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SmartWay Transport Partnership (Renewal)

OMB: 2060-0663

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U.S. Environmental Protection Agency

Information Collection Request



TITLE: Information Collection Activities Associated with the SmartWay Transport Partnership

OMB CONTROL NUMBER: 2060-0663

EPA ICR NUMBER: 2265.05

ABSTRACT:

The U.S. Environmental Protection Agency (“EPA”) created the SmartWay Transport Partnership (“SmartWay”) to help businesses and individuals protect the environment, improve air quality, and maximize the energy efficiency of their transportation and logistics management choices. SmartWay is a voluntary program that focuses on increasing efficiency and lowering emissions generated by goods movement. EPA encourages businesses that transport and move goods to adopt energy-efficient strategies and technologies that reduce fuel use, air pollution, and energy costs.

EPA administers a streamlined reporting process for organizations that join SmartWay and has created incentives for improvement such as the SmartWay Excellence Awards Program. EPA also makes reporting tools and other resources available on the Internet to help SmartWay partners evaluate and track their environmental performance and the value of investing in transportation management year-over-year improvements.

SmartWay consists of the following participant groups:

  1. Carrier partners are businesses that provide freight transport services, and that own and/or operate vehicles used in goods movement and related transportation-based assets. These businesses include freight carriers (large trucking, small business truck owners, railroad, inland marine, and air carriers), commercial manufacturing and retail companies, logistics service providers, and similar organizations. SmartWay partners commit to improving their fuel efficiency and environmental performance when they join the partnership.

  2. Shipper and Logistics partners consist of manufacturers, retailers, logistics companies, and freight forwarders that hire or contract with transportation providers (e.g., carriers) to move goods. SmartWay shipper and logistics companies agree to annually assess the proportion of goods dispatched with SmartWay carriers. They report their freight transportation activity using a reporting tool similar to that used by carriers and EPA calculates their supply chain efficiency. Shippers and logistics companies agree to ship an increasing percentage of their goods with SmartWay carriers and to lower emissions from their facility transportation operations when they join SmartWay.

  3. Affiliates are both private and non-profit organizations and companies, including trade associations, state and local governments, leasing companies, retail truck equipment dealers, and other groups that encourage the transportation sector to integrate cleaner, more efficient strategies into their business operations.



This ICR covers the following reporting activities associated with partner participation in the SmartWay program:

  1. SmartWay Partnership Annual Agreement

An organization joins SmartWay when its submitted reporting tool is reviewed and approved. This reporting tool has an embedded SmartWay Partnership Annual Agreement (“Annual Agreement”) that states the general terms under which the partner agrees to participate. It also includes what EPA commits to do in return for the organization’s participation.

For example, partners commit to measure and report to EPA on an annual basis the environmental performance of their fleet(s) or business units using the EPA’s reporting tool; have their performance results posted on the EPA SmartWay website and in the database and submit supporting documentation for any data used to complete their tools upon request by EPA.

In return, EPA agrees to do the following:

  • Promote company participation in the partnership by posting partner names on the EPA SmartWay Website and in related educational, promotional, and media materials.  EPA will obtain express written consent from the partner before using the partner’s name other than in the context of increasing public awareness of its participation as described here.

  • Provide companies with industry-wide performance benchmark data as this data becomes available to EPA.

  • Assist partners in achieving emission and fuel usage reduction goals (subject to Federal Government Appropriations).

  • Treat individual corporate data as sensitive business information.

Partners must check a box at the bottom of the Annual Agreement indicating that they understand and agree to program participation terms before they can move into the reporting tool to enter their data.

  1. SmartWay Annual Reporting Tool

Upon joining SmartWay, carriers, shippers, and logistics management companies agree to annually measure efficiency and emissions generated by their freight transportation-related activities. To do so, partners collect data on their freight management business, such as transportation mode, fleet size, equipment type, fuel use, number of miles traveled, payload, and related factors. They then input this information into the reporting tool and submit it electronically to the EPA. EPA reviews, approves and uploads the completed reporting tool into its Customer Relationship Management (CRM) partner account database (“Partner database”).

EPA’s partner reporting tools use the keyed-in freight data to calculate efficiency and emission outputs--carbon dioxide (CO2), oxides of nitrogen (NOx), and particulate matter (PM). The outputs in the reporting tool enable partners to conduct analyses that help them optimize the efficiencies of their transportation management activities. These outputs are in reports, embedded in the tool, and can be used to benchmark and continuously improve partner sustainability performance year-over-year.



After initially submitting data in the reporting tool when they first join, partners are asked to annually update their transportation management activities using the reporting tool. These annual updates help partners to track fuel economy improvements and monitor the effectiveness of their actions to improve their freight efficiency and reduce emissions year after year. EPA uses these annual updates to monitor the progress of the SmartWay program.

  1. SmartWay Affiliate Agreement

SmartWay affiliates are organizations that encourage their members or customers to participate in SmartWay. Affiliates also commit to highlighting SmartWay within the freight transportation industry. To become an affiliate, the organization must complete and submit an affiliate agreement to the EPA.

In return, EPA agrees to do the following:

  • Educate SmartWay partners about the affiliates’ involvement;

  • Publicize affiliates’ participation through SmartWay events, the website, and listing in educational materials. EPA will obtain written consent from an Affiliate before publishing its name in a context beyond increasing public awareness of its participation as described above;

  • Provide resources to affiliates to assist them in highlighting SmartWay;

  • Allow affiliates to use the SmartWay Transport name in their activities related to promoting the SmartWay Transport Program provided the name is never used to imply EPA endorsement of affiliates, their products or services;

  • Provide EPA representatives as requested and as available to speak about SmartWay at affiliate meetings, workshops, and conferences;

  • Provide technical assistance as needed to help affiliates achieve program goals.



  1. SmartWay Excellence Awards

Partners may be considered for a SmartWay Excellence Award and gain public recognition for their environmental performance. Efficiency and emissions data may be used by partners to demonstrate their progress in reducing fuel use and air emissions. As part of the award process, a subset of partners (shippers, logistics providers, and multimodal carriers) may also provide greater detail on specific actions/strategies they have taken to increase the efficiency of their transportation-related business activities while reducing environmental impacts.

  1. Program Evaluation

Through workshops, webinars, conferences, and other interactive venues, SmartWay provides opportunities for partners, other industry representatives, and consumers to provide input on their experience with SmartWay.

  1. SmartWay Tractor and Trailer Program

EPA-designated SmartWay tractors and trailers are a newer generation of long-haul rigs equipped with clean, fuel-saving features that meet recommended equipment specifications. EPA-designated SmartWay tractors and new and retrofitted trailers can achieve fuel savings of 10 to 20 percent and lower emissions, as compared to non-SmartWay-designated trucks. SmartWay-designated tractor and trailer owners need not be registered SmartWay partners.

For-hire carriers, owner-operators, manufacturers, and retailers with private fleets that own, lease, and/or operate EPA-designated SmartWay tractors or trailers are eligible to label the exterior of their EPA-designated SmartWay tractors or trailers with the SmartWay logo. Both SmartWay partners and other private or for-hire fleets may submit an application to EPA to obtain the digital files of the EPA-designated SmartWay logo for eligible tractors and trailers.

Original Equipment Manufacturers (OEMs) that produce tractors and trailers that meet the EPA-designated SmartWay specifications may complete and submit a SmartWay license agreement in order to access and use the SmartWay designated logo for promotional purposes.

EPA may re-evaluate designation requirements over time to reflect changes in the fleet mix.



Supporting Statement A

  1. NEED AND AUTHORITY FOR THE COLLECTION:

Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

The EPA’s Office of Transportation and Air Quality (OTAQ) established SmartWay under directives outlined in Title VII Subtitle D of the Energy Policy Act of 20051 which calls on EPA to assess the energy and air quality impacts of activities within the freight industry. These activities include long-duration truck idling, the development and promotion of strategies to reduce idling, fuel consumption, and associated negative air quality effects. SmartWay’s objectives also are consistent with the Clean Air Act, the Federal Technology Transfer Act, and other laws that authorize and support research, training, and air pollutant control activities.

  1. PRACTICAL UTILITY/USERS OF THE DATA:

Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

Information collected through SmartWay assists OTAQ in evaluating the challenges the freight industry is managing as the industry seeks to conserve fuel, reduce idling activity, lower emissions, and improve its overall economic and environmental performance (through the application of technology-based controls, efficient logistics management strategies, and related approaches). SmartWay also provides opportunities for EPA and industry to cooperate and collectively execute strategies that can help improve the transportation industry’s financial and environmental performance, both in the short term and the long term.


Data gathered through SmartWay contribute to OTAQ’s goals to improve transportation efficiencies, reduce transportation-based emissions, and protect human health and the environment. SmartWay program data also is critical to monitoring and measuring the success of SmartWay as a public/private partnership, both in terms of collaboration and as a tool for improving supply chain efficiency and contributing to cleaner air.

  1. USE OF TECHNOLOGY:

Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

EPA will use the Agency’s public web system, a database hosted by Amazon Web Services under contract to EPA, a telephone system, computers, and applicable software to collect, summarize, and analyze information gathered under this ICR. Research may also be undertaken periodically to gauge program effectiveness. The reporting tools have embedded quality assurance controls based on EPA’s statistical analyses of historical freight transportation data. These controls assist the Agency in managing the data and labor costs effectively.

Additionally, EPA will ensure the accuracy and completeness of collected information by reviewing each submittal. The Agency will upload the reviewed and approved data obtained into the partner database and will aggregate data obtained to monitor the progress of participants. These efforts will help to ensure the proper use and processing of the data being collected to enhance the value of the program’s information to EPA and the public.

  1. EFFORTS TO IDENTIFY DUPLICATION:

Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

The information collected under this ICR is not collected by any other EPA office or any other federal agency. Therefore, no potential for duplication with other federal collections exists.

  1. MINIMIZING BURDEN ON SMALL ENTITIES:

If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

EPA expects that some independent truck owners, small fleet (20 and under trucks) operators and other small businesses will participate in SmartWay. EPA has designed its information collections to minimize respondent burden while obtaining sufficient and accurate freight transportation information. EPA has tailored its reporting tools to ensure that the burden on all businesses – including small businesses – is minimal. For truck carrier partners with 20 trucks or fewer filling out an annual update, EPA has introduced an On-Line Truck Tool, which takes less time to fill out.

Small entities, along with any respondent, can call the SmartWay Helpline, attend and/or download recorded SmartWay webinars, download instruction guides or use the SmartWay email box to access help and program information. Additionally, SmartWay works with affiliates such as state trucking associations to provide additional education and training.

  1. EFFECTS OF LESS FREQUENT COLLECTION:

Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The annual agreement is part of the reporting tool. Less frequent data collection would reduce the value of the data in informing freight transportation industry decisions, decrease program effectiveness, and hamper EPA’s ability to track emission benefits.

A company submits the annual reporting tool upon joining SmartWay and annually thereafter, for as long as an organization remains a SmartWay partner. First-year system outputs are used by partners as a baseline to establish energy and emission reduction goals in the future.

Submitting annual reporting tool updates is necessary for SmartWay partners to determine the effectiveness of their actions to reduce emissions and energy use year-over-year. Likewise, for EPA, collecting and storing the reporting tool data annually ensures that the Agency is able to establish quantitative information on the Program’s progress in reaching SmartWay’s goals.

Submitting a reporting tool to EPA less frequently than annually would prevent EPA and its SmartWay partners from tracking and assessing the progress of partners and the program as a whole. It also would make it difficult for partners to modify their strategies to reduce energy use and emissions, as needed, to meet their goals. Annual reporting tool updates are necessary for EPA and its SmartWay partners to effectively work toward their shared energy and environmental goals. It would also require significant changes to the program’s reporting tools and structure.

The updated data also are important to EPA when assessing partner performance as part of the SmartWay Excellence Awards program. The Excellence Awards are an important improvement incentive and encourage partners to implement effective strategies that help conserve energy, reduce emissions, and improve air quality. This recognition is given on an annual basis.

  1. GENERAL GUIDELINES:

Explain any special circumstances that require the collection to be conducted in a manner inconsistent with PRA Guidelines at 5 CFR 1320.5(d)(2).

These reporting or recordkeeping requirements do not violate any of the regulations promulgated by OMB under 5 CFR Part 1320, Section 1320.5.

  1. PUBLIC COMMENT AND CONSULTATIONS:

8a. Public Comment

If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the Agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the Agency in response to these comments. Specifically address comments received on cost and hour burden.

The announcement of a public comment period for this renewal ICR was made in the Federal Register on December 11, 2024, under Docket ID Number EPA-HQ-OAR-2024-0423. One comment was received, stating support for the SmartWay program, and offering no comment on the burden estimates.

8b. Consultations

Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

As part of the Program Evaluation component of this information collection, EPA received feedback from the following trucking companies on the On-line Truck Tool:



  • Andrus Transportation Services

  • ATS Specialized, Inc

  • Averitt Express

  • CRST Dedicated Services, Inc.

  • CRST Expedited, Inc.

  • D & D Sexton Inc.

  • D. M. Bowman Inc.

  • Domino's Pizza LLC

  • H.O. Wolding, Inc.

  • Hobby Lobby Stores Inc.

  • Marathon Petroleum Company

  • Moon Star Express, LLC

  • Mustang Express LTD

  • Pitt Ohio

  • Sunbelt Transport LLC

  • Sunstate Carriers Inc.

  • TransAm Trucking, Inc.

  • Ursa Logistics

  • USA Truck, Inc.

  • 1-800-Pack-Rat, LLC

  • A&R Logistics, Inc.

  • Evergreen Transport, LLC

  • FedEx Freight Inc.

  • Jack Cooper Transport Co., Inc.

  • JK Moving Services

  • Mountain Valley Express Co., Inc.

  • Panther Premium Logistics

  • Southwestern Motor Transport - SMT Lines

  • J.B. Hunt Transport, Inc.

  • Swift Transportation Co. of Arizona, LLC

  • YRC Worldwide Inc.



These partners gave feedback on the user-friendliness and clarity of the new tool as well as on the length of time needed to complete it. The tool includes a feedback questionnaire, with one of the questions being whether the online tool takes more or less time than the Excel tool. 72% percent of respondents indicated that the online tool was either a little faster to complete or much faster.

  1. PAYMENTS OR GIFTS TO RESPONDENTS:

Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

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

  1. PROVISIONS FOR PROTECTION OF INFORMATION:

Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy. If the collection requires a system of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.

Participation in SmartWay is not mandated and may be terminated by participants or EPA at any time. Active partners provide company-specific data to EPA. Such data may contain commercial or financial information or trade secrets. Accordingly, EPA manages SmartWay partner company-specific data and information in accordance with EPA’s provisions on confidentiality. 40 CFR Part 2, Subpart B establishes EPA’s general policy on the public disclosure of information and procedures for handling confidential business information (CBI) claims.

  1. JUSTIFICATION FOR SENSITIVE QUESTIONS:

Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the Agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

The reporting or recordkeeping requirements in the standard do not include sensitive questions.

  1. RESPONDENT BURDEN HOURS AND LABOR COSTS:

Provide estimates of the hour burden of the collection of information. The statement should:

  • Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

  • If this request for approval covers more than one form, provide separate hour burden estimates for each form and the aggregate the hour burdens.

  • Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included as O&M costs under non-labor costs covered under question 13.



12a. RESPONDENTS/NAICS CODES

Table 12.1 lists selected North American Industrial Classification System (NAICS) codes and the primary industry sectors associated with those codes. These industry sectors may be affected by SmartWay-related information collections covered under this ICR.


Table 12.1

List of NAICS Codes for SmartWay Partners


NAICS Code Industry

421 Wholesale Trade, Durable Goods

422 Wholesale Trade, Nondurable Goods

4211 Motor Vehicle and Motor Vehicle Part and Supplies

42111 Automobile and Other Motor Vehicle Wholesalers

42112 Motor Vehicle Supplies and New Part Wholesalers

423 Wholesale Trade, Nondurable Goods

44-45 Retail Trade

48-49 Transportation and Warehousing

481 Air Transportation

4811 Scheduled Air Transportation

481112 Scheduled Freight Air Transportation

4812 Nonscheduled Air Transportation

48121 Nonscheduled Air Transportation

481212 Nonscheduled Chartered Freight Air Transportation

481219 Other Nonscheduled Air Transportation

482 Rail Transportation

4821 Rail Transportation

48211 Rail Transportation

482111 Line-Haul Railroads

482112 Short-Line Railroads

483 Water Transportation

4831 Deep Sea, Coastal and Great Lakes Water Transportation

48311 Deep Sea, Coastal and Great Lakes Water Transportation

483111 Deep Sea Freight Transportation

483113 Coastal and Great Lakes Freight Transportation

4832 Inland Water Transportation

48321 Inland Water Transportation

483211 Inland Water Freight Transportation

484 Truck Transportation

4841 General Freight Trucking

48411 General Freight Trucking, Local

48412 General Freight Trucking, Long-Distance

484121 General Freight Trucking, Long-Distance, Truckload

484122 General Freight Trucking, Long-Distance, LTL

4842 Specialized Freight Trucking

488 Support Activities for Transportation

4881 Support Activities for Air Transportation

48811 Airport Operations

488119 Other Airport Operations

48819 Other Support Activities for Air Transportation

4882 Support Activities for Rail Transportation

48821 Support Activities for Rail Transportation

4883 Support Activities for Water Transportation

48831 Port and Harbor Operations

48832 Marine Cargo Handling

48833 Navigational Services to Shipping

48839 Other Support Activities for Water Transportation

4884 Support Activities for Road Transportation

4885 Freight Transportation Arrangement

48851 Freight Transportation Arrangement

4889 Other Support Activities for Transportation

48899 Other Support Activities for Transportation

488991 Packing and Crating

488999 All Other Support Activities for Transportation

4931 Warehousing and Storage Facilities

49311 General Warehousing and Storage Facilities

49312 Refrigerated Warehousing and Storage Facilities

49319 Other Warehousing and Storage Facilities

Noting trends in partner and affiliate matriculation observed during the previous 3 years, the Agency has downgraded its expectations for respondent growth from 403 partners per year to 50 and from 26 affiliates to 7. The Agency is continuing to approximate that about 75% of first-time registrants will continue participating in the program in subsequent years. As displayed in Table 12.2, the total number of respondents over the three-year period of this collection is 4,230.

Table 12.2– Respondent Counts


Number of Partners Filing Repeat Annual Reports

Number of New Partners Applying

Number of New Affiliates Applying

Total Respondents (over 3-year approval period)

4230


Total Affiliates

YR 1

4098*

50

7

 234*

plus 75% of previous year's new

38

 


 5.25

YR 2

4136

50

271

 239.25

plus 75% of previous year's new

38

 

7

 5.25

YR 3

4173

50

7

 244.5

*Actual as of March 2025.

Response totals associated with year two of the three-year approval period represent the average count for this collection. As displayed in Table 12.3, on average, about 4,500 total responses are expected annually.









Table 12.3– Average Annual Responses

New Partner Applications

50

New Affiliate Applications

7

Annual Reports


Via Excel Spreadsheet

30

Via Online Tool

3643

Via Online Short Form

500

Excellence Awards

132

Program Evaluation

150

Tractor and Trailer Program Applications


Buyers

19

OEM Manufacturers

16

Total

4,547



12b. RESPONDENT ACTIVITIES, INFORMATION REQUESTED, AND BURDEN

  1. SmartWay Partnership Application

A company joining SmartWay completes a partner Application, which includes reading and accepting the Partnership Agreement, indicating which type of partner they are, and providing basic contact information. It also includes the Partnership Agreement which the partner reviews, including legal review, if necessary.

To register with SmartWay, respondents are asked to:

  • Complete a Partner Application

  • Access the reporting tool through the Partner Portal,

  • Review the embedded partnership annual agreement and agree to its terms,

  • Complete the reporting tool, and

  • Submit the completed reporting tool to EPA electronically via the Partner Portal.

The partnership annual agreement includes the following information:

  • The importance of an accurate and true reporting tool submission,

  • Terms of the company’s commitment,

  • Terms of EPA’s commitment,

  • General terms of the SmartWay partnership, and

  • A statement confirming an understanding of the annual agreement.

EPA anticipates that 50 partners will submit new partnership applications each year. On average, EPA estimates each original partner application will require about 5.25 hours to complete resulting in $440 in labor costs.

  1. SmartWay Partners Annual Agreements & Reporting

Upon joining SmartWay, carriers, shippers, and logistics management companies agree to annually measure efficiency and emissions generated by their freight transportation-related activities. To do so, partners collect data on their freight management business, such as transportation mode, fleet size, equipment type, fuel use, number of miles traveled, payload, and related factors. They then input this information into the reporting tool and submit it electronically to the EPA.

After initially submitting data in the reporting tool when they first join, partners are asked to annually update their transportation management activities using the reporting tool. These annual updates help partners track fuel economy improvements and monitor the effectiveness of their actions to improve their freight efficiency and reduce emissions year after year. EPA uses these annual updates to monitor the progress of the SmartWay program.

Annual reporting activities include:

  • Gathering freight transportation data (fuel, miles, and payload) needed for the reporting tool,

  • Reviewing reporting tool reports and data, and

  • Submitting a new or updated reporting tool and reviewing data outputs annually.

Available reporting tools include truck, rail, inland marine (barge), air, multi-modal, and logistics.

For carrier partners, the reporting tool requires the following information:

  • Contact information, including a responsible primary contact for the company, an alternate contact, an executive contact; street and electronic addresses and phone numbers, and

  • Information about the company, including data about its existing transportation equipment, such as the number of trucks employed; gallons of fuel used and miles traveled annually; average payload; clean air equipment deployed; and idling activity.


For shipper and logistics partners, the reporting tool requires the following information:

  • Contact information, including a responsible primary contact for the company, an alternate contact, an executive contact; street and electronic addresses, and phone numbers, and

  • Information about the company’s transportation activities, including carriers hired to transport goods; mode/s used to transport goods; and freight facility operations.

In the past, the SmartWay annual reporting tool was based on a Microsoft Excel-based spreadsheet. SmartWay partners download the reporting tool from the SmartWay website (www.epa.gov/smartway), enter their freight transportation data, and return the file to the Agency. EPA estimates that, on average, only 30 respondents per year will report using the Excel spreadsheet.

In the period since the last ICR was submitted, reporting has transitioned almost completely to the online reporting tool, a secure online form accessed through the SmartWay partner portal. SmartWay partners enter their freight transportation data annually, enabling them to quantify the environmental performance of their freight transportation-based operations in reports generated by the tool. Based on current partner levels and observed participation rates, EPA estimates that, on average, 3643 respondents per year will report using the online form.

Additionally, truck carrier partners with 20 trucks or fewer can fill out a simpler online tool, referred to as the Short Form Truck Tool. EPA estimates that 500 partners will use this reporting tool.

EPA estimates it takes respondents 2.5 hours ($206 in labor costs) to submit an annual report using the Excel-based tool, about 1.6 hours ($131 in labor costs) using the online line portal, and approximately 1.0 hour ($79 in labor costs) for those using the Short Form Truck Tool. These estimates include the time needed to review system outputs prior to sending them to EPA.




  1. Annual SmartWay Excellence Award

The Annual SmartWay Excellence Awards recognize outstanding achievements by partners in the program. Data from the reporting tools uploaded and summarized in the partner database provide the basis for an award. A subset of partners (shippers, logistics providers, and multimodal carriers) also have the option of providing additional qualitative information, as listed below, to be considered for an award. Additional information that may be provided by a Partner includes:

  • Efforts undertaken to educate its staff, customers, stakeholders, and the public about its participation in SmartWay, and

  • Other activities supporting its participation as a SmartWay partner (e.g., a shipper may offer special assistance or incentives that help and/or encourage carriers to join SmartWay).

When a partner chooses to submit this information, it will:

  • Gather and compile information (dates, participants, weight, and/or emissions savings data) on its activities, including samples of promotional materials and in-house tools developed to highlight their involvement in SmartWay, and

  • Send these materials to EPA, electronically.

On average, EPA estimates that 132 partners will choose to submit applications each year and that this activity will 3.25 hours (resulting in $282 in labor costs) to accomplish.

  1. SmartWay Affiliate Agreement

An organization that wishes to support SmartWay as an affiliate completes the SmartWay affiliate agreement when it joins SmartWay. The affiliate agreement is in Adobe Acrobat format and is submitted electronically, or by fax. This activity includes the following:

  • Download the affiliate agreement

  • Review its terms, and

  • Submit the signed affiliate agreement to EPA electronically.

A completed affiliate agreement lists the commitments that both EPA and the joining organization assume by working together through the SmartWay partnership. On average, EPA estimates that 0.66 hours ($66 in labor costs) are needed to thoroughly review, comprehend, and submit the affiliate agreement. This could include some legal review.

  1. SmartWay Tractor and Trailer Program

For-hire carriers, owner-operators, manufacturers, and retailers with private fleets that own, lease, and/or operate EPA-designated SmartWay tractors or trailers are eligible to label the exterior of their EPA-designated SmartWay tractors or trailers with the SmartWay logo. Both SmartWay partners and other private or for-hire fleets may submit an application to EPA to obtain the digital files of the EPA-designated SmartWay logo for eligible tractors and trailers.

Original Equipment Manufacturers (OEMs) that produce tractors and trailers that meet the EPA-designated SmartWay specifications may complete and submit a SmartWay license agreement in order to access and use the SmartWay designated logo for promotional purposes.

For-hire carriers, owner-operators, and manufacturers utilizing the SmartWay Equipment Checklist

Any company*, individual* or SmartWay partner that wants to label the exterior of its tractors and/or trailers as “EPA-designated SmartWay Tractor” or “EPA-designated SmartWay trailer” will complete and submit the SmartWay Equipment Checklist that may be downloaded from the EPA’s SmartWay website. Completion and submission of the Equipment Checklist signifies that a company owns or operates the respective tractor and/or trailer that meets the EPA-designated SmartWay specifications.

* Note: The EPA-designated SmartWay tractor and trailer logos are separate from and different than the SmartWay partner logo and can be applied for by any buyer of EPA-designated SmartWay equipment.

The SmartWay Tractor and Trailer Program application includes the following steps:

  • Review the EPA-designated SmartWay technical specifications to determine whether the tractor and/or trailer is eligible for the designation,

  • Review the SmartWay Graphic Standards and Usage Guide that details specifics and guidelines for SmartWay logo use,

If eligible, respondents complete and submit the SmartWay Equipment Checklist which can be downloaded from the SmartWay website. Data that the partner or EPA-designated equipment buyer submits in the SmartWay Equipment Checklist include:

  • Name of the truck and/or trailer manufacturer,

  • Name of the truck and/or trailer model/brand,

  • The model year of the truck and/or trailer,

  • Identification of SmartWay-verified technologies on the trucks (e.g., tires, idling control devices) and trailers (e.g., tires, aerodynamic equipment), and

  • The number of EPA-designated SmartWay trucks and/or trailers in use by the company fleet owner/operator/lessor.

The company fleet owner/operator/lessor also completes and submits the Mark (i.e., logo) Signature Form. This form is found on page 54 of the SmartWay Graphic Standards & Usage Guide. Signing and submitting this form to EPA signifies understanding of the agreement to adhere to the SmartWay logo guidelines.

EPA estimates that it takes partners and company fleet owners/operators/lessors approximately 2.75 hours ($228 in labor costs) to compile and submit the SmartWay Equipment Checklist and Mark Signature Form. EPA estimates that, on average, 16 buyers will complete this process each year.

Original Equipment Manufacturers (OEMs) and SmartWay License Agreement

Any manufacturer that wishes to label the interior of tractors or trailers it produces as “SmartWay Designated” will complete and submit the SmartWay License Agreement that may be downloaded from the EPA’s SmartWay website (See Exhibit 8 for a copy of the SmartWay License Agreement). Completion and submission of the License Agreement authorizes advertising and promotion of tractors or trailers that meet the EPA-designated SmartWay specifications by Original Equipment Manufacturers

EPA estimates that it takes manufacturers approximately .5 hours ($41 in labor costs) to read, complete, and sign the SmartWay License Agreement. Additional time may be necessary to garner internal company approvals.

The SmartWay Tractor and Trailer Program application includes the following steps:

  • Review the EPA-designated SmartWay technical specifications to determine whether the tractor and/or trailer is eligible for the designation,

  • Review the SmartWay Graphic Standards and Usage Guide that details specifics and guidelines for SmartWay logo use,

A SmartWay Equipment Checklist needs to be submitted for additional purchases of new trucks and/or trailers to be branded with the SmartWay-designated logos.

Manufacturers are requested to submit the SmartWay License Agreement every 3 – 6 years. The following information is requested:

  • Company (licensee) Name

  • Signatory Name (of licensee)

  • Signatory Title

  • Licensee company address

  • Signatory phone number

  • Signatory email address

  • Date

12d. RESPONDENT BURDEN HOURS AND LABOR COSTS

The labor rates used to estimate costs to respondents are consistent with hourly national wage rates published by the U.S. Bureau of Labor Statistics publications on employment and earnings for 2023. EPA estimates a median hourly respondent labor cost. EPA also multiplied hourly wage rates by the standard government overhead factor of 1.6 to calculate overhead costs such as paid leave, health insurance, retirement savings, office space, computers, and other business expenses. This resulted in hourly respondent labor burden of $102.94 for legal staff, $105.97 for managerial staff, $87.02 for technical staff, and $45.82 for clerical and/or administrative staff. Those rates are all higher than in the previous ICR except the rate for legal staff, which is $8.85 lower than the rate of $111.79 used in the previous ICR.

Overall, the average annual respondent burden and labor costs associated with this collection are 7198 hrs. and $590,783. Burden and cost breakdowns are presented in Exhibit 1 at the end of this ICR.

  1. RESPONDENT CAPITAL AND O&M COSTS:

Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).

The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should consider costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling, and testing equipment; and record storage facilities.

If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate.

Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

EPA does not expect that respondents will incur non-labor costs associated with this collection. Any computer equipment and software needed to compile and submit responses will have already been acquired to conduct usual and customary business practices.

  1. AGENCY COSTS:

Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

14a. Agency Activities

The data in Exhibit 2 shows that EPA estimates that each EPA federal burden hour for the information collection activities associated with SmartWay is conducted by an experienced technical staff person. EPA also includes overhead costs associated with employing an experienced technical staff person, such as paid leave, health insurance, retirement savings, office space, telephones, computers, and other business expenses.

EPA SmartWay managers, staff, and Partner Account Managers (PAMs) will perform certain activities associated with information collections described in this ICR. These activities serve to develop, evaluate, and support the SmartWay program.

SmartWay Partner Application

The Agency receives the Agreement and assigns the Applicant to a Partner Account Manager (PAM). The Applicant becomes a partner upon submission of their first Annual Report Tool. Applicants access the form on the SmartWay website, complete it online, and submit it electronically where it is routed to the SmartWay database for action. A PAM is a technical expert who is responsible for reviewing and approving SmartWay partner tool submissions, offers suggestions to partners on efficiency strategies and improvements, and engages non-SmartWay companies with SmartWay

SmartWay Annual Agreement

The Agency will perform the following activities related to the partnership annual agreement:

  • Promote company participation by posting partner names on the SmartWay website and in related educational, training, and media materials,

  • Provide partners with their freight transportation performance ranking data as it becomes available and summarized by EPA,

  • Assist partners in achieving freight performance goals,

  • Update and maintain the SmartWay website, and

  • Monitor the distribution and use of SmartWay logos.

SmartWay Annual Reporting Tool

The Agency will perform the following activities related to SmartWay partner-submitted reporting tools:

  • Review, approve, and upload to the partner database new and updated partner freight transportation performance data submitted in the reporting tool,

  • Send a welcome letter and registration certificate to the new partner,

  • Request updates of data, strategies undertaken, and substantiation of information annually,

  • Review partner activities undertaken to highlight their SmartWay participation,

  • Review the partner’s year-over-year progress in the database, and note any anomalies that would necessitate a call from the PAM to the partner,

  • Update and maintain SmartWay Website Performance Carrier Ranking List.

Annual SmartWay Excellence Awards

The Agency will review SmartWay partner data and any additional information/data partners provide to highlight their progress and achievements in “leaning and greening” their freight operations:

  • Review and rank performance data that is submitted,

  • Review and assess other partner information submitted for award consideration, and

  • Summarize and evaluate partner accomplishments and achievements that warrant excellence recognition.

Program Evaluation

The Agency will review data and feedback from its partners, and industry representatives on the program and use it to adjust/change and improve the program.

SmartWay Tractor and Trailer Program

SmartWay will perform the following activities in support of the SmartWay Tractor and Trailer Program:

  • Review the tractor and trailer logo requests from companies via checklist submissions,

  • Answer questions of companies, individuals, and partners, as appropriate, and

  • Once approved, send the digital logo files to the EPA-designated SmartWay equipment buyer(s),

  • Review and file the SmartWay License Agreement,

  • Send the digital files of the SmartWay designated logo to the manufacturer.

14b. Agency Burden and Labor Cost

EPA assumed that federal staff-level burden hours would be completed by an experienced technical staff person being paid at a GS-13, Step 3 federal government employee salary of $123,990/year.2 EPA then divided the annual 2023 GS-13, Step 3 salary by 2080 (the number of hours in a work year) and multiplied this number by the standard government overhead factor of 1.6. This calculation resulted in a federal cost of $95.38/burden hour.

EPA also assumed that managerial oversight would be completed by a manager being paid at the GS-14, Step 3 federal government employee salary of $146,518 /year. EPA then divided that annual salary figure by 2080 (the number of hours in a work year) and multiplied this number by the standard government overhead factor of 1.6. This calculation resulted in a federal cost of $112.71/burden hour.

EPA also uses Senior Environmental Employees (SEEs) to support SmartWay. For the SEE employees, EPA used the average hourly rate for Tier B Technical Staff of $19.71 multiplied by 1.43 benefits rate for $28.19/burden hour. Labor rates for SEE employees are based on standard rates applied by the Center for Workforce Inclusion, Inc., the administrator of a grant program that makes SEE employees available to the EPA.

Overall, the average annual agency burden and labor costs associated with this collection are 3,520 hrs. and $124,192. Burden and cost breakdowns are presented in Exhibit 2 at the end of this ICR.

4c. Agency Non-Labor Costs

There are no anticipated non-labor costs for the Agency.

  1. CHANGE IN BURDEN:

Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost estimates.

The decrease in respondent burden since the previous ICR was approved is approximately 5,632 hours and can be attributed to the following adjustments:

  • The average number of new affiliates joining annually has fallen to 7 from 30. Additionally the total number of partners and the average number of new partners applying to the program have been downwardly adjusted from the projections made in the previous ICR. These adjustments account for updated growth rates based on observed applicant figures from the past three years. EPA believes that many of the entities that would have an interest in joining the SmarWay program have already done so.

  • The conversion of most partner reporting from the Excel-based method to the online portal (and for those authorized to use it, the online short form) has resulted in significant efficiencies for respondents. The magnitude of these burden reductions was verified through user feedback.

  • Burden and costs associated with the use of postage to transmit forms to EPA have been eliminated since all forms are now transmitted electronically.

  1. PUBLICATION OF DATA:

For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

Data from carrier and logistics reporting tools are used to calculate gram-per-mile and gram-per-ton-mile emission rates for each partner. These emission rates are displayed in the Carrier Performance Report, on the SmartWay website. However, because of privacy concerns, the actual emission rates, as calculated in the tools, are not displayed. Rather the rates for each reporting group are divided into five bin ranges, and for each partner, the midpoint of the range in which they fall is displayed rather than their actual emissions.

  1. DISPLAY OF OMB CONTROL NUMBER AND EXPIRATION DATE ON INSTRUMENTS:

If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

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

  1. CERTIFICATION STATEMENT:

Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

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




ADDITIONAL TABLES AND APPENDICES















Exhibit 1












Estimated Annual Respondent Burden and Cost












US EPA SmartWay Program












Information Collection Activity



Hours and Costs per Respondent




Average Annual Total Hours and Cost



 

 

 




 

 

 

2023 Legal

2023 Manager

2023 Technical

2023 Clerical

Response Hours/Year

Labor Cost/ Year

Capitol Startup Costs

O&M Costs

Number of Respondses

Total Hours/ Year

Total Cost/ Year

Unloaded Wage Rates

$ 64.34

$ 66.23

$ 54.39

$ 28.64








Loaded Wage Rates

$ 102.94

$ 105.97

$ 87.02

$ 45.82








Affiliate Agreement

 

 

 

 

 

 

 

 

 

 

 

Review Affiliate Agreement & Submit Online

0.25

0.25

0.16

0

0.66

$ 66.15

0

$0.00

7

5

$ 463

Subtotal

0.25

0.25

0.16

0

0.66

$ 66.15

0

0

7

4.62

$ 463

New/Initial SmartWay Reporting Tool

 

 

 

 

 

 

 

 

 

 

 

Review Partnership Annual Agreement

0.25

0.24

0.16

0

0.65

$ 65.09

0

$0.00

50

33

$ 3,255

Gather data & info for reporting tool

0

0.5

1.46

0

1.96

$ 180.04

0

$0.00

50

98

$ 9,002

Input data into reporting tool

0

0

1

0.94

1.94

$ 130.10

0

$0.00

50

97

$ 6,505

Review reporting tool

0

0.2

0.5

0

0.7

$ 64.71

0

$0.00

50

35

$ 3,235

Subtotal

0.25

0.94

3.12

0.94

5.25

$ 439.94

$0.00

$0.00

50

263

$ 21,997

Excel-Based SmartWay Reporting Tool

 

 

 

 

 

 

 

 

 

 

 

Gather Data & Info to Update reporting tool

0

0

1

0

1

$ 87.02

0

$0.00

30

30

$ 2,611

Input data into reporting tool

0

0

0

0.5

0.5

$ 22.91

0

$0.00

30

15

$ 687

Review reporting tool

0

0.5

0.5

0

1

$ 96.50

0

$0.00

30

30

$ 2,895

Send reporting tool to EPA

0

0

0

0

0

$ -

0

$0.00

30

0

$ -

Subtotal

0

0.5

1.5

0.5

2.5

$ 206.43

$0.00

$0.00

30

75

$ 6,193

SmartWay Online Tool

 

 

 

 

 

 

 

 

 

 

 

Gather Data & Info to Update reporting tool

0

0

0.75

0

0.75

$ 65.27

0

$0.00

3,643

2,732

$ 237,771

Input data into reporting tool

0

0

0

0.25

0.25

$ 11.46

0

$0.00

3,643

911

$ 41,734

Review reporting tool

0

0.1

0.5

0

0.6

$ 54.11

0

$0.00

3,643

2,186

$ 197,118

Send reporting tool to EPA

0

0

0

0

0

$ -

0

$0.00

3,643

0

$ -

Subtotal

0

0.1

1.25

0.25

1.6

$ 130.83

$0.00

$0.00

3,643

5,829

$ 476,624

SmartWay Online Tool Short Form

 

 

 

 

 

 

 

 

 

 

 

Gather Data & Info to Update reporting tool

0

0

0.4

0

0.4

$ 34.81

0

$0.00

500

200

$ 17,405

Input data into reporting tool

0

0

0

0.25

0.25

$ 11.46

0

$0.00

500

125

$ 5,728

Review reporting tool

0

0.1

0.25

0

0.35

$ 32.35

0

$0.00

500

175

$ 16,176

Send reporting tool to EPA

0

0

0

0

0

$ -

0

$0.00

500

0

$ -

Subtotal

0

0.1

0.65

0.25

1

$ 78.62

$0.00

$0.00

500

500

$ 39,309

SmartWay Excellence Awards

 

 

 

 

 

 

 

 

 

 

 

Gather information for EPA consideration

0

0

2

0

2

$ 174.05

0

$0.00

132

264

$ 22,974

Review and Send Information to EPA

0

0.5

0.5

0.25

1.25

$ 107.95

0

$0.00

132

165

$ 14,250

Subtotal

0

0.5

2.5

0.25

3.25

$ 282.00

$0.00

$0.00

132

429

$ 37,224

Program Evaluation

 

 

 

 

 

 

 

 

 

 

 

Complete and submit online assessment

0

0.25

0

0

0.25

$ 26.49

0

$0.00

150

38

$ 3,974

Subtotal

0

0.25

0

0

0.25

$ 26.49

$0.00

$0.00

150

38

$ 3,974

SmartWay Tractor &Trailer Program

 

 

 

 

 

 

 

 

 

 

 

Buyers complete the Equipment Checklist

0

0.5

1.75

0.5

2.75

$ 228.19

0

$0.00

19

52

$ 4,336

OEMs updating License Agreement

0

0.09

0.32

0.09

0.5

$ 41.51

0

$0.00

16

8

$ 664

Subtotal

0

0.59

2.07

0.59

3.25

$ 269.70

$0.00

$0.00

35

60

$ 5,000

Totals

0.25

2.98

11.09

2.78

17.1

$ 1,434.01

0

0

4540

7,193

$ 590,320





Exhibit 2











Estimated Annual Agency Burden and Cost











US EPA SmartWay Program











Information Collection Activity

Hours and Costs per Respondent



Average Annual Total Hours and Cost


2023 Manager

2023 Technical

2025 SEE

Agency Hours/ Year

Labor Costs/ Year

Annual Capitol Startup Costs

Annual O&M Costs

Number of Respond. Activities

Total Agency Hours/ Year

Total Cost/ Year


$ 112.71

$ 95.38

$ 28.19








Partnership and Affiliate Agreements

 

 

 

 

 

 

 

 

 

 

Review & process submitted Affiliate Agreements

0.03

0.00

0.08

0.11

$ 5.64

0.00

0.00

57

6.27

$321

Send a Letter Welcoming Partner to SmartWay Program

0.00

0.00

0.08

0.08

$ 2.25

0.00

0.50

57

4.56

$129

Update EPA/SmartWay Website-Affiliates

0.00

0.00

0.08

0.08

$ 2.25

0.00

0.00

57

4.56

$129

Subtotal

0.03

0.00

0.24

0.27

$ 10.15

0.00

28.50

57

15.39

$578

New SmartWay Reporting Tools

 

 

 

 

 

 

 

 

 

 

Review and Evaluate Reporting Tools

0.00

0.25

1.50

1.75

$ 66.12

0.00

0.00

427

747.25

$28,234

Update SmartWay partner database with Reporting Tool Data

0.00

0.00

0.50

0.50

$ 14.09

0.00

0.00

427

213.50

$6,018

Update EPA/SmartWay Website

0.00

0.00

0.00

0.00

$ -

0.00

0.00

427

0.00

$0

Subtotal

0.00

0.25

2.00

2.25

$ 80.21

0.00

0.00

427

960.75

$34,252

Update SmartWay Air Pollutant Tracking System

 

 

 

 

 

 

 

 

 

 

Review and Evaluate Updated Excel Reporting Tools

0.00

0.08

0.50

0.58

$ 21.72

0.00

0.00

30

17.40

$652

Review and Evaluate On-Line & Truck Reporting Tools

0.00

0.08

0.25

0.33

$ 14.68

0.00

0.00

4143

1367.19

$60,805

Update SmartWay Partner Acct Mgmt D-base with Updated Reporting Tools

0.00

0.08

0.08

0.16

$ 9.88

0.00

0.00

4173

667.68

$41,250

Subtotal

0.00

0.16

0.58

0.74

$ 46.28

0.00

0.00

4173

3088.02

$41,902

SmartWay Excellence Awards

 

 

 

 

 

 

 

 

 

 

Develop Awards Criteria

0.08

0.50

0.00

0.58

$ 56.70

0.00

0.00

132

76.56

$7,485

Review Database for Environmental Data

0.00

0.50

1.00

1.50

$ 75.87

0.00

0.00

132

198.00

$10,015

Receive and review other information submitted

0.00

1.00

0.50

1.50

$ 109.47

0.00

0.00

132

198.00

$14,450

Notify partners that will receive award

0.00

0.08

0.16

0.24

$ 12.14

0.00

0.50

132

31.68

$1,668

Subtotal

0.08

2.08

1.66

3.82

$ 254.19

0.00

66.00

132

504.24

$33,619

Program Evaluation

 

 

 

 

 

 

 

 

 

 

Review assessment research focus and questions

0.08

0.50

0.00

0.58

$ 56.70

0.00

0.00

132

76.56

$7,485

Process assessment and present results to internal audience

0.00

0.25

0.00

0.25

$ 23.84

0.00

0.00

132

33.00

$3,147

Subtotal

0.08

0.75

0.00

0.83

$ 80.55

0.00

0.00

132

109.56

$10,632

SmartWay Tractor-Trailer

 

 

 

 

 

 

 

 

 

 

Review Partner application submission

0.00

1.00

0.10

1.10

$ 98.20

0.00

0.00

22

24.20

$2,160

Send logo graphic files to Partner

0.00

0.50

0.00

0.50

$ 47.69

0.00

0.00

22

11.00

$1,049

Review and file license agreement

0.00

0.25

0.00

0.25

$ 23.84

0.00

0.00

16

4.00

$382

Send logo digital graphic files to partners

0.00

0.25

0.00

0.25

$ 23.84

0.00

0.00

16

4.00

$382

Subtotal

0.00

2.00

0.10

2.10

$ 152.99

0.00

54.60

76

35.20

$3,209.45

Totals

0.19

5.24

4.58

10.01

$ 624

$ -

$ 149

4,997.00

4,713.16

$ 124,192



1 Energy Policy Act of 2005, Public Law 109-58-756(b) at https://www.govinfo.gov/content/pkg/COMPS-10914/uslm/COMPS-10914.xml

2 Based on the Locality Pay Schedule for Detroit-Warren-Ann Arbor, MI, as most SmartWay staff are located at the National Vehicle and Fuesls Emissions laboratory in Ann Arbor, MI>, https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2023/general-schedule/

14



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