SUPPORTING STATEMENT FOR

INFORMATION COLLECTION REQUEST NUMBER 2050-0139

“REPORTING AND RECORD KEEPING REQUIREMENTS UNDER

EPA’S WASTEWISE PROGRAM”

 

June 3, 2011
TABLE OF CONTENTS

1. IDENTIFICATION OF THE INFORMATION COLLECTION REQUEST

1(a) Title and Number of the Information Collection Request 4

1(b) Short Characterization 4

1(c) Existing Terms of Clearance 7

1(d) EPA Actions to Comply with Terms of Clearance 8

(i) WasteWise Program Evaluation 8

(ii) Discussion Paper on Attribution 8

(iii) Response rates and descriptive statistics 9

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection 9

2(b) Practical Utility/Users of the Data 10

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non-duplication 11

3(b) Public Notice Required Prior to ICR Submission to OMB 11

3(c) Consultations 11

3(d) Effects of Less Frequent Collection 12

3(e) General Guidelines 12

3(f) Confidentiality 12

3(g) Sensitive Questions 12

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes 13

4(b) Information Requested 13

(i) Partner Registration Form 13

(ii) Partner Annual Assessment Form 14

(iii) Endorser Registration Form 14

(iv) Endorser Annual Assessment Form 15

(v) New Contact Form 16

5. THE INFORMATION COLLECTED — AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities 17

(i) Partner Registration Form 17

(ii) Partner Annual Assessment Form 17

(iii) Endorser Registration Form 18

(iv) Endorser Annual Assessment Form 18

(v) New Contact Form 19

5(b) Collection Methodology and Management 19

5(c) Small Entity Flexibility 19

5(d) Collection Schedule 20

6. ESTIMATING THE BURDEN AND COST OF COLLECTION

6(a) Estimating Respondent Burden 20

6(b) Estimating Respondent Costs 21

6(c) Estimating Agency Burden and Costs 26

6(d) Estimating the Respondent Universe and Total Burden and Costs 28

6(e) Bottom Line Burden Hours and Costs 28

6(f) Reasons for Change in Burden 29

6(g) Burden Statement 29
7. POTENTIAL FUTURE WASTEWISE INITIATIVES

7(a) WasteWise Challenges – Targeting Selective Materials 30

7(b) Requirements for Organizations Participating in Challenges 31

7(c) Estimating Burden and Costs for Organizations Participating in Challenges 31

7(d) Estimating Agency Burden and Costs for Challenges 33

TABLES

Table 1: WasteWise Membership 21

Table 2: Hourly Labor Rates – Private Sector 21

Table 3: Local, State and Federal Labor Rates 22

Table 4: Annual Estimated Respondent Burden and Cost – Private Sector Respondents 23

Table 5: Annual Estimated Respondent Burden and Cost – State/Local Respondents 24

Table 6: Annual Estimated Respondent Burden and Cost – Federal Respondents 25

Table 7: Agency Labor Rates 26

Table 8: Annual Estimated Agency Burden and Cost 27

Table 9: Bottom Line Burden and Cost to Respondents 28

Table 10: Bottom Line Burden and Cost to EPA 29

Table 11: Annual Estimated Burden for Challenge Respondents for a Single Challenge 32

Table 12: Annual Estimated Agency Burden and Cost for a Single Challenge 33

ATTACHMENTS

Attachment A: ICR Renewal Terms and Clearance. Office of Management and Budget, Control Number 

2050-0139, June 24, 2008.

Attachment B: Evaluation of the WasteWise Program: Promoting Environmental Results through 

Evaluation. EPA Office of Policy, Economics, and Innovation, July 2010.

Attachment C: Attributing Benefits to Voluntary Programs in EPA’s Office of Resource Conservation 

and Recovery: Challenges and Options. James Boyd and Cynthia Manson, Resources for 

the Future, March 2011.

Attachment D: Response Rates and Descriptive Statistics for WasteWise Program

Attachment E: Partner Registration Form

Attachment: F-JPartner Annual Assessment Form

 Attachment F: Waste Prevention and Recycling

 Attachment G: Municipal Solid Waste Disposed Data

 Attachment H: Buy-Manufactured Recycled Products

 Attachment I: Cost Savings-Revenue

 Attachment J: Comments

Attachment K: New Contact Form

Attachment L: Endorser Registration Form

Attachment M: Endorser Annual Assessment Form

Attachment N: Sample WasteWise Challenge Registration Forms

Attachment O: Partnership Agreement Form

Attachment P: Endorser Agreement Form
4

1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title and Number of the Information Collection Request

This Information Collection Request (ICR) is entitled “EPA’s WasteWise Program,” 

EPA ICR No. 1698.09, OMB Control No. 2050-0139.

1(b) Short Characterization

This submission is intended to request renewal of an ICR for EPA’s WasteWise Program, 

as described in this document. EPA’s existing ICR was approved in 2008, with Terms of 

Clearance, for a three year period. The existing ICR expires on June 30, 2011. EPA’s 

efforts to comply with the Terms of Clearance are discussed below.

Overview

The WasteWise program is an EPA partnership program that encourages companies, nonprofit organizations, state/local/tribal/federal governments, schools, colleges, and 

universities to engage in waste reduction activities. WasteWise activities focus on waste 

prevention, recycling collection, and purchasing or manufacturing recycled-content 

products. The program was developed and is managed by EPA’s Office of Resource 

Conservation and Recovery (ORCR), Resource Conservation and Sustainability Division 

(RCSD). 

WasteWise began in 1994 and since then has helped more than 3,000 organizations, 

including small, medium, and large businesses; local, state, and federal governments; and 

other public and private sector organizations plan, develop, and implement cutting-edge 

waste reduction programs and measure their results. It was one of the first programs 

developed to specifically focus on waste prevention and recycling as a way to bring about 

waste reduction and provide environmental benefits, while at the same time reducing 

overall costs. The program provides one-on-one technical assistance, tools, and resources 

to assist member organizations in designing waste reduction programs that are flexible, 

yet tailored to their individual needs. WasteWise offers a program-specific on-line webbased data management and reporting system to track and report partner progress in the 

program. It also uses EPA’s Waste Reduction Model (WaRM) to quantify the 

environmental benefits of partner actions in the program. Mentoring opportunities are 

also available to allow like-sector organizations the benefit of implementing waste 

reduction program elements that are proven to work. 

The WasteWise program is viewed nationally, as well as internationally, as a model 

program to help organizations bring about waste reduction in a cost-effective manner. 

Many states promote the use of WasteWise to help organizations in their state achieve 

greater waste reduction. Over the years, several international government agencies have 

consulted with EPA and tailored their national partnership programs after the WasteWise 

model. It has become apparent over the years that the WasteWise program provides a 

cadre of resources and technical assistance that are unique in promoting waste reduction 

and obtaining measurable results. 

In return for their participation in the program, active WasteWise Partners and Endorsers 

receive:

 A well-developed approach to program design, implementation, and documentation 

of results that can be implemented within a variety of organizations;

 Recognition opportunities through annual awards and being featured on the 

WasteWise Web site and other WasteWise publications;
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 Opportunities to network with individuals implementing waste reduction activities in 

a variety of industry sectors;

 Access to an online data management and reporting system to facilitate internal 

tracking and allow for better waste management; 

 Helpline, program representative, and list server services that assist with the 

identification of waste reduction opportunities, setting measurable goals, and 

researching technical questions;

 Access to a library and Web site of technical assistance resources to assist in 

achieving waste reduction goals; and

 A climate benefits profile which provides a summary of the amount of equivalent 

greenhouse gas (ghg) reductions that results from a partner’s waste prevention and 

recycling efforts. 

During 2011, EPA transitioned its municipal solid waste management focus to promote 

sustainable materials management (SMM). SMM is a life-cycle approach to resource 

conservation and waste prevention and management. Its purpose is to eliminate waste 

throughout the life of materials use – from extraction through intended use, ultimately 

reducing the amount of materials used; wastes generated; and associated environmental 

impacts. EPA plans to target specific waste streams and sectors in transitioning to its 

SMM focus and the WasteWise tools; technical assistance; and data management and 

reporting system will be an integral part of this overall effort. Data collected as part of 

the SMM initiatives will be obtained through the existing WasteWise data management 

system. Data collection forms will be provided to OMB for approval and will include 

cost burden estimates. Section 7 of this ICR provides more details of how EPA plans to 

use key WasteWise program elements as a tool for promoting SMM. 

WasteWise Partners

Partner participation begins when an organization submits an online Partner 

Registration Form (Attachment E) that provides general information. Partners submit a 

Partnership Agreement Form committing them to identify specific goals, make 

continuous improvements, and report data in order to remain an active Partner in the 

program (Attachment O). Organizations that fulfill their partnership commitments are 

considered active partners and receive benefits including access to the online data 

management system, name in the Partner listing on the WasteWise Web site, and ability 

to use the WasteWise logo. Organizations that do not meet their commitments have their 

access to the online data management system revoked, name removed from the Partner 

listing on the WasteWise Web site, and are not allowed to use the WasteWise logo. 

Partners can establish reporting protocols as a single entity or include multiple reporting 

sites within their organization. Partners are allowed up to two months to provide baseline 

data and self-identified goals in the areas of waste prevention; recycling; buy-recycled 

and/or manufacturing products with recycled content via the Partner Annual 

Assessment Form (Attachments F-J). Partners can add additional users to their online

account by submitting a New Contact Form (Attachment K). The first year of 

membership is the only time during which partners are asked to submit baseline data. 

Partners use the same annual assessment form to submit annual data for every year that 

they are active in the WasteWise Program. By comparing the baseline data to subsequent 

annual data, EPA is able to determine a partner’s waste reduction achievements over 

time.

The WasteWise program currently has 568 active partners (as of April 1, 2011). EPA

expects WasteWise membership to increase by 76 active partners during each year of this 

ICR. While there is no cost to join as a WasteWise Partner, the information collection 

activities are estimated on average to cost each partner organization approximately 
6

$2,706 the first year they are in the program and $2,631 each subsequent year. However, 

EPA also expects that for many of the organizations, these costs will be off-set to realize 

substantial cost savings through implementation of their waste reduction initiatives 

reported under WasteWise. In fact, information provided to the Agency shows that 

savings of hundreds of thousands, or even millions, of dollars is common for a large 

corporation, while even for small companies, significant savings can be realized.

WasteWise Endorsers

WasteWise also includes another component called the WasteWise Endorser Program. 

Various organizations, including non-profit organizations, and federal, state, and local 

governments, become WasteWise Endorsers and commit to recruiting their members and 

other constituents to become WasteWise Partners. Many WasteWise Endorsers go on to 

provide ongoing promotional and/or technical waste reduction information. 

Joining the WasteWise Endorser Program involves submitting the online Endorser 

Registration Form (Attachment L), which provides general contact information, the 

number of business members the organization has, the primary business sectors 

represented, and the activities that the endorser will conduct. This form and all 

information submitted are housed in Re-TRAC (see below). Endorsers can add 

additional users to their online account by submitting a New Contact Form (Attachment 

K). A a new requirement for the Endorser Program starting in 2011, will be for 

Endorsers to submit an Endorser Agreement Form (Attachment P) which commits 

them to identify specific goals and actions they plan to take in the following year. 

WasteWise will also require Endorsers to submit an Endorser Annual Assessment 

Form (Attachment M) by March 31 each year, reporting their promotional, outreach, and 

other endorser-related efforts (first submissions will be March 31, 2012). Organizations 

that fulfill their Endorser commitments are considered active Endorsers and receive 

benefits including access to the online data management system, name in the Endorser 

listing on the WasteWise Web site, and ability to use the WasteWise logo. Organizations 

that do not meet their commitments have their access to the online data management 

system revoked, name removed from the Endorser listing on the WasteWise Web site, 

and are not allowed to use the WasteWise logo. 

EPA will track the information from the Endorser forms to establish participation in the 

program, understand the activities being undertaken by each endorser, and identify 

opportunities to assist them in their efforts (e.g., providing materials and/or a speaker). 

Some WasteWise Partners may also choose to enroll in the program as Endorsers. In 

these instances, the organization must submit separate registration forms, agreement 

forms, and all related reporting forms required for both Partners and Endorsers. 

The WasteWise Endorser Program currently has 86 active endorsers (as of April 1, 

2011). EPA expects membership in the WasteWise Endorser Program to increase by 11 

active endorsers during each year of this ICR. While there is no cost to join as a 

WasteWise Endorser, the information collection activities are estimated on average to 

cost each endorser organization approximately $593 in their first year in the program and 

$375 each subsequent year. While Endorsers are unlikely to realize cost savings from 

their WasteWise activities, Partners that join the program as a result of WasteWise 

Endorser activities are expected to realize substantial cost savings.

The WasteWise Program also allows Endorsers who have members to create a 

WasteWise Affiliate Network. Through the affiliate network, Endorsers can use 

WasteWise to track their members’ progress in their organization’s waste reduction 

initiatives. Affiliate organizations’ members join WasteWise as Partners and the Endorser 
7

is then given access to the member organizations reported data. This allows the Endorser 

to better organize its members’ waste reductions efforts. 

WasteWise Re-TRAC

In 2008, EPA began developing a customized portal in Re-TRAC, an existing waste 

management database, for the WasteWise program after identifying a need to streamline 

data collection, efficiently report on the program, and provide additional support for the 

Waste Wise Partners. The system has been completed and since 2010, EPA has collected 

and stored WasteWise Partner and Endorser information in the online data management 

and reporting system. EPA uses the information collected under the WasteWise program 

to track the activities of individual organizations participating in the program, recognize 

partner accomplishments, and identify effective waste reduction strategies to share with 

the other organizations. Approved paper information collection forms were translated 

into a user-friendly online format. For example, the online system walks WasteWise 

Partners through the Partner Annual Assessment Form page-by-page until all of the data

is entered. Also, users are able to select from convenient drop-down menus that are 

populated with the most commonly observed data and “other” options as needed (e.g. 

most commonly recycled materials). Users can access Re-TRAC at no charge at their 

convenience, save information and return to it later, and add additional contacts using the 

New Contact Form.

In addition to collecting information from WasteWise Partners and Endorsers, Re-TRAC 

also provides members with internal tracking and customized reporting functions. EPA 

headquarters and regional offices have various reporting functions as well for improved 

program management.

1(c) Existing Terms of Clearance

EPA received ICR renewal approval for the WasteWise Program on June 24, 2008 (ICR 

reference Number 2007007-2050-001). This approval expires on June 30, 2011. A copy 

of this approval is included as Attachment A. Under the ICR’s Terms of Clearance, EPA 

was required to evaluate the Program and develop a statistical methodology that could 

quantify the Program’s impact on partner behavior using randomized control trials 

(RCTs), subject the methodology to peer review, incorporate peer review comments, and 

include the methodology with this ICR renewal. Specifically the Terms required the 

methodology to address the following issues: appropriate baseline; appropriate entity 

boundaries for reporting; conditions for self-selection bias; and low response rates from 

the partners and low item response rates from the partners. EPA was also asked to 

provide the following information: overall response rates from the participants; item nonresponse rates for each question in Section II of the approved Registration Form and 

Sections II through IV in the approved Assessment Form; descriptive statistics 

(including, but not limited to, mean, median, and mode) of the responses for each

question in Section II of the approved Registration Form and Sections II through IV in 

the approved Assessment Form.
8

1(d) EPA Actions to Comply with Terms of Clearance

After the 2008 ICR approval, EPA conducted two research projects in an effort to 

evaluate the use of RCTs and other econometric approaches for the WasteWise Program.

The results of these efforts are discussed below.

(i) WasteWise Program Evaluation

EPA’s Office of Policy (OP) and the Office of Resource Conservation and Recovery 

(ORCR) commissioned a study of the WasteWise Program under OP’s Program 

Evaluation Competition. The findings were published in July of 2010. The evaluation 

examined the WasteWise Program in the context of OMB’s Terms of Clearance requiring 

the development and submission of a peer-reviewed econometric-based methodology for 

assessing the Program’s impact on partner behavior. In general, the Evaluation found that 

RCTs and other econometric approaches are unlikely to be either practical or robust for 

partnership programs, due to data limitations and the complexity of the program 

interventions that make it difficult to isolate a control group. Specifically, the Program 

Evaluation found that:

 RCTs and other statistical methodologies that compare participants to nonparticipants do not appear to be feasible or theoretically valid approaches for 

estimating the benefits of partnership programs. These methods are problematic 

due to the extensive resources required and confounding impact of program 

designs that emphasize dissemination of information to non-participants; 

 The literature suggests that links exist between certain external factors and the 

decision by firms to enter partnerships programs, but the specific impact of these 

factors is difficult to predict. Input from partners in literature reviews, 

evaluations, and case studies suggest that partnership programs may in some 

cases be complementary with existing strategies. In these cases, the programs 

may not be the root cause of new behaviors in organizations, but may help 

advance or broaden the adoption of new behaviors in non-linear ways. This 

further complicates efforts to isolate ‘program” impacts, even when it appears 

that program participation has provided significant value; and

 Limited available data and the limited applicability of RCT methods suggest that 

robust trend analysis considering behavioral changes over time among 

participants may be the most tractable methods for estimating program impacts.

The full results of this evaluation are included as Attachment B.

(ii) Discussion Paper on Attribution

EPA obtained the services of Resources for the Future (RFF) to analyze the challenges 

and options of attributing benefits to partnership programs. The result of that effort was a 

discussion paper entitled, Attributing Benefits to Voluntary Program’s in EPA’s Office of 

Resource Conservation and Recovery (March 2011).

Like the WasteWise Program Evaluation, the RFF study concluded that specific features 

of partnership programs make it difficult, and often impractical, to use full scale 

statistical analysis (like RCTs) to assess the direct influence of programs on partner 

behavior. Specifically, the paper identifies the following obstacles as reasons why 

quantifying direct causality can be difficult: sample bias; breadth of confounding factors; 

non-uniform interventions and outcomes; ambiguous intervention events; and spillover 

effects.
9

The discussion paper and all results are included as Attachment C.

(iii) Response Rates and Descriptive Statistics

The 2008 Terms of Clearance also required EPA to submit various response rate statistics 

for the three year duration of the ICR. Specifically, the Terms of Clearance requested:

 Overall response rate from WasteWise participants;

 Non-response rates for specific questions in the Registration and Annual 

Assessment forms; and

 Descriptive statistics (including, but not limited to mean, median, and mode) of 

the responses to specific questions in the Registration and Annual Assessment 

Forms.

EPA has compiled and evaluated all partner reporting activities and reported data from 

2008 through 2010. EPA has included this statistical information in Attachment D.

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection

As stated by Congress (42 U.S.C. #13101-13103. 1990) and EPA (The Solid Waste 

Dilemma: An Agenda for Action. 1989 530-SW-89-019. pp. 16-21), there are significant 

opportunities for businesses to reduce or prevent pollution at the source through costeffective changes in production, operation, and raw material use. The Agency has 

developed a hierarchy asserting that waste should be prevented or reduced at the source 

whenever feasible and waste that cannot be prevented should be recycled where possible. 

The Resource Conservation and Recovery Act (RCRA) directs EPA to “...promote the 

protection of human health and the environment and to conserve valuable materials and 

energy resources ...”(42 section 6902(a)) and “...promote the demonstration, 

construction, and application of solid waste management, resource recovery, and resource 

conservation systems which preserve and enhance the quality of air, water, and land 

resources ...”(42 section 6902(a)(10)). In addition, “The Congress finds that (1) 

significant savings could be realized by conserving materials in order to reduce the 

volume or quantity of material which ultimately becomes wastes: (2) solid waste contains 

valuable energy and material resources which can be recovered and used thereby 

conserving increasingly scarce and expensive fossil fuels and virgin 

materials;...”(Section 4001(a)). The WasteWise program and associated information 

collection activities will assist EPA in meeting the aforementioned objectives of RCRA 

by facilitating the prevention and recycling of wastes by participating organizations.

EPA collects initial information in the Partner Registration Form to formally establish 

participation in the WasteWise program. Partners also submit a Partner Agreement 

Form committing to take certain actions to remain in the program. These forms obtain 

general information on new WasteWise partners; identify the facilities committed to 

implementing the WasteWise initiatives relating to waste prevention, recycling, and 

buy/manufacture recycled-content products; and gain insight on new partners’ areas of 

interests/priorities. 

EPA also needs to collect annual information in the Partner Annual Assessment Form

to better understand and assist each partner’s waste reduction efforts and progress and to 

identify effective waste reduction strategies to share with others. Furthermore, as 
10

mentioned earlier, by compiling partners’ baseline waste reduction data, WasteWise will 

be able to more accurately determine the progress made by its partners in their waste 

reduction efforts.

The New Contact Form is used by a Partner or Endorser when granting a new user 

(within their organization) access to the online data management and reporting system.

For the WasteWise Endorser Program, EPA needs to collect initial information in the 

Endorser Registration Form to establish participation in the Endorser Program and to 

obtain general contact and membership information, as applicable. EPA also plans to 

collect information in the Endorser Annual Assessment Form on recruitment and 

ongoing activities to remain apprised of Endorser activities that bring new partners into 

the WasteWise program (see Sections 4(b)(v) and 5(a)(v)).

2(b) Practical Utility/Users of the Data

The information collected by the WasteWise program is not required for regulatory 

purposes by ORCR or other EPA offices. These data are reported by individual 

WasteWise members as a condition to remain active in the program. The data represent 

members’ progress they make towards waste reduction goals, including waste prevention, 

recycling collection, and buying or manufacturing recycled-content products activities. 

EPA does not conduct facility audits of WasteWise members; however, a quality 

assurance process is in place to review member data for accuracy. Details of this process 

are discussed in Section 5(a)(ii). EPA provides tools, technical assistance, and mentoring 

opportunities to assist members in planning, developing, and implementing their waste 

reduction program efforts. Often this assistance allows members to set higher waste 

reduction goals and achieve greater results than originally anticipated. 

Specifically, EPA uses the information collected in the Partner Registration Form to 

track organization status, prepare reports and mailing lists, and determine the focus of 

future WasteWise outreach efforts (based on partners’ identified priorities). Additional 

contacts for any organization can be added using the New Contact Form.

EPA uses the information collected in the Partner Annual Assessment Form to record 

the participant’s activities and progress in the WasteWise data management and reporting 

system; identify, develop, and disseminate case studies and other materials on key waste 

reduction practices; identify areas where additional technical assistance or information 

would be useful for individual Partners or more generally for program participants (e.g., 

high recycling figures for corrugated containers might indicate an opportunity for 

transport packaging reductions); recognize organizations with significant waste reduction 

accomplishments; evaluate opportunities for improving the WasteWise program, and

measure the program’s progress as well as progress towards sustainable materials 

management goals. Information on Partner results may be published in an annual report, 

however, this report has not been published since 2008.

EPA uses the general information collected in the Endorser Registration Form to track 

organization status and prepare reports and mailing lists. EPA will use the information 

collected in the Endorser Annual Assessment Form to learn about promotional 

activities and share successful strategies with other Endorsers, and offer assistance for 

these activities, such as providing materials for mailings or speakers for conferences (see 

Sections 4(b)(v) and 5(a)(v)).
11

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Non-duplication

The information obtained under this ICR is not duplicative nor is it currently collected by 

EPA or any other federal agency. Other non-federal organizations sponsor partnership 

programs that promote recycling collection or buying recycled products, but they do not 

offer a comprehensive waste reduction program that emphasizes the cost saving and 

environmental benefits of waste reduction. ORCR continues to work with these nonfederal organizations to ensure that efforts are not duplicative.

3(b) Public Notice Required Prior to ICR Submission to OMB

In compliance with the Paperwork Reduction Act of 1995, EPA issued a public notice in 

the Federal Register on February 23, 2011 (76 FR 10022). The public comment period 

ended on April 25, 2011. EPA received no comments on this ICR in response to the 

Federal Register notice.

3(c) Consultations

Since the last ICR approval, EPA has implemented an online data management and 

reporting system for use by Partners and Endorsers. Prior to launching this new system, 

EPA consulted with long-standing WasteWise members to beta-test the online system.

WasteWise staff also conducted personal interviews with specific program members to 

discuss the utility of the registration forms, annual assessment forms, and other online 

features. Interviews were conducted with the following WasteWise members:

Name Organization E-Mail Address

Kirby Kraft Anheuser-Bush kirby.kraft@anheuser-busch.com

Bruce Norton Constellation Energy bruce.a.norton@constellation.com

John Bradburn General Motors john.bradburn@gm.com

Tom Costantino PSEG thomas.costantino@pseg.com

Charlie Vidich USPS charles.vidich@usps.gov

Don Curran Virco Mfg doncurran@virco.com

Vicki Bushnell Kitsap County, WA vbushnel@co.kitsap.wa.us

Kathleen Tobin Verizon kathleen.tobin@verizon.com

Kinley Deller King County, WA kinley.deller@kingcounty.gov

WasteWise also conducted webinars to allow members to test the system. We created test 

accounts so members could input data and trial the system. We evaluated time, 

functionality of the system, utility, ease of use, and maneuverability within the system.

The feedback received allowed us to make key enhancements to the automated system in 

an effort to improve access and facilitate data entry. In addition, EPA headquarters

consulted with regional offices to identify types of reports needed to improve partner 

support and outreach. WasteWise then built the necessary capabilities within the online 

system to satisfy their needs.

Once EPA launched the new online system, we held a series of webinars for existing and 

potential WasteWise members. From these webinars, additional enhancements were 

made. EPA has taken great care to make the transition to our online automated system as 

seamless and workable as possible for our members.
12

According to unsolicited feedback that we have received from Partners, the new online 

data management and reporting system has had a positive effect on the program. Many 

participating partners use the online system for internal tracking and reporting purposes, 

and appreciate the ability to sort their data and run customized reports. Of particular 

benefit is the system’s ability to allow Partners and Endorsers to enter data for individual 

reporting locations within their organization.

3(d) Effects of Less Frequent Collection

The Partner Registration Form and Endorser Registration Form are one-time 

submissions for organizations wishing to participate in the WasteWise program. The New 

Contact Form is used to add additional users to an existing Partner or Endorser account

Within two months of registering, Partners submit the online Partner Annual 

Assessment Form with waste reduction baseline data and goals. This is also a one-time 

submission. Once baseline data is collected, Partners submit annual waste reduction data 

using the Partner Annual Assessment Form by March 31 of each year for the 

proceeding calendar year, for as long as they remain active in the program.

Endorsers will submit the Endorser Annual Assessment Form by March 31 of each 

year for the proceeding calendar year, detailing their annual recruitment and promotional 

activities for as long as they remain active in the program.

WasteWise believes that the frequency of data collection is appropriate and mirrors 

existing organization’s internal annual reporting. Less frequent collection of annual 

assessment reports would hinder any WasteWise efforts to:

 Analyze program data to develop timely and successful strategies for engaging 

with members to achieve greater waste reductions;

 Review Partner activities in order to publicly recognize significant waste 

reduction activities; and

 Generate relevant and timely case studies and success stories that are helpful to 

members.

3(e) General Guidelines

All of the collection activities described within this ICR fall within OMB’s General 

Guidelines.

3(f) Confidentiality

No information collected by EPA under the WasteWise program comprises confidential 

business information.

3(g) Sensitive Questions

No questions asked by EPA under the WasteWise program are of a sensitive nature.
13

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents 

The WasteWise program targets a broad audience, including small, medium, and large 

size businesses, nonprofit organizations, schools, colleges, universities, and federal, state, 

local, and tribal governments. 

The WasteWise Endorser Program targets trade associations, membership organizations, 

and federal, state, local, and tribal organizations in this supporting statement.

4(b) Information Requested

When a member organization joins the WasteWise program as a Partner or Endorser,

they register via the online Partner Registration Form or Endorser Registration 

Form. New partners are required to provide WasteWise with baseline waste reduction 

data within two months of registration using the Partner Annual Assessment Form. By 

March 31 of each year, all existing members and new members that joined the program 

before August 1 of the preceding year must report on the progress made toward achieving 

their goals using the online Partner Annual Assessment Form or Endorser Annual 

Assessment Form. Partners can add additional users to their online account by 

submitting a New Contact Form. 

(i) Partner Registration Form

Program participants complete and submit to EPA a standard online Partner 

Registration Form that provides the following information:

Data items:

 Organization name, parent organization name (if applicable), and industry sector;

 Organization contact information including address, and website;

 Names and location of participating facilities;

 Aggregate number of employees at all participating facilities;

 How the member heard about the WasteWise program;

 Organization’s primary contact’s name; title; address, phone, fax and alternate 

number; and email address;

 Goals and activities; and

 Affiliate Networks, if any.

Respondent activities:

 Review the WasteWise materials and requirements;

 Select a primary contact person for the WasteWise program;

 Gather current waste management data to develop a baseline of waste reduction 

activities;

 Create a password for access to Re-TRAC;

 Accept participation requirements detailed in the Partnership Agreement

included on the Partner Registration Form; and
14

 As part of the registration process, partners are required to submit baseline data.

This data is submitted using the Partner Annual Assessment Form as detailed 

below.

(ii) Partner Annual Assessment Form

WasteWise Partners are required to submit baseline data one time via the online Annual 

Assessment Form and within 60 days of registering with the Program. WasteWise 

Partners are required to submit annual program results. Partner Annual Assessment 

Forms are due by March 31 of each year for data from the preceding calendar year data. 

The online Partner Annual Assessment Form contains both qualitative information and 

quantitative data. 

Data items:

 Municipal Solid Waste Disposed

o Weight of waste disposed via landfill and/or incineration (pounds and/or 

tons); and

o Activity description and/or goals for upcoming year.

 Waste Prevention and Recycling

o Type of material;

o Weight of waste prevented and/or material recycled (pounds and/or tons);

and

o Activity description and/or goals for upcoming year.

 Buying or Manufacturing Recycled-Content Products

o Type of product purchased or manufactured;

o Current and previous recycled content percentages;

o Amount purchased or manufactured (pounds and/or tons); and 

o Comments and/or goals.

 Cost Savings and/or Revenue

o Dates for cost savings and/or revenue;

o Total waste prevention revenue generated;

o Total recycling revenue generated;

o Total avoided purchasing costs due to waste prevention; and

o Total avoided disposal costs due to recycling and waste prevention.

 Comments

o A partner may provide additional information on its waste reduction 

activities (e.g., external promotion of WasteWise, employee education, 

etc.) or comments about the WasteWise program.

WasteWise expects that the information needed for the Partner Annual Assessment 

Form is kept as a common business practice by companies implementing waste reduction 

programs. Therefore, recordkeeping activities associated with reporting are not included 

in this ICR.
15

Respondent activities:

 Conduct a waste assessment or account for annual waste reduction efforts;

 Review waste management records to assess progress during the reporting year;

 Set new self-identified waste reduction goals;

 Complete and submit the online Annual Assessment Form;

 Respond to EPA questions about reported data; and

 As noted above (under Partner Registration Form), partners use the Annual 

Assessment Form to submit baseline data online and within 60 days of 

registering for the program. 

(iii) Endorser Registration Form

Endorsers complete and submit an online Endorser Registration Form that provides 

basic information and describes recruitment and promotional activities. 

Data items:

 Organization name;

 Name, title, address, phone number, fax number, and email address of the 

endorser’s principal contact person;

 Approximate number of business members in the organization;

 List of primary business sectors represented by the organization (e.g., NAICS 

codes);

 Description of proposed recruitment campaign to encourage the organization’s 

members (e.g., local businesses) to become WasteWise Partners; and

 Description of proposed ongoing activities to promote WasteWise and/or provide 

information to organization members on waste reduction strategies.

Respondent activities:

 Review the WasteWise Endorser Program information;

 Identify ongoing promotional and support activities;

 Select a primary contact person for the WasteWise Endorser Program; and

 Complete and submit the online Endorser Registration Form.

(iv) Endorser Annual Assessment Form

In 2011, WasteWise plans to develop a form that will allow Endorsers to track and report 

their annual achievements. Endorsers will be required to complete and submit the 

Endorser Annual Assessment Form by March 31 of each year for the preceding year’s 

activities (first submission will be March 31, 2012). The online Endorser Annual 

Assessment Form will contain information on the Endorsers’ annual recruitment and 

promotional activities, as well as new goals for the following year.
16

Data items:

 Promotional Activities

o Description of activities conducted to promote waste reduction and 

WasteWise; and

o Frequency of promotional efforts.

 Promotional Results

o Number of organizations and/or people reached with promotional efforts;

o New organizations joining WasteWise following promotional efforts; and

o Number of WasteWise Partners that the Endorser provided with tracking 

and reporting assistance.

 Comments

o The Endorser may provide any additional information on its recruitment 

and promotional activities and promotional goals for the upcoming year.

Endorsers can use the online data management and reporting system as the sole method 

to record, track, and report their endorsement activities. Therefore, no separate 

“recordkeeping” activities will be required. As a result, activities associated with separate 

recordkeeping, beyond data entry into the system, are not included in this ICR.

Respondent activities:

 Review recruitment and promotional activities to assess progress during the 

reporting year;

 Set new recruiting and promotional goals; and

 Complete and submit the online Endorser Annual Assessment Form. 

(v) New Contact Form

Partners and Endorsers may elect to have multiple users access the online data 

management and reporting system in order to facilitate reporting at different locations. 

The New Contact Form is used by members when granting a new user (within their 

organization) access to the online data management and reporting system. There are two 

versions of this form, one for individuals to request access for themselves to the 

WasteWise online data management and reporting system and one for account 

administrators to add additional users. The only difference between the two versions is 

that the account administrators have two additional fields to assign and/or restrict each 

user’s rights within the WasteWise online data management and reporting system. 

Burden estimates for this form are included in estimates provided for the Partner 

Registration Form and Endorser Registration Form since this is an extension of 

registration information. 

Data items:

 Organization name, reporting location, and state;

 Contact’s name; title; address, phone, fax and alternate number; and email 

address;

 User access level: Primary or Reporting (For account administrators only); and
17

 User location access: Establish/Restrict a user's access to one or more locations

(For account administrators only).

Respondent activities

 Create a password for access to Re-TRAC.

5. THE INFORMATION COLLECTED – AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

Under the WasteWise program, EPA engages in various activities related to the following 

five forms:

(i) Partner Registration Form

 Maintain Partner Registration Forms in the online data management and 

reporting system and public WasteWise website;

 Answer questions posed by potential participants regarding program 

membership;

 Review and approve new partner registration forms;

 Place welcome calls to new partners; and

 Email welcome letters to new partners containing participation information and 

links to program resources.

(ii) Partner Annual Assessment Form

 Maintain the online data management and reporting system containing annual 

assessment data entered by members. This online system is also a tool to assist 

partners in measuring and tracking waste reduction progress;

 Provide tools to assist partners with measuring, tracking, and reporting progress. 

These tools range from resources posted to the program website, a staffed 

helpline, and periodic webinars;

 Email partners to remind them to submit data by due dates:

o New partners must submit baseline waste reduction data and goals within 

two months of registering for the program; 

o Existing Partners must submit waste reduction data and new goals by 

March 31 of each year for the proceeding calendar year; and

 Answer questions regarding the Partner Annual Assessment Form, and once 

received, review it for consistency and completeness, making follow-up inquiries

as needed.

o Reported Data Quality. The WasteWise program employs a quality 

assurance process that involves reviewing the data submitted by each 

Partner and determining whether the reported results appear consistent with 

the volumes reported by the Partner in previous years for similar activities. 

If newly submitted data appear to be the exact same as data submitted in 

previous years or appear to be cumulative rather than simply for the current 

reporting year period, the Partner is contacted to clarify the reported 
18

results. For reported amounts above 1,000,000 pounds, Partners are 

contacted to confirm the order of magnitude and to prevent any errors of 

interpretation. In addition, data are reviewed to ensure that only acceptable 

WasteWise materials and activities are included in the amounts reported. 

Once this thorough review is complete, the data is verified. Only data

verified through the quality assurance process is included in official 

program data.

 Develop Climate Change profiles, for each Partner, which provides annual 

summaries of verified data and related greenhouse gas impacts using EPA’s 

WaRM. 

(iii) Endorser Registration Form

 Maintain Endorser Registration Forms on the public WasteWise website;

 Answer questions posed by potential Endorsers regarding membership in the 

program;

 Review and approve new Endorser Registration Forms;

 Place a welcome call to new Endorsers; and

 Email welcome letters to new Endorsers containing participation information and 

links to program resources.

(iv) Endorser Annual Assessment Form

As noted above, this is a newly developed form. WasteWise anticipates undertaking the 

following activities in association with this form:

 Maintain the online data management and reporting system containing annual 

assessment data entered by members. This web based system is also a tool to 

assist Endorsers in measuring and tracking promotional and recruiting activities;

 Provide tools to assist Endorsers with their promotional and recruitment efforts. 

These tools range from resources posted to the program website, a staffed 

helpline, and periodic webinars;

 Email Endorsers to remind them to submit data by due dates:

o Endorsers must submit the previous year’s promotional and recruiting data 

and new goals by March 31 of each year for the proceeding calendar;

 Answer any questions regarding the Endorser Annual Assessment Form and 

once received, review it for consistency and completeness, making follow-up 

inquiries, as needed;

o Reported Data Quality. The WasteWise program reviews the data 

submitted by each Endorser and determines whether the information 

reported appears consistent with the activities and goals reported in 

previous years. If newly submitted data appear to be the exact same as 

submitted in previous years or appears to be cumulative rather than simply 

for the current reporting year period, the Endorser is contacted to clarify 

the reported results. In addition, reported information is reviewed to ensure 

that only acceptable WasteWise activities are included. Once this thorough 

review is complete, the data is verified. Only verified data is included in 

official program data.
19

(v) New Contact Form

 Maintain New Contact Form in the online data management and reporting 

system; 

 Email contacts on the form that they have access to the online data management 

and reporting system; and

 When requested, provide newly activated contacts with assistance in accessing 

the online system.

5(b) Collection Methodology and Management

EPA relies on its online forms and database to collect, store, and evaluate the data 

submitted by Partners. EPA reviews each submission to ensure the collected information 

is reasonable and complete. The data are used to identify prominent waste reduction 

strategies, develop and publish case studies of significant accomplishments, and steer the 

program’s priorities for the upcoming year. In addition, members can use the online data 

management and reporting system to benchmark data and evaluate trends.

The data collected under this ICR is reported by individual WasteWise members as a 

condition to remain active in the program. The data represent members’ quantified

progress that they made towards waste reduction goals (in areas such as waste prevention, 

recycling collection, and buying or manufacturing recycled-content products). EPA does 

not conduct facility audits of WasteWise members; however, a quality assurance process 

is in place to review reported data for accuracy and adherence to goals as described in 

Section 5(a)(ii). 

WasteWise uses the collected data to record participant’s activities and progress made in 

waste prevention and recycling, identify technical assistance needs for each participant,

and develop case studies and mentoring opportunities that can be used by participants to 

enhance their waste reduction programs.

Data are also used to report the overall results of members involved in the program. Any

time data is aggregated and/or disseminated, EPA follows the existing Terms of 

Clearance and qualifies its results to ensure attribution (i.e., program’s impact on Partner 

achievements) is not implied. EPA will work with OMB to develop a methodology to 

better characterize the program’s influence on Partner behavior and results. Once a 

methodology is developed, EPA would like to disseminate and use the program results

from WasteWise with attribution.

5(c) Small Entity Flexibility

Some of the participants in the WasteWise program will be small entities. EPA designed 

its online reporting forms to be highly flexible and dependent on activities in order to 

minimize respondent burden, while obtaining sufficient and accurate information. 

Organizations can also choose the number of facilities to include in the program and 

choose their own goals based on resources. In addition, the burden associated with the 

WasteWise program is greatly reduced for small entities in particular because the

program offers direct one-on-one mentoring and a helpline that provides support 

especially valuable for small organizations allowing them to fully participate in the 

program. 
20

5(d) Collection Schedule

Organizations may join the WasteWise program by submitting the online Partner 

Registration Form at any time. New Partners submit baseline waste reduction data and 

goals via the online Partner Annual Assessment Form within two months of joining the 

program. All existing Partners’ online Partner Annual Assessment Forms are due to 

EPA by March 31 of every year for the proceeding calendar year that the partner 

participates in the program.

Trade associations and other membership-based organizations may join the program by 

submitting the online Endorser Registration Forms at any time. All existing Endorsers’ 

online Endorser Annual Assessment Forms will be due to EPA by March 31 of every 

year for the proceeding calendar year that the Endorser participates in the program.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

Tables 4-6 present the burden hours, costs per respondent, and total for all respondents 

during each of the three years covered under this ICR. WasteWise members are divided 

into three sectors representing: Private, State/Local, and Federal.

The Partner Registration Form contains basic questions, and thus the burden is 

expected to be minimal. The overall burden, as shown in the tables, is estimated to be one 

hour per participant. This burden level is an estimate based on 17 years of WasteWise 

program experience. The burden estimate for the Partner Registration Form is for 

completing and submitting the form only.

Completing the Partner Annual Assessment Form entails assessment, reporting, and 

recordkeeping activities. The overall annual labor burden for Partners is expected to 

average 34.5 hours per participant; this estimate is based on 17 years of WasteWise 

program experience. Burden hours for the Partner Annual Assessment Form are for 

conducting a waste assessment, collecting data, entering data into the online data 

management and reporting system, and reporting activities.

In the first year of membership, new Partners are estimated to spend 35.5 hours (one hour 

on the Partner Registration Form and 34.5 hours on the Partner Annual Assessment 

Form, i.e. providing baseline data) on the information collection activities. It is estimated 

that Partners spend 34.5 hours (on the Partner Annual Assessment Form) for 

subsequent years in the program. Estimates for submitting information associated with 

the New Contact Form are included in the burden estimates for the Partner 

Registration Form and Endorser Registration Form since this information is an 

extension of registration.

The Endorser Registration Form asks for basic information and requests brief

descriptions of promotional activities, and thus the burden is expected to be minimal. The 

overall burden, as shown in Tables 4-6, is estimated to be three hours per participant; this 

estimate is based on 17 years of WasteWise program experience. All burden hours for the 

Endorser Registration Form are for reporting only.

Completing the Endorser Annual Assessment Form entails assessment, reporting, and 

recordkeeping activities. The overall annual labor burden for Endorsers is expected to 

average five hours per participant. Burden hours for the Endorser Annual Assessment 

Form are for accounting for annual efforts, assessing progress, entering data into the 

online data management and reporting system, and reporting activities.
21

6(b) Estimating Respondent Costs

Currently, WasteWise has 568 active Partners and 86 active Endorsers. WasteWise 

anticipates receiving 343 new Partner Registration Forms and 54 new Endorser 

Registration Forms each year under this ICR. Of these new registrants, WasteWise 

anticipates 76 Partners and 11 Endorsers will fulfill their membership requirements and 

submit Annual Assessment Forms each year. The membership breakdown by sector 

over the next three years is shown in the following table.

Table 1. WasteWise Membership

WasteWise Partners (by category)

Federal State/Local Private Total

Current 21 45 502 568

Year 1 24 51 569 644

Year 2 27 57 636 720

Year 3 30 63 703 796

WasteWise Endorsers (by category)

Federal State/Local Private Total

Current 2 12 72 86

Year 1 2 14 81 97

Year 2 2 16 90 108

Year 3 2 18 99 119

EPA used the May 2009 Occupational Employment Statistics (OES) Survey from the 

Bureau of Labor Statistics, Department of Labor to estimate average hourly private 

respondent labor. This survey provides unloaded labor rates for a number of job 

categories in various sectors. EPA believes (based on 17 years of program experience)

that responses will require time from one manager and one technical staff person. For 

managers, EPA used labor category 11-9199 (Managers, All Others) which has an 

average unloaded labor rate of $47.67/hour. For technical staff, EPA used labor category 

19-2041 (Environmental Scientists) which has an unloaded labor rate of $32.38/hour. 

These hourly rates were multiplied by a standard private sector overhead calculation 

factor of 2.3 to obtain the loaded labor rates for private sector respondents shown in 

Table 2. All rates have been rounded up to the nearest dollar. No capital or operations and 

management costs are incurred by respondents under this ICR.

Table 2. Hourly Labor Rates – Private Sector

Labor Category Hourly Rate Plus Overhead 

Management $110

Technical $74

For federal, state, and local respondents, EPA used the General Schedule Salary Tables 

for 2011 issued by the Office of Personnel Management (OPM) to estimate hourly labor 

rates. EPA believes (based on program experience) that responses will require time from 

one manager (GS 14, Step 3) and one technical staff person (GS 11, Step 10). To estimate 

national labor rates for each of these job categories, EPA summed the unloaded hourly 

rates of all 36 locality tables and averaged the rates for GS 14, Step 3 and GS 11, Step 10. 

Based on these calculations, the average unloaded rates for GS 14, Step 3 is $51.86 and 

for GS 11, Step 10 is $37.53. EPA multiplied these basic hourly rates by the standard 

government overhead factor of 1.6 to obtain the loaded labor rates shown in Table 3. All 

figures have been rounded up to the next full dollar.
22

Table 3. Local, State, and Federal Labor Rates

Labor Category Rate Plus Overhead ($/hour)

Management $84

Technical $61
23

Table 4. Annual Estimated Respondent Burden and Cost – Private Sector Respondents

Partner Respondents

Individual Respondent Burden Hours & Cost 

for All Years Year 1 Costs Year 2 Costs Year 3 Costs

Hours per Respondent per Activity Cost 

per 

Activity

Total 

Hours Total Cost

Total 

Hours Total Cost

Total 

Management Technical Hours Total Cost

Total 

Hours

Partner Registration Form (includes New Contact Form)

Review Form 0.25 0.50 0.75 $65 227 $19,479 227 $19,479 227 $19,479

Complete/Transmit 

Form 0.00 0.25 0.25 $19 76 $5,587 76 $5,587 76 $5,587

SUBTOTAL 0.25 0.75 1.00 $83 302 $25,066 302 $25,066 302 $25,066

Annual Assessment Form

Collect records and 

conduct a waste 

assessment OR 

account for annual 

efforts 7.00 14.00 21.00 $1,806 11,949 $1,027,614 13,356 $1,148,616 14,763 $1,269,618

Review records to 

assess progress 0.25 0.25 0.50 $46 285 $26,174 318 $29,256 352 $32,338

Set Goals 2.50 7.50 10.00 $830 5,690 $472,270 6,360 $527,880 7,030 $583,490

Complete/Transmit 

Form 0.25 1.75 2.00 $157 1,138 $89,333 1,272 $99,852 1,406 $110,371

Respond to EPA 

Questions 0.25 0.75 1.00 $83 569 $47,227 636 $52,788 703 $58,349

SUBTOTAL 10.25 24.25 34.50 $2,922 19,631 $1,662,618 21,942 $1,858,392 24,254 $2,054,166

Costs to Partners

Total Cost to All 

Partners 19,933 $1,687,684 22,244 $1,883,458 24,556 $2,079,232

Endorser Respondents

Individual Respondent Burden Hours & Cost 

for All Years Year 1 Costs Year 2 Costs Year 3 Costs

Hours per Respondent per Activity Cost 

per 

Activity

Total 

Hours Total Cost

Total 

Hours Total Cost

Total 

Management Technical Hours Total Cost

Total 

Hours

Endorser Registration Form (includes New Contact Form)

Review Form 0.25 0.50 0.75 $65 34 $2,903 34 $2,903 34 $2,903

Determine 

Activities 0.25 1.50 1.75 $139 79 6,233 79 $6,233 79 $6,233

Complete/Transmit 

Form 0.00 0.50 0.50 $37 23 1,665 23 $1,665 23 $1,665

SUBTOTAL 0.50 2.50 3.00 $240 135 10,800 135 $10,800 135 $10,800

Endorser Annual Assessment Form

Account for annual 

efforts 0.50 1.50 2.00 $166 162 $13,446 180 $14,940 198 $16,434

Review records to 

assess progress 0.25 0.25 0.50 $46 41 $3,726 45 $4,140 50 $4,554

Set Goals 0.25 1.00 1.25 $102 101 $8,222 113 $9,135 124 $10,049

Complete/Transmit 

Form 0.00 0.50 0.50 $37 41 $2,997 45 $3,330 50 $3,663

Respond to EPA 

Questions 0.25 0.50 0.75 $65 61 $5,225 68 $5,805 74 $6,386

SUBTOTAL 1.25 3.75 5.00 $415 405 $33,615 450 $37,350 495 $41,085

Costs to Endorsers

Total Cost to All 

Endorsers 540 $44,415 585 $48,150 630 $51,885

Assumptions

Management rate: $110/hr

Technical rate: $74/hr

New partners: 302/yr

Reporting partners: Y1=569, Y2=636, Y3=703

New Endorsers: 45/yr

Reporting Endorsers: Y1=81, Y2=90, Y3=99
24

Table 5. Annual Estimated Respondent Burden and Cost – State/Local Respondents

Partner Respondents

Individual Respondent Burden Hours & Cost 

for All Years Year 1 Costs Year 2 Costs Year 3 Costs

Hours per Respondent per Activity Cost 

per 

Activity

Total 

Hours

Total 

Cost

Total 

Hours

Total 

Cost

Total 

Hours

Total 

Management Technical Cost

Total 

Hours

Partner Registration Form (includes New Contact Form)

Review Form 0.25 0.50 0.75 $52 25 $1,700 25 $1,700 25 $1,700

Complete/Transmit 

Form 0.00 0.25 0.25 $15 8 $503 8 $503 8 $503

SUBTOTAL 0.25 0.75 1.00 $67 33 $2,203 33 $2,203 33 $2,203

Annual Assessment Form

Collect records and 

conduct a waste 

assessment OR 

account for annual 

efforts 7.00 14.00 21.00 $1,442 1,071 $73,542 1,197 $82,194 1,323 $90,846

Review records to 

assess progress 0.25 0.25 0.50 $36 26 $1,849 29 $2,066 32 $2,284

Set Goals 2.50 7.50 10.00 $668 510 $34,043 570 $38,048 630 $42,053

Complete/Transmit 

Form 0.25 1.75 2.00 $128 102 $6,515 114 $7,282 126 $8,048

Respond to EPA 

Questions 0.25 0.75 1.00 $67 51 $3,404 57 $3,805 63 $4,205

SUBTOTAL 10.25 24.25 34.50 $2,340 1,760 $119,353 1,967 $133,394 2,174 $147,436

Costs to Partners

Total Cost to All 

Partners 1,793 $121,556 2,000 $135,597 2,207 $149,639

Endorser Respondents

Individual Respondent Burden Hours & Cost 

for All Years Year 1 Costs Year 2 Costs Year 3 Costs

Hours per Respondent per Activity Cost 

per 

Activity

Total 

Hours 

Total 

Cost

Total 

Hours 

Total 

Cost

Total 

Hours 

Total 

Management Technical Cost

Total 

Hours

Endorser Registration Form (includes New Contact Form)

Review Form 0.25 0.50 0.75 $52 6 $412 6 $412 6 $412

Determine 

Activities 0.25 1.50 1.75 $113 14 $900 14 $900 14 $900

Complete/Transmit 

Form 0.00 0.50 0.50 $31 4 $244 4 $244 4 $244

SUBTOTAL 0.50 2.50 3.00 $195 24 $1,556 24 $1,556 24 $1,556

Endorser Annual Assessment Form

Account for annual 

efforts 0.50 1.50 2.00 $134 28 $1,869 32 $2,136 36 $2,403

Review records to 

assess progress 0.25 0.25 0.50 $36 7 $508 8 $580 9 $653

Set Goals 0.25 1.00 1.25 $82 18 $1,148 20 $1,312 23 $1,476

Complete/Transmit 

Form 0.00 0.50 0.50 $31 7 $427 8 $488 9 $549

Respond to EPA 

Questions 0.25 0.50 0.75 $52 11 $721 12 $824 14 $927

SUBTOTAL 1.25 3.75 5.00 $334 70 $4,673 80 $5,340 90 $6,008

Costs to Endorsers

Total Cost to All 

Endorsers 94 $6,229 104 $6,896 114 $7,564

Assumptions

Management Rate: $84/hr

Technical Rate: $61/hr

New Partners: 33/yr

Reporting Partners: Y1=51, Y2=57, 

Y3=63

New Endorsers: 8/yr

Reporting Endorsers: Y1=14, 

Y2=16, Y3=18
25

Table 6. Annual Estimated Respondent Burden and Cost – Federal Respondents

Partner Respondents

Individual Respondent Burden Hours & Cost 

for All Years Year 1 Costs Year 2 Costs Year 3 Costs

Hours per Respondent per Activity Cost 

per 

Activity

Total 

Hours

Total 

Cost

Total 

Hours

Total 

Cost

Total 

Hours

Total 

Management Technical Cost

Total 

Hours

Partner Registration Form (includes New Contact Form)

Review Form 0.25 0.50 0.75 $52 6 $412 6 $412 6 $412

Complete/Transmit 

Form 0.00 0.25 0.25 $15 2 $122 2 $122 2 $122

SUBTOTAL 0.25 0.75 1.00 $67 8 $534 8 $534 8 $534

Annual Assessment Form

Collect records and 

conduct a waste 

assessment OR 

account for annual 

efforts 7.00 14.00 21.00 $1,442 504 $34,608 567 $38,934 630 $43,260

Review records to 

assess progress 0.25 0.25 0.50 $36 12 $870 14 $979 15 $1,088

Set Goals 2.50 7.50 10.00 $668 240 $16,020 270 $18,023 300 $20,025

Complete/Transmit 

Form 0.25 1.75 2.00 $128 48 $3,066 54 $3,449 60 $3,833

Respond to EPA 

Questions 0.25 0.75 1.00 $67 24 $1,602 27 $1,802 30 $2,003

SUBTOTAL 10.25 24.25 34.50 $2,340 828 $56,166 932 $63,187 1,035 $70,208

Costs to Partners

Total Cost to All 

Partners 836 $56,700 940 $63,721 1,043 $70,742

Endorser Respondents

Individual Respondent Burden Hours & Cost 

for All Years Year 1 Costs Year 2 Costs Year 3 Costs

Hours per Respondent per Activity Cost 

per 

Activity

Total 

Hours 

Total 

Cost

Total 

Hours 

Total 

Cost

Total 

Hours 

Total 

Management Technical Cost

Total 

Hours

Endorser Registration Form (includes New Contact Form)

Review Form 0.25 0.50 0.75 $52 1 $52 1 $52 1 $52

Determine 

Activities 0.25 1.50 1.75 $113 2 $113 2 $113 2 $113

Complete/Transmit 

Form 0.00 0.50 0.50 $31 1 $31 1 $31 1 $31

SUBTOTAL 0.50 2.50 3.00 $195 3 $195 3 $195 3 $195

Endorser Annual Assessment Form

Account for annual 

efforts 0.50 1.50 2.00 $134 4 $267 4 $267 4 $267

Review records to 

assess progress 0.25 0.25 0.50 $36 1 $73 1 $73 1 $73

Set Goals 0.25 1.00 1.25 $82 3 $164 3 $164 3 $164

Complete/Transmit 

Form 0.00 0.50 0.50 $31 1 $61 1 $61 1 $61

Respond to EPA 

Questions 0.25 0.50 0.75 $52 2 $103 2 $103 2 $103

SUBTOTAL 1.25 3.75 5.00 $334 10 $668 10 $668 10 $668

Costs to Endorsers

Total Cost to All 

Endorsers 13 $862 13 $862 13 $862

Assumptions

Management Rate = $84/hr

Technical Rate = $61/hr

New Partners = 8/yr

Reporting Partners: Y1=24, Y2=27, 

Y3=30

New Endorsers = 1/yr

Reporting Endorsers: Y1=2, Y2=2, 

Y3=2
26

6(c) Estimating Agency Burden and Costs

Table 8 (below) presents the estimated Agency burden hours and costs associated with 

the information collection activities under this ICR. Other direct costs (copying, printing, 

telephone, and mailing expenses) are also included. EPA based its burden estimates on 17 

years of experience managing the WasteWise program and interacting with partners.

EPA used the General Schedule Salary Tables for 2011 issued by the Office of Personnel 

Management (OPM) to estimate hourly labor rates for the Agency. The Agency expects 

most activities under this ICR to be performed by managerial staff (GS 14, Step 3) and 

technical staff (GS 11, Step 10). To estimate national labor rates for each of these job 

categories, EPA summed the unloaded hourly rates of all 36 locality tables and averaged 

the rates for GS 14, Step 3 and GS 11, Step 10. Based on these calculations, the average 

unloaded rates for GS 14, Step 3 is $51.86 and for GS 11, Step 10 is $37.53. EPA 

multiplied these basic hourly rates by the standard government overhead factor of 1.6 to 

obtain the loaded labor rates shown in Table 7. All figures have been rounded up to the 

next full dollar.

EPA still expects to have contractor support for various activities associated with the 

information collection under this ICR and has included contractor costs in the estimates. 

Contractor hourly rates, estimated based on the rates for the current contractor, ERG, are 

$150.58 for managerial staff (Project Manager) and $78.00 for technical staff (Program 

Analyst 2) so the average hourly rates are proportional to the percentage of contractor 

support on a given task.

Table 7. Agency Labor Rates

EPA/ 

Contractor 

Share

Mgmt.

Rate

Technical 

Rate

Mgmt.

%

Technical 

%

Average 

Rate

100% EPA $83 $60 25% 75% $66 

0% 

Contractor

$0 $0 0% 0% $0 

Total $66 

25% EPA $21 $15 25% 75% $17 

75% 

Contractor

$113 $59 25% 75% $73 

Total $90 

0% EPA $0 $0 0% 0% $0 

100% 

Contractor

$151 $78 25% 75% $96 

Total $96 
27

Table 8. Annual Estimated Agency Burden and Cost

Avg. 

Hourl

y Rate

Year 1 Year 2 Year 3

Labor Other 

Direct 

Costs

Total 

Costs

Labor Other 

Direct 

Costs

Total 

Costs

Labor Other 

Direct 

Costs

Total 

Hours Costs Costs

Hour

s Costs

Hour

s Costs

Partner Registration Form (includes New Contact Form)

Maintain 

Online 

Form and 

Database $96 0 $0 $10,000 $10,000 0 $0 $11,000 $11,000 0 $0 $12,000 $12,000

Answer 

Questions $96 350 $33,600 $1,400 $35,000 350 $33,600 $1,400 $35,000 350 $33,600 $1,400 $35,000

Subtotal 350 $33,600 $11,400 $45,000 350 $33,600 $12,400 $46,000 350 $33,600 $13,400 $47,000

Partner Annual Assessment Form

Maintain 

Online 

Form and 

Database $96 0 $0 $10,000 $10,000 0 $0 $11,000 $11,000 0 $0 $12,000 $12,000

Answer 

Questions $90 1,300 $117,000 $5,200 $122,200 1,450 $130,500 $5,800 $136,300 1,600 $144,000 $6,400 $150,400

QA/QC 

Data $96 1,300 $124,800 $5,200 $130,000 1,450 $139,200 $5,800 $145,000 1,600 $153,600 $6,400 $160,000

Subtotal 2600 $241,800 $20,400 $262,200 2900 $269,700 $22,600 $292,300 3200 $297,600 $24,800 $322,400

Endorser Registration Form (includes New Contact Form)

Maintain 

Online 

Form and 

Database $96 0 $0 $10,000 $10,000 0 $0 $11,000 $11,000 0 $0 $12,000 $12,000

Answer 

Questions $96 50 $4,800 $200 $5,000 50 $4,800 $200 $5,000 50 $4,800 $200 $5,000

Subtotal 50 $4,800 $10,200 $15,000 50 $4,800 $11,200 $16,000 50 $4,800 $12,200 $17,000

Endorser Annual Assessment Form

Maintain 

Online 

Form and 

Database $96 0 $0 $10,000 $10,000 0 $0 $11,000 $11,000 0 $0 $12,000 $12,000

Answer 

Questions $90 200 $18,000 $800 $18,800 225 $20,250 $900 $21,150 250 $22,500 $1,000 $23,500

QA/QC 

Data $96 200 $19,200 $800 $20,000 225 $21,600 $900 $22,500 250 $24,000 $1,000 $25,000

Subtotal 400 $37,200 $11,600 $48,800 450 $41,850 $12,800 $54,650 500 $46,500 $14,000 $60,500

Cost to EPA

Total 

Cost 3400 $317,400 $53,600 $371,000 3750 $349,950 $59,000 $408,950 4100 $382,500 $64,400 $446,900
28

6(d) Estimating the Respondent Universe and Total Burden and Costs

As of April 1, 2011, the WasteWise program had 568 active partners. EPA expects 343

organizations to submit the Partner Registration Form during each year for the period 

covered by this ICR. The Partner Registration Form is a one-time reporting 

requirement. Organizations must submit the Partner Annual Assessment Form, an 

annual reporting requirement containing quantitative information, to be considered an 

active WasteWise partner. As previously mentioned, WasteWise anticipates that 76 of the 

343 new registrants each year will complete the Partner Annual Assessment Form. 

Thus, WasteWise estimates the following Partner Annual Assessment Form

submittals: 644 in year 1, 717 in year 2, and 796 in year 3. 

The WasteWise program currently has approximately 86 active Endorsers. The Endorser 

Registration Form is a one-time reporting event. EPA estimates that 54 organizations 

will submit the Endorser Registration Form each year. Endorsers must submit the 

Endorser Annual Assessment Form, an annual reporting requirement containing 

information on promotional and recruitment activities, to be considered an active 

WasteWise Endorser. EPA anticipates that 11 of the 54 new registrants will submit the 

Endorser Annual Assessment Form. Therefore, WasteWise estimates the following 

Endorser Annual Assessment Form submittals: 97 in year 1, 108 in year 2, and 119 in 

year 3. The New Contact Form represents supplemental registration information and 

the time to complete this form is included in the burden estimates for the Partner 

Registration Form and Endorser Registration Form.

6(e) Estimated Burden Hours and Costs

The estimated burden and costs to respondents are displayed in the Table 9 below. Note 

that the estimated number of respondents changes each year, depending on the 

information collection activity. There are variations in the estimated costs for each of the 

three years covered because the number of respondents increases each of these years.

Table 9. Estimated Burden and Costs to Respondents

Form Number of 

Respondents

Burden Hours Cost

Year 1

Partner Registration 343 343 $27,803

Partner Annual Assessment 644 22,218 $1,838,137

Endorser Registration 54 156 $12,551

Endorser Annual Assessment 97 485 $38,956

Year 1 Total 1,136 23,202 $1,917,447

Year 2

Partner Registration 343 343 $27,803

Partner Annual Assessment 717 24,736 $2,054,973

Endorser Registration 54 156 $12,551

Endorser Annual Assessment 108 540 $43,358

Year 2 Total 1,220 25,775 $2,138,685

Year 3

Partner Registration 343 343 $27,803

Partner Annual Assessment 796 27,462 $2,271,462

Endorser Registration 54 156 $12,551

Endorser Annual Assessment 119 595 $47,761

Year 3 Total 1,310 28,556 $2,359,577

3-Year Total 3,666 77,533 $6,415,709

Annual Average 1,222 25,844 $2,138,570
29

The estimated burden and costs to EPA also vary each year, according to the number of 

respondents. Table 10 indicates the Agency’s estimated burden and costs for each of the 

three years covered under this ICR. 

Table 10. Estimated Burden and Costs to EPA

Year Burden Hours Cost

Year 1 3,400 $371,000

Year 2 3,750 $408,950

Year 3 4,100 $446,900

3-Year Total 11,250 $1,226,850

Annual Average 3,750 $408,950

6(f) Reasons for Change in Burden

Since the last clearance, EPA has made the following changes to the WasteWise program 

that affect information collection activities:

 Online Data Management and Reporting System. WasteWise’s new online data 

management and reporting system reduced burden of WasteWise members and 

program administrators by automating tasks. 

 Changes in Wage Rates. EPA changed the burden costs for private respondents to 

reflect the updated rates in the May 2009 Occupational Employment Statistics (OES)

Survey from the Bureau of Labor Statistics, Department of Labor. EPA also changed 

the burden costs to state, local and federal respondents, as well as the Agency to 

reflect the 2011 GS rates. This only impacted burden costs; it did not impact burden 

hours.

 Variation in Number of Participants. For this ICR, the Agency updated the 

Partner numbers to reflect current WasteWise membership trends. EPA expects that 

76 new active Partners will join AND report as active Partners during each year 

covered by this ICR. Additionally, EPA expects the WasteWise program to bring in 

11 new active reporting Endorsers each year. Active members include Partners and 

Endorsers that register AND report.

6(g) Burden Statement

The reporting burden for information collection requirements associated with completing 

the Partner Registration Form and New Contact Form are estimated to be one hour 

per respondent. The burden estimate includes time to review WasteWise program 

information and requirements and to complete and submit the form(s).

The reporting burden for information collection requirements associated with completing 

the Partner Annual Assessment Form is estimated to be 34.5 hours per respondent. 

This burden estimate includes time to conduct a waste assessment, set up a tracking 

system, determine goals, collect and review records, complete and submit the form, and 

respond to questions from EPA regarding data clarification.

The reporting burden for information collection requirements associated with completing 

the Endorser Registration Form and New Contact Form are estimated to be three

hours per respondent. This burden estimate includes time to review WasteWise Endorser 

program information and requirements, to determine recruitment and promotional 

activities, and to complete and submit the form.
30

The reporting burden for information collection requirements associated with completing 

the Endorser Annual Assessment Form is estimated to be five hours per respondent. 

This burden estimate includes time to collect and review records, determine goals, 

complete and submit the form, and respond to questions from EPA regarding data 

clarification.

Burden means the total time, effort, and financial resources expended by persons to 

generate, maintain, retain, disclose, or provide information to or for a federal agency. 

This includes the time needed to review instructions; develop, acquire, install, and utilize 

technology and systems for the purposes of collecting, validating, and verifying 

information, processing and maintaining information, and disclosing and providing 

information; adjust the existing ways to comply with any previously applicable 

instructions and requirements; train personnel to be able to respond to a collection of 

information; search data sources; complete and review the collection of information; and 

transmit or otherwise disclose the information. An agency may not conduct or sponsor, 

and a person is not required to respond to, a collection of information unless it displays a 

currently valid OMB control number. The OMB control numbers for EPA’s regulations 

are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

To comment on the Agency’s need for this information, the accuracy of the provided 

burden estimates, and any suggested methods for minimizing respondent burden, 

including the use of automated collection techniques, EPA has established a public 

docket for this ICR under Docket ID No. EPA-HQ-RCRA-2010-0832, which is available 

for online viewing at www.regulations.gov, or in person viewing at the RCRA Docket in 

the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., 

NW, Washington, DC. The EPA/DC Public Reading Room is open from 8:30 a.m. to 

4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for 

the Reading Room is (202)566-1744, and the telephone number for RCRA Docket is 

(202) 566-0270.

Use www.regulations.gov to obtain a copy of the draft collection of information, submit 

or view public comments, access the index listing of the contents of the docket, and to 

access those documents in the public docket that are available electronically. Once in the 

system, select “search,” then key in the docket ID number identified in this document.

7. POTENTIAL FUTURE WASTEWISE INITIATIVES

7(a) WasteWise Challenges – Targeting Selective Materials and Sectors

In his September 2009 Strategy for American Innovation, President Obama called on 

federal agencies to increase their ability to promote innovation by using tools, such as 

challenges to solve tough problems. In response, WasteWise will issue Challenges to its 

Partners to give them the opportunity to target selected materials for waste prevention 

and recycling. WasteWise may also challenge certain sectors, such as federal, state, or 

local governments; colleges and universities; etc., to increase waste prevention and 

recycling in general or target certain materials generated in high volume by those sectors. 

These WasteWise Challenges will raise awareness of the opportunities to reduce the 

amount of these materials generated and increase their recovery, recruit organizations to 

join and participate in WasteWise, and encourage existing Partners to pursue additional 

waste reduction activities. The use of these Challenges will be a key component of

EPA’s efforts to promote Sustainable Materials Management (SMM). 

During the duration of this ICR, EPA anticipates issuing a number of WasteWise 

Challenges that would impact the number of Partners that may join the program and/or 

the number of organizations (Partners and Non-Partners) submitting data to the program. 
31

We anticipate issuing one or more Challenges over the next three years, targeting the 

following materials/sectors: electronics; packaging; colleges and universities; 

federal/state/local governments; and food wastes. We hope to initiate two Challenges in 

the first year of this ICR that will serve as models for subsequent Challenges. One of 

these challenges will use the standard WasteWise forms. The other will use equivalent 

forms which are included in Attachment N. Subsequent Challenges will follow the form 

of these two initial Challenges and data collection needs will be similar. However, if 

additional data information or form changes are needed, we will amend the ICR. Since 

these Challenges and their burden are not included in the burden estimates provided 

earlier in this document, the annual estimated burden for a typical Challenge is shown in 

Table 11.

7(b) Requirements for Organizations Participating in Challenges

To participate in a Challenge, organizations may sign-up via the WasteWise Partner 

Registration Form or a Challenge Registration Form which would be a substantively 

equivalent form with alternative formatting. Following standard WasteWise 

requirements, Challenge participants will report results of Challenge-related efforts via 

the Partner Annual Assessment Form or a Challenge Assessment Form, which would 

be a substantively equivalent form with alternative formatting. EPA will provide the 

alternative Challenge Registration and Assessment Forms to reduce the burden on 

participating organizations and streamline data collection of Challenge related activities.

Attachment N includes samples of how the alternative online Challenge forms may be 

presented to participants. These formats will allow the online database system to sort 

data submitted under the particular Challenge in a more efficient manner, depending on 

the complexity of the Challenge issued. For the purposes of this ICR, EPA assumes, 

conservatively, that all participants would also formally join WasteWise as part of any 

Challenge issued, so that this estimate is likely to overestimate, but will not 

underestimate, this burden on participants. 

Based on all of the aforementioned assumptions, Challenge participants would be 

expected to:

 review a narrative description of the Challenge details;

 register, if they so choose, for the Challenge using the standard Partner 

Registration Form or a substantively equivalent alternative form;

 submit baseline data using the standard Partner Annual Assessment Form or a 

substantively equivalent alternative form;

 report accomplishments using the standard Partner Annual Assessment Form

or a substantively equivalent alternative form.

7(c) Estimating Burden and Costs for Organizations Participating in Challenges

At this time, plans for the WasteWise Challenges are still being developed, so the 

estimated burdens in this section are conservative and are likely to overestimate the 

burden in order to adequately account for future activity in these areas. Based on 

historical review and previous WasteWise Challenges, EPA estimates that approximately 

50 organizations will participate in each Challenge. The estimated cost burden on 

participants for a single Challenge is shown in Table 11. EPA used the highest cost 

labor mix, that of the private sector, in developing the estimates since we are unable, at 

this time, to identify the exact number of participants in each Challenge by sector. 
32

Table 11. Annual Estimated Burden for Challenge Respondents for a Single Challenge

Challenge Respondents

Individual Respondent Burden Hours & Cost for 

All Years Year 1 Costs Year 2 Costs Year 3 Costs

Hours per Respondent per Activity

Cost per 

Activity

Total 

Hours

Total 

Cost

Total 

Hours

Total 

Cost

Total 

Hours

Total 

Management Technical Cost

Total 

Hours

Challenge Registration Form (includes new contact form)

Review Challenge 

details 0.25 0.50 0.75 $65 15 $1,290 11 $968 11 $968

Complete/

Transmit Form 0.00 0.25 0.25 $19 5 $370 4 $278 4 $278

SUBTOTAL 0.25 0.75 1.00 $83 20 $1,660 15 $1,245 15 $1,245

Challenge Assessment Form

Collect records 

and conduct a 

waste assessment 

OR account for 

annual efforts 1.75 3.50 5.25 $452 105 $9,030 184 $15,803 263 $22,575

Review records to 

assess progress 0.25 0.25 0.50 $46 10 $920 18 $1,610 25 $2,300

Set Goals 0.50 1.75 2.25 $185 45 $3,690 79 $6,458 113 $9,225

Complete/

Transmit Form 0.25 1.00 1.25 $102 25 $2,030 44 $3,553 63 $5,075

Respond to EPA 

Questions 0.25 0.75 1.00 $83 20 $1,660 35 $2,905 50 $4,150

SUBTOTAL 3.00 7.25 10.25 $867 205 $17,330 359 $30,328 513 $43,325

Costs to Partners

Total Cost to All 

Partners 225 $18,990 374 $31,573 528 $44,570

Assumptions

Management rate: $110/hr

Technical rate: $74/hr

New Challenge participants: 15/yr

Challenge participant totals: Y1=20, Y2=35, 

Y3=50
33

7(d) Estimating Agency Burden and Costs for Challenges

Table 12 (below) presents the estimated Agency burden hours and costs associated with 

administering WasteWise Challenges. Other direct costs (copying, printing, telephone, 

and mailing expenses) are also included. EPA based its burden estimates on 17 years of 

experience managing the WasteWise program and interacting with partners. EPA's 

burden estimate uses the highest cost scenario of running a Challenge by assuming that 

each Challenge will require separate and unique Challenge Registration and Annual 

Assessment Forms and that the Agency will need to provide technical assistance and 

QA/QC of reported data for each Challenge participant. EPA used the same rates and 

assumptions for hourly rates as in the calculation of Agency burden in Section 6(c).

Table 12: Annual Estimated Agency Burden and Cost for a Single Challenge

Avg. 

Hourly 

Rate

Labor Other Direct 

Costs

Total Costs

Hours Costs

Challenge Registration Form

Maintain 

Online Form 

and Database

$96 0 $0 $0* $0*

Answer 

Questions

$96 25 $2,400 $100 $2,500

Subtotal 25 $2,400 $100 $2,500

Challenge Assessment Form

Maintain 

Online Form 

and Database

$96 0 $0

Answer 

Questions

$90 50 $4,500 $200 $4,700

QA/QC Data $96 50 $4,800 $200 $5,000

Subtotal 100 $9,300 $400 $9,700

Cost to EPA

Total Cost 150 $11,700 $500 $12,200

*There are no additional costs for maintaining the online form or database for the 

Challenge beyond the standard costs of the program’s online database hosting and 

maintenance included in section 6(c).