers and the EPA's actions and determinations.

The EPA activities associated with the implementation of the in-use testing programs are similar:

● Review and interpret regulations;

● Answer manufacturers' questions;

● Evaluate testing programs submitted by manufacturers and ensure that the programs comply with applicable requirements;

● Enter data from reports into the database;

● Review submissions for format and completeness;

● Analyze information submitted;

● Keep records;

● Request and review additional information, as needed;

● Perform maintenance or make enhancements to the database;

● Make data from completed test programs available to the public, including posting it on the Internet; and

● Analyze and manage requests for confidentiality.

In addition, when conducting SEAs, the agency must:

● Request and gather production data from manufacturers;

● Determine which manufacturers and engine families to audit;

● Issue an SEA test order;

● Travel to the testing laboratory to witness the testing; and

● Oversee testing, ensure proper procedures are followed, answer questions.

14b. Agency Labor Cost

GECB administers SI certification and compliance programs and certify evaporative components. There are currently eight full-time employees in Ann Arbor, MI, and four Senior Environmental Employment (SEE) Program (for clerical support) personnel dedicated to the activities covered by this ICR. Other EPA employees from Washington, DC and Ann Arbor also provide support for these activities, such as IT personnel, agency lawyers at the Office of General Counsel and the Office of Enforcement and Compliance Activities, work assignment/contract managers, upper management, etc. Contract support is also provided for database development/maintenance as well as compliance program report processing. Table 4 summarizes EPA’s approximate overall burden associated with this ICR. These costs are based on hourly wage rates that are effective as of January 2025 as obtained from the Office of Personnel Management (OPM) and adjusted by a factor of 1.6 to account for benefits and overhead. For purposes of estimating Agency labor costs, the labor rates for engineers, lawyers, and managers from the Detroit, MI area were used to reflect the fact that nearly all Agency labor costs for the NRSI programs will be incurred at OTAQ’s Ann Arbor, MI location. These rates are available at https://www.opm.gov/policy-data-oversight/pay-leave/pay-systems/general-schedule/.

Table 6 - Annual Agency Burden and Cost (2025 estimates)
Employee	Hours and Labor Cost
	Level	Rate	Rate Increase by 1.6	Number of Employees	Full time hours	% of Time	Total hr/yr	Total Labor cost/yr
Engineer	GS-13/6	63.75	$102.00	8	2080	100%	16640	$13,578,240
Contract	GS-13/6	$56.75	$90.80	1	2080	0%	0	$0
Attorney	GS-13/7	63.75	$102.00	1	2080	80%	1664	$169,728
Managers (Sector Leads)	GS-14/1	65.82	$105.31	3	2080	100%	6240	$1,971,441
SES-1	SES - 1	$72.19	$115.50	1	2080	25%	520	$60,062
IT Support	GS-13/6	63.75	$102.00	2	2080	30%	1248	$254,592
SEE Support		12.72	$20.352	4	2080	100%	8320	$677,315
Subtotal				20	N/A	N/A	34,632	$ 16,711,377

14c. Agency Non-Labor Costs

O&M Costs
Testing	$200,000
Other	$20,000
SEE Support	$177,066
Contract Support - Compliance	$83,000
Contract Support -Certification	$200,000
Subtotal:	$ 680,066

15. REASONS FOR CHANGE IN BURDEN

While there have been no changes to EPA’s certification and compliance programs over the past three years, there has been shifts in manufacturing process, the number of entities engaged in certification and compliance activities and EPA’s continuing assessment and estimate of those activities and how the Agency manages and reports its data. In addition, we have refined the way we compute O&M costs in a way that more accurately estimates manufacturer burden in meeting the applicable statutory and regulatory requirements. As a result, the total number of manufacturers has decreased from 430 under ICR 1695.14 to 393 (on average) in this 1695.15 renewal. The result has been less labor burden per manufacturer, on average, because there are simply fewer manufacturers conducted the same NRSI certification and compliance activities. However, we saw a rise in O&M costs, which seems to be fueled by two phenomena. We have improved our estimates on contract testing and compliance activities related to contract overhead and recordkeeping expense. Also, we have correctly attributed these O&M obligations to the appropriate responses and not merely the respondent. As a result, the overall amount of the burden attributed to O&M has increased from the previous estimate, but still falls in line with the expected burden per response.

The additional increase from 1695.14 to 1695.15 is attributed to the increase in wages across the board for labor (though fewer respondents than before), and an increase in the cost of contract testing across all manufacturer sectors. Finally, we have attributed fee payments to the O&M cost of each manufacturer, which also contributed to the increase in O&M cost from the previous ICR.

Table 7

	ICR 1695.14	ICR 1695.15	Change
Number of Respondents:	430.00	393.00	(37.00)
Number of Activities per Respondent:	37.00	46.00	9.00
Total Hours Per Year:	738,603.00	538,207.50	(200,395.50)
Total Labor Cost:	65,940,385.02	56,738,926.01	(9,201,459.01)
Total Annual Capital Costs:	-	-	-
Total Annual O&M Costs:	30,243,492.65	45,650,002.40	15,406,509.75
Total Costs:	95,360,655.00	102,388,928.41	7,028,273.41

15. PUBLICATION OF DATA

The EPA aggregates some of the emissions data collected by this ICR and publishes on a quarterly basis on our website here: https://www.epa.gov/compliance-and-fuel-economy-data/annual-certification-data-vehicles-engines-and-equipment

15. DISPLAY OF EXPIRATION DATE

The Agency plans to display the expiration date for OMB approval of the information collection on all instruments.

15. CERTIFICATION STATEMENT

This information collection complies with all provisions of the Certification for Paperwork Reduction Act Submissions.

1 CumSum is the cumulative summation used for the PLT calculation to determine the sequential analysis of engine production from a product line. The CumSum equation is represented as Ci = Max [0 or Ci-1 + Xi−(STD + 0.25 × σ)]; where: Ci = The current CumSum statistic; Ci-1 = The previous CumSum statistic; Xi = The current emission test result for an individual engine; STD = Emission standard (or family emission limit, if applicable).

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