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View ICR - OIRA Conclusion



2060-0086 199910-2060-002
Historical Active 199603-2060-003
EPA/OAR
Investigation into Possible Noncompliance of Motor Vehicles with Federal Emission Standards
Extension without change of a currently approved collection   No
Regular
Approved without change 06/05/2001
Retrieve Notice of Action (NOA) 10/14/1999
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