Document k6Q9g4JzwDzmRE54Xq6LoGGnO

DownloadSearchable PDFRandom document
* UNITED STATES ENVIRONMENTALP ROTECTIO. ANGEN CY REGION 9 SAN FRANCISCO, CA 94105 ENFORCEMENT & COMPLIANCE ASSURANCE DIVISION Alec Uyeno, Owner Jamo Performance Exhaust LLC 6957 Speedway Blvd Suite 104 Las Vegas, NV 89115 AlecUyeno @ Jamo Performance.com Sent Via Electronic Mail Return Receipt Requested Re: Request for Information Under Sections 114 (a) (1) and 208 (a) of the Clean Air Act, 42 U.S.C. 7414 (a) (1), 7542 (a) Dear Alec Uyeno: The United States Environmental Protection Agency (" EPA ") conducted an onsite inspection at Jamo Performance Exhaust LLC's facility on February 5, 2020, and September 11, 2023. EPA now hereby requires Jamo Performance Exhaust LLC and any of its parent organizations, affiliates, predecessors, successors, and assignees (" Jamo " or " you "), to submit certain information as part of an EPA investigation to determine Jamo's compliance with Section 203 of the Clean Air Act (" CAA "), 42 U.S.C. 7522, and the applicable regulations at 40 C.F.R. Parts 85, 86, and 1068. Examples of vehicles regulated under these Parts include, but are not limited to, light - duty gasoline and diesel trucks and vehicles. Appendix A provides definitions, Appendix B provides instructions for your responses to this request, and Appendix C specifies the information that you must submit. Appendix D provides a non - exhaustive list of products identified by EPA that Jamo must provide information on in its submission. Appendix E provides information about asserting a claim of confidentiality over information you provide in response 1 The CAA makes it a violation " for any person to manufacture or sell, or offer to sell, or install, any part or component intended for use with, or as part of, any motor vehicle or motor vehicle engine, where a principal effect of the part or component is to bypass, defeat, or render inoperative any device or element of design installed on or in a motor vehicle or motor vehicle engine in compliance with regulations under this subchapter, and where the person knows or should know that such part or component is being offered for sale or installed for such use or put to such use. " CAA 203 (a) (3) (B), 42 U.S.C. 7522 (a) (3) (B). It is also a violation to cause any of the foregoing acts. CAA 203 (a), 42 U.S.C. 7522 (a). to this Information Request. Appendix F contains the form with which you are required to certify the truth and completeness of your response. Appendix G is an Excel workbook provided by EPA to help you organize your responses to Requests 1 through 7. The EPA issues this Request for Information (" Information Request ") under Sections 114 (a) (1) and 208 (a) of the CAA, 42 U.S.C. 7414 (a) (1) and 7542 (a). Under Section 208 (a), the Administrator of the EPA may require any person who is subject to the CAA to provide information necessary to determine whether the person has acted in compliance with the CAA's requirements pertaining to vehicles and engines, and the regulations promulgated thereunder. Section 114 (a) (1) authorizes the Administrator to require any person subject to the CAA's requirements or who the Administrator believes may have information necessary for the purposes of carrying out the CAA, other than manufacturers regulated under Title II of the CAA with respect to a provision of Title II, to provide information reasonably required to carry out the CAA's provisions. The Administrator has delegated this authority to the undersigned Manager of Region 9's Air Enforcement Office, Enforcement and Compliance Assurance Division. You must submit this information to the EPA representatives listed below within thirty (30) calendar days from the date of this Request for Information. Please carefully review the instructions, definitions, and specific requests as you prepare your response. If you anticipate being unable to fully respond to this Request for Information by this date, you must contact the EPA representatives listed below via email, within ten (10) days of receipt of this Request for Information and, with an appropriate justification, request an extension of time to answer some or all of the requests below. If timely submitted, the EPA will review your request and may extend the time in which your response must be provided. Failure to provide the requested information may result in a civil action pursuant to Sections 113 (b) (2) and 205 (b) of the CAA, 42 U.S.C. 7413 (b) (2) and 7524 (b). Failure to provide all requested information in its entirety, and in the format requested, may result in additional inquiries and penalties. These inquiries may include additional written requests, inspections, or depositions as authorized by Sections 208, 114, and 307 of the CAA, 42 U.S.C. 7542 (a) - (b), 7414, 7607 (a). It is important that your responses be clear, accurate, organized, and complete. The EPA will regard any submitted information that is misleading, false, incomplete, or submitted without regard to its accuracy as a violation of the CAA and / or criminal statutes. You must submit all requested information under an authorized signature with the following certification (provided in Appendix F): I certify under penalty of law that I have examined and am familiar with the information in the enclosed documents, including all attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are, to the best of my knowledge and belief, true and complete. I am aware that there are significant penalties for knowingly submitting false 2 statements and information, including the possibility of fines or imprisonment pursuant to Section 113 (c) (2) of the Clean Air Act, 42 U.S.C. 7413 (c) (2), and 18 U.S.C. 1001 and 1341. You are entitled to assert a business confidentiality claim covering all or part of the information you submit in response to this Request for Information, in accordance with the procedures described in the Confidentiality of Business Information (" CBI ") regulations, 40 C.F.R. Part 2, Subpart B. However, no CBI claim may be made with respect to emissions data as defined at 40 C.F.R. 2.301 (a) (2). You must specify the page, paragraph, and sentence when identifying the information subject to your CBI claim. Appendix E of this Request for Information specifies the assertion requirements for business confidentiality claims. The EPA may, without further notice, provide the public with any information not subject to a CBI claim. The EPA may use any information submitted in response to this Request for Information in an administrative, civil, or criminal action. We would also like to take this opportunity to advise you that Jamo may qualify as a " small business " under the Small Business Regulatory Enforcement Fairness Act (" SBREFA "). EPA is providing you with a link to this Small Business Resources Information Sheet (https://www.epa.gov/compliance/small-business-resources-information-sheet) that is designed to provide information on compliance assistance to entities that may qualify as small businesses and inform them of their right to comment to the SBREFA Ombudsman concerning EPA's enforcement activities. Please be aware that SBREFA does not eliminate Jamo's responsibility to respond in a timely fashion to any complaint or information request that EPA may issue or other enforcement action that EPA may take, nor does SBREFA create any new rights or defenses under the law other than the right to comment to the SBREFA Ombudsman. EPA Region 9 is not accepting hard - copy documents for this information request. Please submit the requested information electronically. You may do so via email to Janice Chan, of my staff at chan.janice@epa.gov. Please note that the EPA email server will allow attachments up to 20 MB. Alternatively, you may want to provide documents in response to this Information Request way of a secure file transfer program (FTP) site. Please let us know how you want to proceed. Upon request to chan.janice@epa.gov, EPA can provide a secure link to an FTP site in order to submit responses to this Information Request. Any questions concerning this Information Request should be directed to Janice Chan at (415) 3 972-3308 or chan.janice@epa.gov or have your attorney contact Denise Leong in the Office of Regional Counsel at (415) 972-3409 or leong.denise@epa.gov. Enclosures Digitally signed by ROSHNI ROSHNI BRAHMBHATT Date: 2024.02.06 BRAHMBHATT 13:19:24 -08'00 ' Roshni Brahmbhatt, Manager Air Enforcement Office Enforcement and Compliance Assurance Division EPA Region 9- San Francisco 4 Appendix A Definitions All terms used in this Information Request will have their ordinary meaning unless such terms are defined below or in the CAA, 42 U.S.C. 7401 et seq., or applicable Regulations found at 40 C.F.R. Parts 85, 86, and 1068, in which case they shall have their meanings as defined therein. 1. The term " information " includes any written, recorded, or graphic matter of any nature whatsoever, regardless of how recorded, and whether original or copy, including but not limited to, the following: memoranda, reports, expense reports, books, manuals, instructions, financial reports, working papers, records, notes, letters, notices, confirmations, telegrams, receipts, appraisals, pamphlets, magazines, newspapers, prospectuses, interoffice and intraoffice communications, electronic mail (" email "), instant messages, calendars, contracts, cables, notations of any type of conversation, telephone call, meeting, or other communication, bulletins, printed matter, computer printouts, invoices, transcripts, diaries, analyses, returns, summaries, minutes, bills, accounts, estimates, projections, comparisons, messages, correspondence, press releases, circulars, financial statements, reviews, opinions, offers, studies and investigations, questionnaires and surveys, presentations, spreadsheets, and worksheets. The term " information " includes all drafts, preliminary versions, alterations, modifications, revisions, changes, and amendments to the foregoing, as well as any attachments or appendices thereto. The term " information " also includes any graphic or oral records or representations of any kind (including, without limitation, photographs, charts, graphs, voicemails, microfiche, microfilm, videotapes, recordings, and motion pictures), electronic and mechanical records or representations of any kind (including, without limitation, tapes, cassettes, disks, computer server files, computer hard drive files, CDs, DVDs, back - up tape, memory sticks, recordings, and removable computer media such as thumb drives, flash drives, memory cards, and external hard drives), and other written, printed, typed, or other graphic or recorded matter of any kind or nature, however produced or reproduced, and whether preserved in writing, film, tape, electronic format, disk, videotape or otherwise. Information bearing any notation not part of the original text is considered to be separate information. A draft or non- identical copy is separate information within the meaning of this term. 2. The term " entity " means any natural person, corporation, partnership, limited liability company, sole proprietorship, joint venture, or any formal or informal group, organization or association. 3. The term " person " includes an individual, corporation, partnership, or association. See Section 302 (e) of the CAA, 42 U.S.C. 7602 (e). 5 4. The term " you, "'your, " and " Jamo " means Jamo Performance Exhaust LLC, and any affiliates, predecessors, successors, and assignees. 5. The term " affiliated organization " means any organization or entity associated with another entity as an agent, parent organization, predecessor corporation, subsidiary organization, or any organization, or entity acting in lieu of another entity. 6. The term " applications " means all vehicle or engine configurations. 7. The term " emission related parts " means those parts installed for the specific purpose of controlling emissions, or those components, systems, or elements of design which must function properly to assure continued vehicle emission compliance, as defined in 40 C.F.R. 85.2102. 8. The term " element of design " means any control system (e.g., computer software, electronic control system, emission control system, computer logic), and / or control system calibrations, and / or the results of systems interaction, and / or hardware items on a motor vehicle or motor vehicle engine, as defined in 40 C.F.R. 86.094-2 and 86.1803-01. 9. The term " electronic control module " or " ECM " means a device that receives inputs from various sensors and outputs signals to control engine, vehicle, or equipment. functions. The ECM uses software programming including calculations and tables of information to provide the appropriate outputs. Multiple electronic control modules may be incorporated in a single unit to control various engine, vehicle, or equipment functions. ECM can be a generic term but may refer specifically to the engine control module when discussing emission controls on vehicles and engines. Examples of electronic control modules include, but are not limited to, the Engine Control Module, OBD Control Modules, Powertrain Control Module (" PCM "), Transmission Control Module (" TCM "), Body Control Module (" BCM ") and aftertreatment control module. 10. The term " EM product " means any device or product capable of accessing, altering, or replacing the software programming, calculations, computer logic, tables of information (e.g., fuel timing maps), coding, or other content or information stored within or used by an ECM. EM products include, but are not limited to, programmers, modules, tuners, ECM calibration tools, replacement ECMs, flash tools, or engine management products. 11. The term " engine tune, " " tune, " or " calibration " means any combination of software. programming, calculations, computer logic, tables of information (e.g., fuel timing. maps), coding, or other content or information, stored in any form, capable of affecting or controlling an ECM. 6 12. The term " product " includes any software code, software, hardware, program, element of design, calibration, engine tune, EM product, device, part, component, or kit. 13. The term " manufacture " includes the creation, design, development, alteration, fabrication, production, or programming of a software code, software, hardware, program, element of design, calibration, engine tune, EM product, engine tuner, device, part, or component. 14. The term " onboard diagnostics " or " OBD " means systems which monitor components ' emission - related systems, and assists repair technicians in diagnosing and fixing problems with those emission - related systems. If a problem is detected, an OBD system should record a Diagnostic Trouble Code (" DTC "), illuminate a Malfunction Indicator Light (" MIL ") or other warning lamp on the vehicle instrument panel, and / or provide information to the ECM which induces engine derate due to malfunctioning or missing emission - related systems. 15. The term " exhaust product " means exhaust components designed for use downstream from the exhaust port of a motor vehicle engine, and include, but are not limited to, EGR block plates, EGR delete kits, exhaust replacement pipes, and straight pipes. This term does not include ancillary exhaust components such as clamps, hangers, nuts, bolts, and gaskets that are not capable of impacting or replacing emission related parts. 16. The term " exhaust gas recirculation " or " EGR " means systems which redirect, usually by use of an EGR valve, a portion of engine exhaust back into the engine's combustion chamber to cool and reduce peak combustion temperatures and pressures, thereby reducing the production of nitrogen oxides (" NOX "). The EGR system may include an EGR cooler to cool the recirculated exhaust to further reduce the combustion temperature. 7 Appendix B Instructions for Responses 1. Provide a complete, detailed response, in English, to each Request in Appendix C below. 2. Appendix G consists of an Excel workbook in which you are requested to organize your responses to Requests 1 through 7. Please populate the workbook with your responses to Requests 1 through 7 in accordance with all instructions. Requests 1 through 7 are summarized in Appendix G for your convenience only. The Request summaries in Appendix G are not substitutes for the full text of the Requests in Appendix C. Please contact chan.janice@epa.gov if providing the responses in Excel format will be an issue. 3. Where a Request allows or requires documents to be provided in response, provide all documents electronically in a folder specific to that question or subpart and labeled accordingly. Provide copies of documents, not original documents. 4. When a response is provided in the form of a number, specify the units of measure. 5. Where documents or information necessary for a response is not in your possession, custody, or control, indicate in your response why such documents or information are not available or in your possession, custody, or control, and identify any source that either possesses or is likely to possess such information. 6. Where you have previously submitted information to the EPA that is responsive to any of the Requests set forth in Appendix C, re - submit that information in accordance with these instructions (Appendix B). Identify the material that was previously provided, the date on which it was provided, how the information was provided (e.g., electronically, fax, mail), and the individual at the EPA to whom it was provided. 7. If you assert any objections in responding to this Information Request, each objection must state with specificity the grounds for objecting to the request, including the reasons, and must state whether any responsive materials are being withheld on the basis of that objection. 8. This Request for Information is a continuing request. You must promptly supplement your response to any Request in Appendix C in the event you learn that you possess responsive information not yet produced or if you gain possession, custody, or control of responsive information after responding to this Information Request. 8 9. You must maintain an unaltered and complete copy of your website as it exists at the time this Information Request is received for a period of two years. This includes all pages, graphical elements, and text displayed on the website. You must provide this information in readable electronic format to EPA within ten days upon request. Electronic Submissions To aid in our electronic recordkeeping efforts, we request that you provide all documents responsive to this information request in an electronic format according to paragraphs 1 through 6, below. These submissions are in lieu of hard copy. 10. Provide all responsive documents in Portable Document Format (PDF) or similar format, unless otherwise requested in specific questions. If the PDFs are scanned images, perform at least Optical Character Recognition (OCR) for " image over text " to allow the document to be searchable. Submitters providing secured PDFs should also provide unsecured versions for EPA use in repurposing text. 11. When specific questions request data in electronic spreadsheet form, provide the data and corresponding information in an unlocked, editable Excel format, and not in image format. If Excel format is not available, then the format should allow for data to be used in calculations by a standard spreadsheet program such as Excel. EPA has provided an Excel workbook in Appendix G to organize your responses where applicable. 12. Provide submission to the secure web - link provided by EPA. 13. Provide a table of contents of all electronic documents submitted in response to our request so that each document can be accurately identified in relation to your response to a specific question. We recommend the use of electronic file folders organized by question number. 14. Documents claimed as confidential business information (CBI) must be submitted in separate file folders apart from the non - confidential information. This will facilitate appropriate records management and appropriate handling and protection of the CBI. Please follow the instructions in Appendix C for designating information as CBI. 15. Certify that the attached files have been scanned for viruses and indicate what program. was used. 9 Appendix C Information Request Jamo Performance Exhaust LLC (" Jamo " or " you ") must submit the following information to the United States Environmental Protection Agency pursuant to Sections 208 and 114 of the CAA, 42 U.S.C. 7542 and 7414, regarding the manufacture, sale, offer for sale, or installation of certain parts and products. Jamo must also submit information on the products identified in Appendix D, however, Jamo's submission is not limited to Appendix D. Provide the following information in Appendix G, worksheet 1. 1. Identify each EM product Jamo manufactured, sold, offered for sale, or installed during the period from January 1, 2020, through the date of this Information Request, in Appendix G, worksheet 1, and provide: a. Part Number, Item Code, or other unique identifier used by Jamo; Product name; c e b d.... Product manufacturer (if different); Identity of the product's applications by vehicle type, make, model, and year(s); Quantity Jamo sold during the period January 1, 2020, through the date of this Information Request; f. Average sale price; g. Indication whether you advertised this product and if so provide the electronic file names of each advertisement provided in response to Request No. 8d (if applicable); h. Indication whether the product affects or changes fuel delivery rate, timing of mixtures, diagnostics, turbo boost, or other engine parameters or calibrations. i. Description of how the product differs from the stock components it replaces or specifically changes the stock configuration. You may provide owner's or installation manuals for a product in lieu of a narrative description if you identify the electronic names of the files provided in response to Request No. 8d. j. Indication whether the product is sold with or without the following: i. Tunes; ii. Tunes from the EM product manufacturer; iii. Tunes manufactured by you; iv. Tunes manufactured by you sold without an EM product (i.e., calibration. file only); v. If no to i - iv, describe the product in detail. k. Indication whether the product includes a tune manufactured by you and if so provide the following: i. The software used to develop the tune; ii. The developer of the software; and iii. A list of compatible EM products. 10 I. Indication whether the product permanently or temporarily changes, affects, or bypasses a motor vehicle's emission related parts, including but not limited to the: i. EGR; ii. DPF iii. SCR; iv. catalyst; v. OBD; or vi. any sensors, signals, or records related to these systems; m. Indication whether the product modifies, interferes, or overrides the vehicles ' OBD system; n. Indication whether the product replaces or overwrites an ECM; o. Indication whether, together with the addition, modification, or removal of a motor vehicle's parts, the product has the effect to permanently or temporarily change, affect, bypass, defeat, or render inoperative a motor vehicle emission control device or emission related part; and p. Quantity Jamo installed during the period January 1, 2020, through the date of this Information Request. 2. For each product identified in response to Request 1, indicate in Appendix G, worksheet 1 whether: a. the product is capable of disabling the EGR without illuminating a MIL or prompting any on - board DTC; b. Jamo has sold a version of the product that, upon installation and without post- sale modification of the product, disables or allows the end user to disable the EGR without illuminating a MIL or prompting any DTC; c. the product is capable of disabling the EGR without any engine derating; d. Jamo has sold a version of the product that, upon installation and without post- sale modification of the product, disables or allows the end user to disable the EGR without any engine derating; e. the product is capable of allowing the removal of the EGR without illuminating a MIL or prompting any on - board DTC; f. Jamo has sold a version of the product that, upon installation and without post- sale modification of the product, allows the removal of the EGR without illuminating a MIL or prompting any DTC; g. the product is capable of allowing the removal of the EGR without any engine derating; h. Jamo has sold a version of the product that, upon installation and without post- sale modification of the product, allows the removal of the EGR without any engine derating; i. the product is capable of allowing removal of a DPF without illuminating a MIL or prompting any DTC; j. Jamo has sold a version of the product that, upon installation and without post- 11 sale modification of the product, allows the removal of the DPF without illuminating a MIL or prompting any DTC; k. the product is capable of allowing removal of a DPF without any engine derating; I. Jamo has sold a version of the product that, upon installation and without post- sale modification of the product, allows removal of a DPF without any engine derating; m. the product is capable of disabling or allowing removal of a SCR system without illuminating a MIL or prompting any DTC; n. Jamo has sold a version of the product that, upon installation and without post- sale modification of the product, allows removal of a SCR system without illuminating a MIL or prompting any DTC; o. the product is capable of allowing removal of a SCR system without any engine derating; p. Jamo has sold a version of the product that, upon installation and without post- sale modification of the product, allows removal of a SCR system without any engine derating; q. the product is capable of allowing removal of a catalyst without illuminating a MIL or prompting any DTC; Jamo has sold a version of the product that, upon installation and without post- sale modification of the product, allows removal of a catalyst without illuminating a MIL or prompting any DTC; s. the product is capable of allowing removal of a catalyst without any engine derating; t. Jamo has sold a version of the product that, upon installation and without post- sale modification of the product, allows removal of a catalyst without any engine derating; u. Jamo has sold a version of the product that, upon installation and without post- sale modification of the product, alters fuel timing maps within engine electronic calibrations; v. the product is capable of bypassing or altering parameters to prevent DTCs or MILs from being recorded or illuminated; and w. Jamo has sold a version of the product that, upon installation and without post- sale modification of the product, prevents DTCs or MILs from being recorded or illuminated. 3. For each product identified in response to Request 1 which Jamo sold during the period January 1, 2020, through the date of this Information Request, provide all sales information using the format provided in Appendix G, worksheet 2. Jamo may provide the requested information in a spreadsheet exported from an invoice management program such as QuickBooks in lieu of using Appendix G, worksheet 2. 4. Identify each exhaust product, including any kit, Jamo manufactured, sold, offered for 2 Including but not limited to the identified products in Appendix D. 12 sale, or installed during the period from January 1, 2020, through the date of this Information Request, in Appendix G, worksheet 3, and provide: a. Part Number, Item Code, or other unique identifier used by Jamo; Product name; c e b d.... Product manufacturer (if different); Identity of the product's applications by vehicle type, make, model, and year(s); Quantity Jamo sold during the period January 1, 2020, through the date of this Information Request; f. Average sale price; g. Indication whether you have advertised this product and provide electronic file names of each advertisement provided in response to Request No. 8b (if applicable); h. Description of how the product differs from the stock components it replaces or specifically changes the stock configuration. You may provide owner's or installation manuals for a product in lieu of a narrative description if you identify the electronic names of the files provided in response to Request No. 8d. i. Indication whether the product permanently or temporarily changes, affects, or bypasses a motor vehicle's emission related parts, including but not limited to the: i. EGR; ii. DPF; iii. SCR; iv. Catalyst; v. OBD; or vi. any sensors, signals, or records related to these systems; and j. Indication whether, together with the addition, modification, or removal of a motor vehicle's parts, the product has the effect to permanently or temporarily change, affect, bypass, defeat, or render inoperative a motor vehicle emission control device or emission related part. k. Quantity Jamo installed during the period January 1, 2020, through the date of this Information Request. 5. For each product identified in response to Request 1 which Jamo sold during the period. January 1, 2020, through the date of this Information Request, provide all sales information using the format provided in Appendix G, worksheet 4. Jamo may provide the requested information in a spreadsheet exported from an invoice management program such as QuickBooks in lieu of using Appendix G, worksheet 4. Provide the following information in Appendix G, worksheet 5. 6. For products identified in response to Requests 1 and 4, state whether Jamo or any other entity conducted tests measuring emissions of hydrocarbons, carbon monoxide, nitrogen oxides, or particulate matter, including tests that measure the impact of the 13 product on motor vehicle emissions or that measure the impact of the product on a vehicle's emission control devices or elements of design. For each such test, provide the following information: a. a description of the test, including identification of the product and vehicle, the EPA engine family, name of the vehicle, test equipment, test protocols, and calibration procedures; b. any training or instructional materials used for educating employees and affiliates about how to perform the test; and c. the date and location of the test, the name and position of the person that conducted the test, and the test results. 7. For products that are identified in response to Requests 1 and 4: a. State whether Jamo or any other entity submitted an application for an Executive Order to the California Air Resources Board; i. if so, provide a copy of the application for each product. b. State whether each product received an Executive Order exempting the product from California's emission control system anti - tampering law, California Vehicle Code 27156. If the product received an Executive Order, provide the Executive Order number; and d. If the product received an Executive Order, state whether the California Air Resources Board required changes to the product or application to receive approval. Provide the following information. 8. For each product identified in response to Requests 1 and 4: a. provide a detailed written description of all methods by which the product has been promoted or publicized by Jamo, including but not limited to, print media, commercial websites, point - of - sale webpages, event promotion or sponsorship, trade show promotion, or social media promotion, including promotion dates and / or date ranges, if applicable; b. provide copies of all advertisements for the product published in print or electronic media, including commercial websites, point - of - sale webpages, or social media; c. provide a list of other entities known to have advertised the product; and d. provide all manuals available (e.g., owner's and installation). 9. Provide a detailed, written description of Jamo's business structure including ownership, corporate form, parent and / or subsidiary companies, and affiliated organizations. 10. Provide the location of all warehouses or storage facilities where Jamo stores products. 14 11. Identify each person responsible for responding to this Information Request, including his or her title, and the Request(s) to which he or she responded. 15 Appendix D Products Identified by EPA to Include in Response Product Part # Number AC003RPL 1 AC003RPS 2 AC004RP 3 Product Name or Description (if any) 2007.5-2010 4IN GM ALUMINIZED COMPETITION RACE PIPE LONG BED (WITH GASKESTS AND BOLT) 2007.5-2010 4IN GM ALUMINIZED COMPETITON RACE PIPE SHORT BED (WITH GASKESTS AND BOLT) 2011-2015 4IN GM ALUMINIZED COMPETITION RACE PIPE (FRONT AND MID SECTION WITH CLAMPS) AC005RP 4 AC006RP 5 2015.5+ 4IN GM ALUMINIZED COMPETITION RACE PIPE (FRONT AND MID SECTION WITH CLAMPS) 2017+ 4IN GM ALUMINIZED COMPETITION RACE PIPE (FRONT AND MID SECTION WITH CLAMPS) AD004RP 6 2007.5-2017 4IN DODGE ALUMINIZED COMPETITION RACE PIPE (DOWNPIPE AND MID SECTION WITH CLAMPS) AD503TB - MD2004.5-2007 Dodge 5.9L Cummins 5 " Race Exhaust No Muffler No Tip 7 AF004RP 8 00 2008-2010 4IN FORD ALUMINIZED COMPETITION RACE PIPE (FRONT AND MID SECTION WITH GASKETS) AF005RP 9 2011+ 4IN FORD ALUMINIZED COMPETITION RACE PIPE (FRONT AND MID SECTION WITH GASKETS) AF504DB - MD 2008-2010 Ford 6.5L Powerstroke 5IN Race Exhaust No Muffler No 10 Tip AF505DB - MD2011-2016 Ford Powerstroke 5IN Race Exhaust No Muffler No Tip 11 C003RPL 12 DURAMAX 2007.5-2010 LONG BED COMPETITION RACE PIPE (WITH GASKETS AND BOLTS) C003RPS 13 DURAMAX 2007.5-2010 SHORT BED COMPETITION RACE PIPE (WITH GASKESTS AND BOLTS) 16 Product Part # Number Product Name or Description (if any) C004RP DURAMAX 2011-2015 COMPETITION RACE PIPE (FRONT & MID 14SECTION WITH CLAMPS) 15 C005DBJAMO 15.5+ GM 4in Race Exhaust with Muffler 16 C005DB - MD2015.5+ GM 4in Race Exhaust No Muffler C005RP DURAMAX 2015-2016 COMPETITION RACE PIPE 3 BOLT FLANGE 17(FRONT & MID SECTION WITH CLAMPS) 18 C503DB - MD2007.5-2010 GM 5in Race Exhaust No Muffler 19 C504DB2011-2015 GM 5in Race Exhaust with Muffler (V-band Style) 20 C504DB - MD2011-2015 GM 5in Race Exhaust No Muffler (V-band flange) 21 C505DB2015.5+ GM 5in Race Exhaust with Muffler (3 bolt flange) 22 C505DB - MD2015.5+ GM 5in Race Exhaust No Muffler Kit (3 bolt flange) 23 D002TB2003-2004 Dodge 4in Race Exhaust with Muffler 24 D002TB - MD2003-2004 Dodge 4in Race Exhaust No Muffler 25 D003TB2004.5-2007 Dodge 4in Race Exhaust with Muffler 26 D003TB - MD2004.5-2007 Dodge 4in Race Exhaust No Muffler D004RP 27 CUMMINS 2007.5-2019 COMPETITION RACE PIPE (DOWNPIPE & MID SECTION WITH CLAMPS) 28 D004TB2007.5-2009 Dodge 4in Race Exhaust with Muffler 29 D004TB - MD2007.5-2009 Dodge 4in Race Exhaust No Muffler D005TB2010-2012 Dodge Cummins 4in Race Exhaust with Muffler 30 D005TB - MD2010-2012 Dodge Cummins 4in Race Exhaust No Muffler 31 32 D006TB2013-2017 Dodge 4in Race Exhaust with Muffler D006TB - MD2013-2017 Dodge Cummins 4in Race Exhaust No Muffler 33 34 D502TB2003-2004 Dodge 5in Race Exhaust with Muffler 17 Product Part # Number Product Name or Description (if any) 35 D502TB - MD2003-2004 Dodge 5in Race Exhaust No Muffler 36 D503TB2004.5-2007 Dodge 5in Race Exhaust with Muffler 37 D503TB - MD2004.5-2007 Dodge 5in Race Exhaust No Muffler 38 D504TB2007.5-2009 Dodge 6.7L Cummins 5 " Race Exhaust w / Muffler 39 D504TB - MD2007.5-2009 Dodge 5in Race Exhaust No Muffler 40 D505TB2010-2012 Dodge 5in Race Exhaust with Muffler 41 D505TB - MD2010-2012 Dodge 5 " Race Exhaust No Muffler 42 D506TB2013-2017 Dodge 5in Race Exhaust with Muffler 43 D506TB - MD2013-2017 Dodge 5in Race Exhaust No Muffler 44 F003TB2003.5-2007 Ford 4in Race Exhaust with Muffler 45 F003TB - MD2003.5-2007 Ford 4in Race Exhaust No Muffler 46 F004DB2008-2010 Ford 4in Race Exhaust with Muffler 47 F004DB - MD2008-2010 Ford 4in Race Exhaust No Muffler F004RPPOWERSTROKE 2008-2010 COMPETITION RACE PIPE 48 49 F005DB2011-2017 Ford 4in Race Exhaust with Muffler 50 F005DB - MD2011-2017 Ford 4in Race Exhaust No Muffler F005RP2011+ Ford Powerstroke Race Pipe 51 52 F503TB2003.5-2007 Ford 5in Race Exhaust with Muffler 53 F503TB - MD2003.5-2007 Ford 5in Race Exhaust No Muffler 18 Product Part # Number Product Name or Description (if any) 54 F504DB2008-2010 Ford 5in Race Exhaust with Muffler 55 F504DB - MD2008-2010 Ford 5in Race Exhaust No Muffler 56 F505DB2011-2017 Ford 5in Race Exhaust with Muffler 57 F505DB - MD2011-2017 Ford 5in Race Exhaust No Muffler 19 Appendix E Confidential Business Information An entity may assert a business confidentiality claim covering all or part of the information. provided in response to this Information Request for any business information entitled to confidential treatment under Section 208 (c) of the CAA, 42 U.S.C. 7542, and 40 C.F.R. Part 2, subpart B. Under Section 208 (c) of the CAA, entities are entitled to confidential treatment of information that would divulge methods or processes entitled to protection as trade secrets. Under 40 C.F.R. Part 2, subpart B, business confidentiality means " the concept of trade secrecy and other related legal concepts which give (or may give) a business the right to preserve the confidentiality of business information and to limit its use or disclosure by others in order that the business may obtain or retain business advantages it derives from its rights in the information. " 40 C.F.R. 2.201 (e). Information covered by a claim of business confidentiality will be disclosed by the EPA only to the extent, and by means of the procedures, set forth in Section 208 (c) of the CAA and 40 C.F.R. Part 2, subpart B. If no such business confidentiality claim accompanies the response to this Information Request when it is received by EPA, then such information may be made available to the public without further notice. See 40 C.F.R. 2.204 (a) (3). Pursuant to 40 C.F.R. 2.301 (h), the EPA possesses the authority to disclose to any authorized representative of the United States information which might otherwise be entitled to confidential treatment. To assist in its review and analysis, the EPA may disclose information provided in response to this and other information requests to an EPA contractor, the Eastern Research Group, under contract number 68HERH19C0004. See 84 Fed. Reg. 8859, 59-60 (Mar. 12, 2019). To assert a business confidentiality claim, an entity must place on (or attach to) all information subject to the claim either a cover sheet, stamped or typed legend, or other suitable form of notice employing language such as " trade secret, " " proprietary, " or " company confidential " at the time it provides its response to this Information Request. Allegedly confidential portions of otherwise non - confidential documents should be clearly identified, and may be provided separately to facilitate identification and handling by the EPA. An entity should indicate whether confidential treatment is only required until a certain date or until the occurrence of a certain event. The criteria the EPA will use in determining whether material claimed as business confidential is entitled to confidential treatment are set forth at 40 C.F.R. 2.208 (a) - (d) and 2.301. Emission data, as defined at 40 C.F.R. 2.301 (a) (2), is expressly not entitled to confidential treatment under 40 C.F.R. Part 2, subpart B. See 42 U.S.C. 7542 (c); 40 C.F.R. 2.301 (e). 20 Appendix F Statement of Certification You are submitting the enclosed documents in response to the U.S. Environmental Protection Agency's (" EPA ") Information Request, issued pursuant to Section 208 (a) of the Clean Air Act, to determine compliance with the Clean Air Act and its affiliated regulations. I certify that I am fully authorized by provide the above information on its behalf to EPA. [corporate affiliation] to I certify under penalty of law that I have examined and am familiar with the information in the enclosed documents, including all attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the information, I certify that the statements and information are, to the best of my knowledge and belief, true and complete. I am aware that there are significant penalties for knowingly submitting false statements and information, including the possibility of fines or imprisonment pursuant to Section 113 (c) (2) of the Clean Air Act, 42 U.S.C. 7413 (c) (2), and 18 U.S.C. 1001 and 1341. Date: Name (Printed): Signature: Title: