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INFORMATION COLLECTION REQUEST

for

EPA’S GREEN POWER PARTNERSHIP AND 

COMBINED HEAT AND POWER PARTNERSHIP

EPA ICR NUMBER 2173.05 (Renewal)

OMB CONTROL NUMBER 2060-0578
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SUPPORTING STATEMENT A

1. IDENTIFICATION OF THE INFORMATION COLLECTION

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

EPA’s Green Power Partnership (GPP) and Combined Heat and Power (CHP) Partnership

(Renewal), EPA ICR No. 2173.05, OMB Control No. 2060-0578.

1(b) Short Characterization/Abstract

In 2001, EPA launched two new partnership programs with industry and other 

stakeholders: the Green Power Partnership (GPP) and the Combined Heat and Power Partnership 

(CHPP). These voluntary partnership programs encourage organizations to invest in clean, 

efficient energy technologies, including renewable energy and combined heat and power. EPA 

collects information from GPP and CHPP Partners to assess the success of these programs in 

achieving their national energy and greenhouse gas (GHG) reduction goals.

EPA has developed this ICR to obtain authorization to collect information from 

organizations participating in the GPP and CHPP. Organizations that join these programs 

voluntarily agree to the following respective actions: (1) designating a GPP or CHPP liaison and 

filling out a Partnership Agreement or Letter of Intent (LOI), respectively; (2) for the GPP, 

reporting to EPA on a annual basis their progress toward their green power commitment via a 3-

page reporting form; (3) for the CHPP, reporting to EPA information on their existing CHP 

projects, new project development and other CHP-related activities. Partners are organizational

entities that have volunteered to participate in either Partnership program.

2. NEED FOR AND USE OF THIS COLLECTION

2(a) Need/Authority for the Collection

EPA needs to collect the information in the Partnership Agreement or LOI to formally

establish participation in the GPP or CHPP program and to obtain general information about new 

Partners. Additional information collected through information forms is needed to allow EPA to 

track GPP Partner progress toward meeting their commitments, to enable the programs to 

facilitate and provide assistance to encourage green power purchases and the implementation of 

CHP projects, and to determine progress in meeting the programs’ national energy and GHG 

reduction goals. This information collection will assist the GPP in increasing demand for the use 

of qualifying renewable energy sources for power generation, thereby reducing GHG emissions. 

The information also will help the CHPP to increase the use of more efficient, cleaner power 

generation and reduce GHG emissions.
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Participation in the GPP and CHPP is voluntary. Program participants agree to provide 

EPA with the requested information.

2(b) Practical Utility/Users of the Data

EPA uses the information submitted in the Partnership Agreement or LOI to update its 

databases of GPP and CHPP Partners. The databases serve as a source of general information and 

a contact list. EPA uses the information submitted in additional forms to monitor the progress of 

current participation and projects and to identify new opportunities. EPA also uses the data to 

prepare reports on GPP and CHP projects and progress as well as to determine the GHG 

reductions achieved by the programs. General information on the Partners, green power, and 

CHP also is provided on the respective program websites, making it available to other Partners as 

well as the public.

3. NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Non-duplication

For new Partners, the information to be collected previously has not been gathered by

EPA or any other Federal Agency. Existing GPP Partners provide updates to existing information 

through a Partner Yearly Report. Existing CHPP Partners review and update a CHPP Partners 

Project Data Form every year. 

For existing Partners with both programs, some of the information required is available in 

the existing databases from previous submittals. To avoid requesting information that already has 

been collected, forms sent to existing Partners are pre-populated with previously submitted

information from the database. Recipients of the forms are asked to review the information 

provided. Only if the information is incorrect or out of date will the recipients be required to 

provide updated or additional information. To further reduce burden, EPA provides CHPP

Partners who have CHP systems or ongoing project development activities with a CHPP Partners 

Project Data Form populated with previously submitted information that they can review and 

revise electronically rather than filling out a new form. 

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

On December 28, 2011, in compliance with the Paperwork Reduction Act of 1995, EPA 

solicited public comments on the ICR through an announcement in the Federal Register

(Volume 76, Number 249). EPA received two comments. One comment suggested that the 

burden be reduced through use of on-line interactive reporting forms. EPA will investigate the 
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possibility of implementing this suggestion. The second comment suggested that EPA expand the 

information collected to include actual output of a subject boiler (instead of the design capacity as 

is now collected) and information about secondary fuel types, when applicable. EPA does not 

believe the benefit of collecting this information would justify the added burden on CHPP 

Partners. 

3(c) Consultations

In 2004 EPA consulted with three GPP Partners and three CHPP Partners regarding the 

burden of information collection for the programs. The contacted Partners were provided copies 

of the information collection forms and asked to provide estimates of the associated hourly labor 

burden. Labor wage rates from the Bureau of Labor Statistics (BLS) were provided for reference,

and EPA requested comments on whether these labor rates were appropriate. The Partners all 

provided labor hour estimates of each activity and either provided labor rates or indicated that the 

BLS rates were representative. Generally, the estimates provided by the Partners were similar and

were consistent with EPA expectations of the labor burden.

In 2008 EPA consulted with three GPP Partners and three CHPP Partners regarding the 

burden of this information collection. The contacted Partners were provided copies of the 

information collection forms, estimates of the labor burden derived from Partners responses in 

2004, and labor wage rates from the Bureau of Labor Statistics (BLS). EPA requested comments 

on whether the labor burden estimates and labor rates were appropriate. Generally, the estimates 

provided by the Partners were similar and were consistent with the estimates provided by EPA. 

EPA averaged Partner responses for the labor burden estimates and labor rates for use in this ICR 

renewal.

In 2012 EPA consulted with four GPP Partners and four CHPP Partners regarding the 

burden of this information collection. The contacted Partners were provided copies of the 

information collection forms, estimates of the labor burden derived from Partners responses in 

2008, and labor wage rates from the Bureau of Labor Statistics (BLS). EPA requested comments 

on whether the labor burden estimates and labor rates were appropriate. Generally, the labor rate 

estimates provided by the Partners were similar and consistent with the estimates provided by 

EPA, whereas the hourly burdens reported by Partners were lower than estimated. EPA averaged 

Partner responses for the labor burden estimates and labor rates for use in this ICR renewal.
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3(d) Effects of Less Frequent Collection

The Partnership Agreement or LOI are submitted once by organizations that choose to 

become Partners of the GPP or CHPP. To allow EPA to remain current on Partner participation 

and determine if green power purchase commitments are being met, GPP Partners are asked to 

update an annual report. All CHPP Partners review and update their existing project information,

provide updates on new projects, and describe their CHP related activities every year. Partners 

of both programs may also update company and contact information periodically via the

respective partnership websites. EPA believes that any reduction in the frequency of this 

information collection would impede efforts by EPA to evaluate results of the programs, facilitate 

green power purchases and CHP project implementation, and respond in a timely manner to needs 

of the Partners.

3(e) General Guidelines

This information collection request was prepared in compliance with OMB’s and EPA’s 

guidelines for ICR preparation. 

3(f) Confidentiality

Participation in the GPP and CHPP is voluntary. Participants are not asked to reveal 

Confidential Business Information (CBI). Additionally, participants will be given specific 

instructions not to provide any information that they consider confidential or to notify EPA of 

specific information that should not be publicly released. 

3(g) Sensitive Questions

No questions of a sensitive nature are asked in any of the forms or periodic information 

updates.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondent NAICS/SIC Codes

This information collection will encompass a wide variety of respondents with most 

respondents specific to either the GPP or CHPP. 

(i) GPP Respondent NAICS/SIC codes

The GPP Partners consist of company, institutional, and public sector organizations that 

pledge to purchase a proportion of their annual electricity use from eligible renewable energy 

resources through one of three options: a utility green power product, renewable energy

certificates, or on-site generation. Companies include both privately- and publicly-held goods 
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and services industries; institutions are comprised of institutes of higher education and NGOs; and 

public sector Partners are local, state, or federal government agencies. 

Table 1. Sample GPP NAICS/SIC Industry Codes and Descriptions

NAICS SIC Description

Full-scale Partners a

611310 8221 Colleges, Universities, and Professional Schools

722110 5812 

5461 

Restaurants

522110 6081 Commercial Banking

445110 5411 Grocery Stores

323110 2752 Print shops

621111 8093 Offices of Physicians

924 9511 Public Administration of Environmental Quality Programs

92411 9631 Public Administration of Air and Water Resource and Solid Waste Management 

Programs

531210 6531 Real Estate Agencies

541110 8111 Law Offices

aGiven the breadth of industries who are currently GPP Partners, only a subset of their NAICS/SIC codes is listed to 

provide examples.

(ii) CHPP Respondent NAICS/SIC codes

The CHPP classifies its Partners into nine categories. State, Local and Tribal Partners 

include state and local energy, environmental, and economic development agencies who will 

promote CHP development in their area. The remaining nine categories are included in the 

commercial and institutional Partner group. End-user Partners comprise a broad range of 

industrial, commercial, or institutional organizations that utilize CHP technology to provide heat 

and electricity at their facilities. Equipment suppliers are involved in the manufacturing, 

supplying, or installation of CHP-related products. Other Partner categories can be classified as 

CHP project promoters and facilitators who work to create new CHP projects. These Partners 

include energy services companies (ESCOs), CHP project developers, non-government 

organizations (NGOs), financiers, and engineering consultants. Utility Partners work to provide 

end-users with fuel for their CHP projects or work to distribute electricity from CHP sources. 

The following list provides the most common NAICS/SIC codes for the various different types of 

CHPP Partners:

Table 2. Sample CHPP NAICS/SIC Industry Codes and Descriptions

NAICS SIC Description
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NAICS SIC Description

State/Local/Tribal Partners

92613 9631 Public Administration, Regulation and Administration of Communications, 

Electric, Gas, and Other Utilities

926130 9631 Public Administration, Energy development and conservation programs

9611 9611 Public Administration of General Economic Programs

924 9511 Public Administration of Environmental Quality Programs

Equipment Manufacturers

333611 3511 Turbine and turbine generator manufacturing

335999 3699 Fuel cells, electrochemical generators, manufacturing

541512 7373 Information management computer systems integration design services

541614 8742 Manufacturing operations improvement consulting services

CHP project promoters and facilitators

541690 8999 Energy consulting services

541330 8999 Engineering consulting services

523910 6153 6211 

6799

Financial Investments and Related Activities, Miscellaneous Intermediation

Utilities

221122 4911 Electric Power Distribution

221210 4923 Natural Gas Distribution

End-Usersa

325415 2834 Pharmaceutical Preparation Manufacturing

611310 8221 Colleges, Universities, and Professional Schools

322121 2611 2621 Pulp and Paper Mills (Except Newsprint Mills)

336111 3711 Automobile Manufacturing

813110 8661 Religious Organizations

331111 3317 Steel Mills

721110 7011 Hotels (Except Casino Hotels) and Motels

a There is a wide variety of entities that could install CHP projects and become CHP end users. Any facility with a 

demand for both electricity and thermal energy (i.e., steam, heating, or cooling) during most of the year and with 

access to fuels is a potential candidate as a CHPP end-user Partner. For this reason, only a subset of the end-users is 

listed to provide examples.

4(b) Information Requested

(i) Data Items, Including Recordkeeping Requirements

GPP. Information will be collected through the Partnership Agreement and Partner 

Yearly Report, as well as through clarification follow-ups and calls or emails as needed. Each 

activity is described below. 
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The Partnership Agreement requests the following information from all Partners:

• Organization name;

• Scope of entity/entities joining the Partnership;

• Total electricity use and green power commitment;

• Signature and printed name and title of authorized organization representative;

• Contact information for the organizational liaison to the GPP, including name, 

title, address, phone number, fax number and email address; 

• Purchase details such as provider name, the type of green power product and type 

of renewable resource; 

• Questions about product certification status and contract dates; and

• Motivations for joining the Partnership.

The GPP Partner Yearly Reports collect or update the following information:

• Updates to liaison information listed above;

• Updates to commitment details, including total annual energy consumption and 

annual green power commitment;

• Updates to purchase details such as provider name, the type of green power 

product delivered (utility product, renewable energy certificates, or on-site 

generation) and type of renewable resource; 

• Updates to product certification status and contract dates; and

• Short profile paragraph addressing Partner’s green power commitment. 

The company profile is available on the GPP website. Partners may submit corrections or 

updates to their profile via the website or electronically at any time. EPA also will place followup calls to clarify any unclear information submitted by Partners.

Occasionally, EPA may request technical information in addition to the standard forms. 

This information will be requested on a voluntary basis from a subset of GPP Partners. For 

instance, information may be requested from the fifty largest green power purchasers in order to 

feature them on the GPP website and Top Partner Rankings, which are updated quarterly. 

Requested information may also be used to target communications and outreach efforts more 

effectively.
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CHPP. Information will be collected through the LOI and the CHPP Partners Project 

Data Form as well as through clarification follow-up calls or emails as needed. The LOI requests 

the following information from all new Partners:

 Organization name;

 Designated CHPP Partner Liaison’s contact information;

 Organization CHP-related service or activity; 

 Organization website address and/or CHP-related web page; and 

 Organization description.

CHPP Partners Project Data Forms are used to collect information on completed or planned CHP 

projects and other CHP-related activity on a yearly basis. The requested information includes:

• Project Owner;

• Project Name and address;

• Project information including market sector, start-up date, fuel type, annual 

operating hours, average net power output, percentage of electricity sold offsite or 

to grid and percentage of thermal output sold offsite;

• List of each prime mover, including size, fuels and emission controls;

• Types and applications of thermal output;

• Contact information including the company name, contact name, phone number 

and date submitted; 

• Project team information including the engineer, prime contractor, project 

developer and thermal host; and

• Other CHP-related activity.

After the first submittal, EPA will send the Partner a CHPP Partner Project Data Form

containing all previously-submitted information for the Partner to review and update annually.

Company profiles and contact information will be available on the CHPP website. 

Partners may submit corrections or updates via the website at any time. EPA also will place 

follow-up calls to clarify any unclear information submitted by Partners.

Participation in GPP and CHPP does not require any records to be kept, although Partners 

likely will keep file copies of the LOI and CHPP Partner Project Data Forms submitted to EPA.

(ii) Respondent Activities
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The respondent activities depend on the aspect of the information collection to which they

are responding. In completing the Partnership Agreement or LOI, respondents will:

• Review the form;

• Complete the form;

• Sign and submit the form electronically or via fax or mail to EPA; and 

• File a copy of the form.

In completing the pre-populated GPP Partner Yearly Report or the pre-populated CHPP Partner 

Projects Data Form, respondents will:

• Read the forms and instructions;

• Update the pre-populated report or form with new information where necessary;

• Submit the yearly report (or CHP project form) electronically or via fax or mail to 

EPA; and 

• File a copy of the form.

In replying to or initiating an information update or clarification, respondents will:

• Gather information; and

• Provide information to the GPP or CHPP via the website, an email, or a telephone 

interview.

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

(i) Agency Activities for the GPP’s Partnership Agreements and CHPP LOIs

Agency activities associated with this information collection depend upon the aspect of 

the information collection that the Agency has received. In receiving the Partnership Agreement 

or LOI for either the GPP or CHPP, the Agency will:

• Review the information provided;

• Enter the information into a database; and

• File the form.

(ii) Agency Activities for GPP
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Agency activities specific to the GPP will depend upon the types of activities the Agency

will initiate and receive. In requesting and receiving the information through a Partner Yearly 

Report Form sent to Partners one year after they join the Partnership and annually thereafter, the 

Agency will:

• Prepare pre-populated partner data and email the Partner Yearly Report annually;

• Receive and review the information provided on completed forms;

• Enter the information into a database; and

• File the form.

In initiating information updates and follow-ups, the Agency will:

• Call or email Partners;

• Request updated information or clarification on Partnership Agreements or Partner 

Yearly Report Forms by telephone or email;

• Request additional technical information, as needed, from a subset of GPP

Partners; and

• Revise data in the database based upon these updates.

In receiving information updates via the website, the Agency will:

• Review the data received through the GPP website; and

• Revise data in the database based upon the updates.

(iii) Agency Activities for CHPP

Agency activities specific to the CHPP also will depend upon the types of activities the 

Agency will initiate and receive. In requesting and receiving the information on CHP projects 

through an information form sent to Partners within the same year they join the Partnership, the 

Agency will:

• Prepare and email the CHPP Partner Projects Data Forms;

• Receive and review the information provided on completed forms;

• Enter the information into a database; and

• File the form.

In requesting and receiving information on ongoing project development activities, 

updates of existing projects and other CHP-related activities through a CHPP Partner Projects
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Data Form pre-populated with information provided on a Partner’s initial project reporting form 

or most recent project, the Agency will, once a year:

• Populate the CHPP Partner Projects Data Form with previously-submitted 

information, which is contained in the CHP project database;

• Email the pre-populated CHPP Partner Projects Data Forms to the appropriate 

Partners;

• Receive and review any updates provided from the Partner on the Data Forms;

• Enter updated information into a database; and

• File the CHPP Partner Projects Data Form.

In initiating information updates and follow-ups, the Agency will:

• Call or email Partners;

• Request updated information or clarification on CHPP Partner Projects Data 

Forms; and

• Revise data in the database based on the updates.

In receiving information updates via the website, the Agency will:

• Review the data received on the CHPP website; and

• Revise data in the database based on the updates.

5(b) Collection Methodology and Management

The methods selected for this information collection are chosen based on efficiency and 

minimization of burden for respondents and EPA. The respective Partnership Agreement and LOI 

can be downloaded from the respective websites and returned to EPA electronically or by fax or 

mail. General Partner information will be posted on the GPP or CHPP websites where it can be 

reviewed for accuracy by the Partners and revised if necessary. Annual reporting forms are

available for Partners electronically on each website and can be returned electronically or by fax or

mail. In addition, the GPP sends pre-populated Yearly Reports to Partners each year containing the 

information previously submitted. Partners need only to review the information for accuracy and 

submit any updates, thus minimizing the burden of the respondents. To further reduce burden, 

EPA will provide all CHPP Partners with a CHPP Partner Projects Data Form of previously 

submitted project data that they can review and revise electronically. All information received 
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through the forms (electronically or via hard copy) is reviewed by EPA before being entered into 

the database. 

5(c) Small Entity Flexibility

EPA expects that some GPP Partners and CHPP Partners are small entities. EPA has 

designed its approach for this information collection to minimize burden for all respondents while 

obtaining sufficient and accurate information. The data requested include only the most critical 

information and may be submitted electronically. As discussed above, EPA pre-populates Yearly

Report forms or CHPP Partner Projects Data Forms for both Partnership programs with 

information previously submitted to avoid duplication of effort and minimize the burden for 

respondents. Additionally, participation in GPP and CHPP is voluntary. Any small entity that 

finds the information collection overly burdensome is not required to participate.

EPA expects that some GPP partners are small entities. GPP determined whether Local 

Government Partners are small entities based on the population served by these government 

agencies. Approximately 33 percent of existing Local Government Partners are in cities or 

counties with populations less than 50,000, which is the threshold for small entities within the 

public administration sector. GPP assumed that all State Government Partners are not classified as 

small entities, since each State population is greater than 50,000. Likewise, GPP assumed that all 

Federal Government Partners are not small entities.

Given the large number of private sector and NGO GPP partners, EPA was not able to 

review the small entity status of each Partner individually. GPP assumed that all companies on 

Fortune magazine’s list of the top 1,000 U.S. companies by revenue are not small entities. GPP 

also assumed that all non-profit organizations are classified as small entities. For the remaining 

private sector Partners, GPP determined the small entity status of a portion of Partners, following 

the U.S. Small Business Administration’s 2010 Table of Small Business Size Standards Matched 

to North American Industry Classification System Codes. GPP reviewed company profiles and 

websites when available to help determine the selected company’s small entity status. GPP then 

compared the company’s small entity status to their total electricity use, a figure which EPA 

collects for all Partners. Using this information, EPA determined an approximate electricity

baseload under which a company could reasonably be considered a small entity. The companies 

whose small entity status was not determined were assumed to follow a similar correlation to those 
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reviewed. Following this assumption, EPA estimates that 60 percent of its private sector Partners 

are small entities. Overall, 61 percent of all GPP Partners are estimated to be small entities.

EPA has designed its approach for this information collection to minimize the burden for 

all respondents while obtaining sufficient and accurate information. 

EPA expects that some CHPP Partners are small entities. The CHPP consists of the 

following partner categories: project developer; consultant/engineering; energy service company

(ESCO); financier; utility; non-governmental organization (NGO); government; equipment 

manufacturer; and end-user. The CHPP assumed that all utilities, government partners, equipment 

manufacturers, and end-users are not small businesses. Companies of these partner types are large 

in scale and scope and are most likely not small businesses.

The CHPP assumed that all NGO partners are small businesses given they typically have a 

small number of employees and typically do not work for profit. In all, the CHPP has 17 NGO 

partners.

For project developer partners, the CHPP reviewed websites and organization descriptions 

for 25 percent of the partners. The companies whose websites were not reviewed were assumed to 

contain a similar percentage of small businesses to those reviewed. For the 25 percent of partners 

reviewed, the CHPP evaluated the number of projects developed by these partners as an additional 

gauge of whether or not the project developer is a small business. In most cases, if the project 

developer reviewed by the CHPP had zero projects, it was assumed to be a small business. At the 

end of 2011, the CHPP had 133 project developer partners, so 33 were evaluated for small 

business applicability. Of the 33 project developers evaluated, six were categorized as small 

businesses, representing 18.18 percent. Applying this percentage to those companies not reviewed, 

the CHPP estimates that 24 project developer partners are small businesses.

For consultant/engineer partners, the CHPP reviewed websites and organization 

descriptions for 25 percent of the partners. The companies whose websites were not reviewed were 

assumed to contain a similar percentage of small businesses to those reviewed. For the 25 percent 

of partners reviewed, the CHPP evaluated the number of projects developed by these partners as an 

additional gauge of whether or not the consultant/engineer is a small business. In most cases, if the 

consultant/engineer reviewed by the CHPP had zero projects, it was assumed to be a small 

business. At the end of 2011, the CHPP had 79 consultant/engineer partners, so 20 were evaluated 

for small business applicability. Of the 20 consultants/engineers evaluated, four were categorized 
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as small businesses, representing 20 percent. Applying this percentage to those companies not 

reviewed, the CHPP estimates that 16 consultant/engineer partners are small businesses.

For ESCO partners, the CHPP reviewed websites and organization descriptions for all of 

the partners. At the end of 2011, the CHPP had nine ESCO partners. Of the nine ESCOs evaluated, 

one was categorized as a small business due to it employing only 60 employees.

For financier partners, the CHPP reviewed websites and organization descriptions for all of 

the partners. In most cases, if the financier had zero projects, it was assumed to be a small 

business. At the end of 2011, the CHPP had 14 financier partners. Of the 14 financiers evaluated, 

two were categorized as a small business because they employ fewer than 50 employees.

Table 3 summarizes the small entities affected per year according to partner category. The 

numbers in Table 3 reflect the CHPP’s assumption that the distribution of small entities within 

each new partner category over the years 2012-2014 will be similar to the distribution analyzed for 

each existing partner category.

Table 3: CHPP Estimate of Small Entities for Each Respondent Category

Respondent Category New Existing

Project Developer* 4 24

Consultant/Engineer* 4 16

ESCO** 0 1

Financier** 0 2

NGO** 0 17

Utility* 0 0

Government* 0 0

Equipment Manufacturer* 0 0

End-User* 0 0

Total 9 60

* The CHPP ICR burden estimate assumes the following number of new partners for each of the years 2012-2014: 

project developer – 7; consultant/engineer –7; utility – 6; government – 2; equipment manufacturer – 5; end-user – 5

(Note: the CHPP assumed that none of the existing or new utility, government, equipment manufacturer, or end-user 

partners are small businesses).

** The CHPP ICR burden estimate assumes that there will be no new ESCO, financier, or NGO partners in years 

2012-2014.

5(d) Collection Schedule

EPA will collect general information from all new Partners through either the GPP’s 

Partnership Agreement or CHPP’s LOI, which is completed and submitted by each Partner upon 

their agreement to participate in the program. In addition, GPP Partners will be asked to complete 

a Partner Yearly Report on an annual basis on the anniversary of EPA’s receipt of the Partner’s last 

information update. In addition, a subset of GPP Partners occasionally may be asked to provide 

additional information specific to their industry sector or to an aspect of the GPP program. Once a 
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year, all CHPP Partners are asked to review and update a Partner Projects Data Form that contains 

information about CHP projects in which they are involved (regardless of the state of 

development) and about other CHP-related activity.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

In order to obtain accurate hourly burden and cost estimates, EPA consulted with eight

Partners (respondents) from the GPP and the CHPP. These responses were averaged to estimate 

the hourly burden for each activity and the labor rates. In consulting with Partners, EPA provided 

them with hourly burden estimates from the last submitted ICR as well as current labor rates from 

the Bureau of Labor Statistics. Respondents were asked if the hourly burden estimates and labor 

rates were appropriate and, if not, to provide estimates based on their experience.

The hourly burden for each activity was multiplied by the number of Partners 

(respondents) performing the activity each year to estimate the total respondent burden. In 

accordance with the Paperwork Reduction Act, Federal Partners were excluded from the burden 

estimate, although we summarize their burden in Table 7. Capital, operation and maintenance costs 

were also considered. Attachment A presents the estimated annual respondent burden and costs for 

information collection activities associated with the GPP for each year of the collection. 

Attachment A and Table 7 include burden estimates for Federal entities in the GPP, but these are 

not included as part of this Information Collection Request. Attachment B presents the estimated 

annual respondent burden and costs for information collection activities associated with the CHPP

for each year of the collection. Table 5 in Section 6(e) of this supporting statement presents a 

summary of the overall respondent burden for both the GPP and CHPP for each of the three years 

as well as the total burden and the annual average burden.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

Respondent labor rates came from direct consultations with four current GPP Partners and

four current CHPP Partners, as discussed in section 6(a). For GPP Partners loaded rates are $58.44

for legal staff, $56.94 for managerial staff, $44.11 for technical staff, and $23.01 for clerical staff. 

For CHPP Partners loaded rates are $71.15 for legal staff, $65.48 for managerial staff, $47.74 for 

technical staff, and $25.34 for clerical staff.

(ii) Estimating Capital and Operations and Maintenance Costs
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Because this information collection requires respondents to report only information that is 

already available to them, there are no capital costs. EPA does not expect that the operations and 

maintenance (O&M) costs of these programs will be significant. The only O&M costs expected 

are for postage required to return any completed forms, long distance fax charges if the forms are 

faxed instead of mailed, and costs to copy the forms if Partners wish to retain them on file. A 

submittal cost of $3 is attributed to all activities involving mailing materials to account for the use 

of trackable mail or long distance fax and copying. If Partners choose to submit forms 

electronically, their costs will be lower than estimated. The average annual O&M cost over three 

years is $6,744. 

6(c) Estimating Agency Burden and Costs

Attachments C and D present the estimated Agency burden hours and costs for the 

information collection activities associated with GPP and CHPP, respectively. Table 4 presents a 

summary of the total Agency burden for both programs. EPA estimates an average hourly labor 

cost of $93.00 for managerial staff, $78.00 for technical staff, and $52.50 for clerical staff. To 

derive these estimates, EPA used the rates charged by its support contractors to perform the 

activities covered by this ICR. 

Table 4: Summary of Agency Burden

2012 2013 2014 Total Annual Average 

Hours 3,188 3,436 3,684 10,308 3,436

Cost $224,336 $241,489 $258,647 $724,472 $241,490

6(d) Estimating the Respondent Universe

GPP. GPP had a total of 1,335 Partners at the end of 2011. EPA expects future growth to 

be constant since the number of Partners that have joined in the past few years has been steady. 

EPA anticipates that 248 new Partners will join the program each year in 2012, 2013, and 2014. 

Of these new 248 Partners joining each year, EPA expects that 220 will be from the private sector 

(including NGOs) and 28 from local and state governments, as is consistent with the Partnership’s 

current makeup. Each new Partner is required to complete and submit a Partnership Agreement 

form, and all participating Partners are expected to fill out or update the Partner Yearly Report, 

starting the year after they join. Partners who fail to meet the program’s requirements are 

suspended, yielding an anticipated average net annual growth rate of 134 Partners.
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The average annual number of respondents over three years is 1,702. The number of 

respondents in each of the three years of this information collection and the average over the 3-

year period are shown in Table 5 in Section 6(e) of this supporting statement.

CHPP. CHPP had a total of 450 Partners at the end of 2011. EPA anticipates 

approximately 30 new Partners will join the program each year in 2012, 2013, and 2014. Of these 

new respondents, it is assumed that there are 5 or 6 new Partners per year in each of the following 

categories: end-users, project developers, consulting engineers, equipment manufacturers, and 

utilities, with up to an additional two Partners belonging to State/Local/Tribal governments per 

year. Each of the new Partners is expected to fill out an LOI. All of the new Partners will 

complete the CHPP Partner Projects Data Form within the same year they join the Partnership. All 

of the existing Partners will continue to review their project information and provide updates every 

year in a project CHPP Partners Project Data Form starting in the year they join the Partnership.

The average annual number of respondents over three years is 514. The number of 

respondents in each of the three years of this information collection and the average over the 3-

year period are shown in Table 5.

6(e) Bottom Line Burden Hours and Costs

GPP. Attachments A and C show the detailed annual burden and cost to respondents and 

the Agency, respectively, for the information collection activities associated with GPP. The results 

are summarized in Tables 5 and 6. The total annual burden, averaged over the three-year period, is 

2,896 hours and $147,103 per year for respondents and 2,347 hours and $156,455 per year for the 

Agency. (See Tables 5 and 6 for these average numbers). The bottom line burden for respondents 

will be the least in year 1 and will gradually increase in years 2 and 3. This is because there are 

more Partners responding in years 2 and 3. The burden per respondent is similar in all 3 years. In 

years 1, 2, and 3, new Partners will complete a Partnership Agreement. In years 1, 2, and 3, 

existing Partners will update information in the Partner Yearly Report Form as needed. After the 

first submittal, EPA will provide the information previously submitted by existing Partners and ask 

only for updates. Similarly, the Agency burden is the least in year 1 and will increase gradually in 

years 2 and 3 as EPA has more information submittals to review and enter into the database. See 

Tables 5 and 6 for respondent and Agency burdens in each of the three years. 

Table 7 summarizes the total annual respondent burden for Federal Partners, although these 

are not included in Table 5 since, in accordance with the Paperwork Reduction Act, Federal 
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respondents are excluded from Information Collection Requests. The total annual burden for 

Federal Partners, averaged over the three-year period, is 30 hours and $2,038 per year.

CHPP. Attachments B and D show the detailed annual burden and cost to respondents and 

the Agency, respectively, for the information collection activities associated with CHPP. The 

results are summarized in Tables 5 and 6. The total annual burden, averaged over the three-year 

period is 1,905 hours and $108,950 for Partners, and 1,089 hours and $85,036 for the Agency. 

(See Tables 5 and 6 for these average numbers). The bottom line burden for respondents will be 

the least in year 1 and will increase gradually in years 2 and 3. This is because there are more 

Partners responding in years 2 and 3. The burden per respondent is similar in all 3 years. In years 

1, 2, and 3, new Partners will complete an LOI. New Partners also will report their CHP related 

activities including project data, if applicable. In years 1, 2, and 3, existing Partners will provide 

data on CHP projects and CHP related activity. EPA will provide the information previously

submitted by the existing Partners in a CHPP Partners Project Data Form and ask only for updates. 

Similarly, the Agency burden is the least in year 1 and will gradually increase in years 2 and 3 as 

EPA has more information submittals to review and enter into the database. See Tables 5 and 6 for 

the respondent and Agency burdens in each of the three years.

Table 7 summarizes the total annual respondent burden for Federal Partners, although these 

are not included in Table 5 since, in accordance with the Paperwork Reduction Act, Federal 

respondents are excluded from Information Collection Requests. The CHPP has no Federal 

Partners.

Total. Considering both the GPP and the CHPP, the combined total annual burden 

(averaged over a 3-year period) is 4,800 hours and $256,053 per year for respondents and 

3,436 hours and $241,490 per year for the Agency. Tables 5 and 6 show the breakout between 

labor costs and O&M costs. The burden estimates reflect an average of 2,216 respondents per 

year. The average annual burden per respondent is 2.17 hours and $118 per year.
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TABLE 5.

ESTIMATED TOTAL RESPONDENT BURDEN AND COST FOR GPP, CHPP, AND 

COMBINED

Year 1 Year 2 Year 3 Total Annual Average

Green Power Partnership Program

Number of Respondents* 1,568 1,702 1,836 5,106 1,702

Number of Company/Institutional 

Respondents

1,392 1,511 1,630 4,533 1,511

Number of Local/State Respondents 176 191 206 573 191

Hours 2,681 2,896 3,111 8,688 2,896

Labor Costs $131,399 $141,997 $152,593 $425,989 $141,997

O&M Costs $4,704 $5,106 $5,508 $15,318 $5,106

TOTAL Costs $136,103 $147,103 $158,101 $441,307 $147,103

CHP Partnership Program

Number of Respondents 482 514 546 1,542 514

Number of Company/Institutional 

Respondents

450 480 510 1,440 480

Number of State Respondents 32 34 36 102 34

Hours 1,790 1,904 2019 5,714 1,905

Labor Costs $100,881 $107,305 $113,751 $321,937 $107,312

O&M Costs $1,542 $1,638 $1,734 $4,914 $1,638

TOTAL Costs $102,423 $108,943 $115,485 $326,851 $108,950

Combined Totals for Both Programs

Number of Respondents 2,050 2,216 2,382 6,648 2,216

Hours 4,471 4,800 5,130 14,402 4,800

Labor Costs $232,280 $249,302 $266,344 $747,923 $249,309

O&M Costs $6,246 $6,744 $7,242 $20,232 $6,744

TOTAL Costs $238,526 $256,046 $273,586 $768,158 $256,053

Average annual hours per respondent - - - - 2.17

Average annual costs per respondent - - - - $115

*In accordance with the Paperwork Reduction Act, Federal government respondents are not included in the burden estimate in 

Table 5 because, based on its experience, GPP assumes that participating Federal facilities are not run by contractors. The burden 

on Federal government respondents is shown separately in Table 7.

TABLE 6.

ESTIMATED TOTAL AGENCY BURDEN AND COST FOR GPP, CHPP and 

COMBINED

Year 1 Year 2 Year 3 Total Annual Average

Green Power Partnership Program

Number of Respondents 1,585 1,7208 1,855 5,160 1,720

Hours 2,163 2,347 2,532 7,042 2,347

Labor Costs $144,232 $156,455 $168,677 $469,364 $156,455

O&M Costs $0 $0 $0 $0 $0

TOTAL Costs $144,232 $156,455 $168,677 $469,364 $156,455

CHP Partnership Program

Number of Respondents 482 514 546 1,542 514

Hours 1,025 1,089 1,152 3,266 1,089
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Year 1 Year 2 Year 3 Total Annual Average

Labor Costs $80,104 $85,034 $89,970 $255,108 $85,036

O&M Costs $0 $0 $0 $0 $0

TOTAL Costs $80,104 $85,034 $89,970 $255,108 $85,036

Combined Totals for Both Programs

Number of Respondents 2,067 2,234 2,401 6,702 2,234

Hours 3,188 3,436 3,684 10,308 3,436

Labor Costs $224,336 $241,489 $258,647 $724,472 $241,490

O&M Costs $0 $0 $0 $0 $0

TOTAL Costs $224,336 $241,489 $258,647 $724,472 $241,490

* The Agency burden calculations include the processing of forms submitted by Federal government respondents for GPP, 

increasing the total annual respondent community to 2.234 rather than the 2,216 listed in Table 5.

TABLE 7.

ESTIMATED RESPONDENT BURDEN FOR FEDERAL GOVERNMENT PARTNERS

Year 1 Year 2 Year 3 Total Annual Average

Green Power Partnership Program

Number of Respondents 17 18 19 54 18

Hours 28 30 31 89 30

Labor Costs $1,928 $2,038 $2,148 $6,114 $2,303

O&M Costs $51 $54 $57 $162 $54

TOTAL Costs $1,979 $2,092 $2,205 $6,276 $2,092

CHP Partnership Program

Number of Respondents 0 0 0 0 0

Hours 0 0 0 0 0

Labor Costs 0 0 0 0 0

O&M Costs 0 0 0 0 0

TOTAL Costs 0 0 0 0 0

Combined Totals for Both Programs

Number of Respondents 17 18 19 54 18

Hours 28 30 31 89 30

Labor Costs $1,877 $1,984 $2,091 $5,952 $1,984

O&M Costs $51 $54 $57 $162 $54

TOTAL Costs $1,928 $2,038 $2,148 $6,114 $2,038

Average annual hours per respondent 1.65

Average annual costs per respondent $113

6(f) Reasons for Change in Burden

Under this renewal ICR, the total annual respondent burden is 4,800 hours. The 2008 ICR 

average annual respondent burden was 5,823 hours per year. 

Since the last ICR renewal, both the GPP and CHPP have introduced program efficiencies 

to reduce program burden; and Partners have become more familiar with the annual reporting 

forms. As a result of these changes, the average number of hours per Partner has decreased from 
22

3.25 to 2.17 hours; and consequently the total hourly burden for Partners decreased despite an 

increase in the total number of Partners. 

6(g) Burden Statement

The annual public reporting and recordkeeping burden for this collection of information is 

estimated to average 2 hours per respondent. The average number of annual burden hours per type 

of response is: 1.96 hours for a Partnership Agreement (a one-time burden for GPP Partners), 2.14

hours for a Letter of Intent (a one-time burden for CHPP Partners), 1.38 hours for the Partner 

Yearly Report for the GPP, and 3.51 hours for the Partner Projects Data Form for the CHPP. 

Partners from both programs also may submit voluntary updates of simple information, 

such as contact information or company profiles, via the website. These updates take from 15 

minutes to 0.5 hours per response. A subset of Partners may participate in brief (i.e., 10-15 

minute) telephone calls with EPA to clarify questions pertaining to the Partnership Agreement or

LOI, GPP Partner Yearly Report, or CHPP Partners Project Data Form. All of these activities are 

included in the annual burden estimate.

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-OAR-2004-0501, which is available for public viewing at the Air and Radiation 

Docket and Information Center in EPA’s Docket Center (EPA/DC), EPA West, Room 3334, 1301 

Constitution Avenue, NW, Washington, DC. EPA’s Docket Center 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 the Air and 

Radiation Docket is (202) 566-1742. An electronic version of the public docket is available at

www.regulations.gov. This site can be used to submit or view public comments, access the index 

listing of the contents of the public docket, and 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 above. Also, you can send comments to the Office of Information and Regulatory

Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, 

Attention: Desk Officer for EPA. Please include EPA’s Docket ID No. EPA-HQ-OAR-2004-0501 

and OMB Control Number 2060-0578 in any correspondence.
23

ATTACHMENT A: Green Power Partnership Respondent Burden for Years 1 though 3

A-1 Green Power Partnership Private Sector Respondent Burden for Year 1

A-2 Green Power Partnership Private Sector Respondent Burden for Year 2

A-3 Green Power Partnership Private Sector Respondent Burden for Year 3

A-4 Green Power Partnership Local & State Government Respondent Burden for Year 1

A-5 Green Power Partnership Local & State Government Respondent Burden for Year 2

A-6 Green Power Partnership Local & State Government Respondent Burden for Year 3

A-7 Green Power Partnership Federal Government Respondent Burden for Year 1

A-8 Green Power Partnership Federal Government Respondent Burden for Year 2

A-9 Green Power Partnership Federal Government Respondent Burden for Year 3

ATTACHMENT B: CHP Partnership Respondent Burden for Years 1 through 3

B-1 CHP Partnership Private Sector Respondent Burden for Year 1

B-2 CHP Partnership Private Sector Respondent Burden for Year 2

B-3 CHP Partnership Private Sector Respondent Burden for Year 3

B-4 CHP Partnership State & Local Government Respondent Burden for Year 1

B-5 CHP Partnership State & Local Government Respondent Burden for Year 2

B-6 CHP Partnership State & Local Government Respondent Burden for Year 3

ATTACHMENT C: Green Power Partnership Agency (EPA) Burden for Years 1 through 3

C-1 Green Power Partnership Agency (EPA) Burden for Year 1

C-2 Green Power Partnership Agency (EPA) Burden for Year 2

C-3 Green Power Partnership Agency (EPA) Burden for Year 3

ATTACHMENT D: CHP Partnership Agency (EPA) Burden for Years 1 through 3

D-1 CHP Partnership Agency (EPA) Burden for Year 1

D-2 CHP Partnership Agency (EPA) Burden for Year 2

D-3 CHP Partnership Agency (EPA) Burden for Year 3