1 **INFORMATION COLLECTION REQUEST**

**f or**  **EPA’S GREEN PO**  **W ER PARTNERSHIP AND**  **COMBINED HEAT**  **AND POWER PARTNERSHIP EPA ICR NUMBER**  **2173.0 5**  **(Renewal) OMB CONTROL NUMBER**  **2060 -**  **0578**2 **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 C ombined H eat and P ower (CHP) Partnership (Renewal) , EPA ICR No. 2173.0 5 , 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 collect s 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 gen eral information about new Partners. Additional information collected through information forms is needed to allow EPA to track GPP Partner progress to ward 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 renew able 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.3

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 database s of GPP and CHPP Partners. The database s 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 b y the programs. General information on the Partners, green power, and CHP also is provided on the respective program website s, making it available to o ther 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 CHP P Partners review and update a CHPP Partners Project Data Form every ye ar. 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 f orms are asked to review the information provided. Onl y 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 provide s CHPP Partners who have CHP systems or ongoing project development activities with a CHPP Partners Project Data Form populated with previousl y submitted information that they can review and revise electronicall y 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 sugges ted that the burden be reduced through use of on
- line interactive reporting forms. EPA will investigate the4

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 ty pes, 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 Partner s 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 hourl y labor burden. Labor wage rates from the Bureau of Labor Statistics (BL S) were provided for referen ce , 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 BL S rates were representative. Generall y, the estimates provided b y the Partners were similar and were consistent with EPA expectations of the labor burden. In 2008 EPA consulted with three GPP Partner s 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 l abor wage rates from the Bureau of Labor Statistics (BL S) . EPA requested comments on whether the labor burden estimates and labor rates were appropriate. Generall y, the estimates provided b y the Partners were similar and were consi stent 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 informati on 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 (BL S). EPA requested comments o n whether the labor burden estimates and labor rates were appropriate. Generall y, the labor rate estimates provided b y the Partners were similar and consistent with the estimates provided b y EPA , whereas the hourl y burdens reported b y Partners were lower than estimated . EPA averaged Partner responses for the labor burden estimates and labor rates for use in this ICR renewal.5

**3(d) Effects of Less Frequent Collection**  The Partnership Agreement or LOI are submitted once b y organizations that choose to becom e 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 p roject information , provide updates on new projects, and describe their CHP related activities every ye ar. Partners of both programs may

also update company and contact information periodically via the respective partnership website s. EPA believes that any reduction in the frequency of this information collection would impede efforts b y 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 reve al C onfidential B usiness 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 goods6

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 C HP development in their area. The remaining nine categories are included in the commercial and institutional P artner 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** 7

**NAICS SIC**  **Description State/Local/Tribal Partners**  92613 96 3 1 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 prom oters 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 -**  **Users a**  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 701 1 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 P artnership Agreement and Partner Yearl y Report, as well as through clarification follow
-ups and calls or email s as needed. Each activity is described below.8

The Partnership Agreement request s 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 ty pe of green power product and ty pe of renewable resource ;
• Questions about product certification status and contract dates ; and

• Motivations for joining the Partnership. The GPP Partner Yearl y Reports collect or update the following information:

• Updates to l iaison information listed above;

• Updates to c o mmitment details, including total annual energy consumption and annual green power commitment;

• Updates to purchase details such as provider name, the ty pe of green power product delivered (utility product, renewable energy certificates , or on - site generation) and ty

pe 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 follow
up calls to clarify

any unclear information submitted by Partners. Occasionall y, 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 quarterl y . Requested information may also be used to target communications and outreach efforts more effectivel y .9

**CHPP**. Information will be collected through the LO I and the CHPP Partners Project Data F orm as well as through clarification follow
-up calls or email s 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 w eb page ; and

 Organization description . CHPP Partner s Project Data Forms are used to collect information on completed or planned CHP projects and other CHP
- related activity on a ye arly 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;

• Ty

pes 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 annuall y. C ompany profile s 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 Partn ers likely will keep file copies of the LOI and CHPP Partner Project Data F orms submitted to EPA. **(ii) Respondent Activities** 10

The respondent activities depend on the aspect of the information collection to which they are responding. In completing the Partnership Agreement or LO I, respondents will:

• Review the form;

• C omplete the form;

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

• F ile a cop y of the form. In completing the pre -populated GPP Partner Yearly Report or the pre -populate d CHPP Partner Projects Data Form, respondents will:

• Read the forms and instructions;

• Update the pre -populated report or form with new information where necessary ;
• S ubmit the yearl y report (or CHP project form ) electronicall y or via fax or mail to EPA; and

• F ile a cop y of the form. In repl ying to or initiating an information update or clarification, respondents will:

• G ather information; and

• P rovide information to the GPP or CHPP vi a 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 Agreement**  **s and**  **CHPP LOIs**  Agency activities associated with this information collection depend up on 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 Agenc y will:

• Review the information provided;

• Enter the information into a database; and

• F ile the form. **(ii) Agency Activities for**  **GPP**11

Agency activities specific to the GPP will depend up on the ty pes of activities the Agency will initiate and receive. In requesting and receiving the information through a Partner Yearl y Report Form sent to Partners one ye ar after they join the Partnership and annually thereafter , the Agency will:

• P repare pre -populated partner data and email the Partner Yearl y Report annually ;
• Receive and review the information provided on completed forms;

• Enter the information into a database; and

• F ile the form. In initiating information updates and follow
-ups, the Agency will:

• C all or email Partners;

• Request updated information or clarification on Partnership Agreements or Partner Yearl y Report Forms b y telephone or email ;

• Request additional technical information, as needed, from a subset of GP P Partners; and

• Revise data in the database based up on 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 up on the updates. **(iii) Agency Activities**  **for CHPP**  Agency activities specific to the CHPP also will depend up on 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:

• P repare and email the CHPP Partner Projects Data Forms;

• Receive and review the information provided on completed forms;

• Enter the information into a database; and

• F ile 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 Project s12

Data Form pre -populated with information provided on a Partner’s initial project reporting form or most recent project , the Agency will, once a ye ar:

• P opulate 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 Form s to the appropriate Partners;

• Receive and review any updates provided from the Partner on the Data Form s ;
• Enter updated information into a database; and

• F ile the CHPP Partner Project s Data Form . In initiating information updates and follow
-ups, the Agency will:

• C all 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 website s and returned to EPA electronically or by fax or mail . General Partner information will be posted on the GPP or CHPP website s where it can be reviewed for accuracy

by the Partners and revised if necessary . Annual reporting forms are available for Partners electronicall y on each website and can be returned electronicall y or by fax or mail . Inaddition, the GPP send s pre -populate d Yearl y Reports to Partners each ye ar 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 Project s Data Form of previousl y submitted project data that they can review and revise electronically . All information received13

through the forms (electronically or via hard copy) is reviewed b y EPA before bein g 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 suf

ficient and accurate information. The data requested include only the most critical information and may

be submitted electronicall y. As discussed above, EPA pre
-populates Yearly Report forms or CHPP Partner Project s Data Form s 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 o verl y burdensome is not required to participate. EPA expects that some GPP p artners are small entities. GPP determined whether Local Government Partners are small entities based on the population served b y these government agencies. Approximately 3 3 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 s m all 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 p artners, 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 20 10 Table of Small Business Size Standards Matched to North American Industry Classification S ys tem C odes. GPP reviewed company profiles and website s when available to help determine the selected company’s small entity status. GPP th en 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 companie s whose small entity

status was not determined were assumed to follow a similar correlation to those1 4

reviewed. Following this assumption, EPA estimates that 6 0 percent of its private sector Partners are small entities. Overall, 6 1 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 ty pically have a small number of employees and typicall y do not work for profit. In all, the CHPP has 1 7 NGO partners. For project developer partners, the CHPP reviewed website s and organization descriptions for 25 percent of the par

tners. The companies whose website s 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 b y 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 b y the CHPP had zero projects, it was assumed to be a small business. At the end of 20 11 , 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 p roject developer partners are small businesses. For consultant/engineer partners, the CHPP reviewed website s and organization descriptions for 25 percent of the partners. The companies whose website s were not reviewed were assumed to contain a similar perc entage 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 b y the CHPP had zero projects, it was assumed to be a small business. At the end of 20 11 , the CHPP had 79 consultant/engineer partners, so 20 were evaluated for small business applicability . Of the 20 consultants/engineers evaluated, four were categorized15

as small businesses, representing 2 0 percent. Applying this percentage to those companies not reviewed, the CHPP estimates that 1 6 consultant/engineer partners are small businesses. For ESCO partners, the CHPP reviewed website s and organization descriptions for all of the partners. At the end of 20 11 , the CHPP had nine ESCO partners. Of the nine ESCOs evaluated, one was categorized as a small business due to it employing onl y 60 employees. For financier partners, the CHPP reviewed website s 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 20 11 , the CHPP had 1 4 financier partners. Of the 1 4 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 ye ars 20 12 - 201 4 will be similar to the distribution analy zed 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 1 6 ESCO** 0 1 Financier** 0 2 NGO** 0 1 7 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 year s 20 12 - 201 4 : 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 manu facturer, 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 20 12 - 201 4 . **5(d) Collection Schedule**  EPA will collect general information from all new Partners through either the GPP ’s Partnership Agreement or CHPP ’s LO I, 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 Yearl y 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 occasionall y may be asked to provide additional information specific to their industry sector or to an aspect of the GPP program. On ce a16

ye ar, 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 TH**  **E 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 Burea u of Labor Statistics. Respondent s were asked if the hourl y burden estimates and labor rates w ere appropriate and , if not , to provide estimates based on their experience . The hourl y burden for each activity was multiplied by the number of Partners (respondents) performing the activity each ye ar to estimate the total respondent burden. In accordance with the Paper work 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 ye ar 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 CHP P 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 CHP P Partners , as discussed in section 6(a) . For GPP Partn ers l oaded 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** 17

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 th ese program s will be significant. The onl y 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 cop y 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 cop ying. If Partners choose to submit forms electronically , their costs will be lower than estimated. The average annual O&M cost over three ye ars 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 hourl y 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 b y this ICR. **Table 4**  **: Summary of Agency Burden 20**  **12 2**  **01 3**  **201 4**  **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 20 11 . 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 2 48 new Partners will join the program each ye ar in 20 12 , 201 3 , and 201 4 . Of these new 2 48 Partners joining each ye ar, E PA expects that 2 2 0 will be from the private sector (including NGOs) and 2 8 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 Yearl y Report, starting the ye ar after they join . Partners who fail to meet the program’s requirements are suspended, yi elding an anticipated average net annual growth rate of 134 Partners.18

The average annual number of respondents over three ye ars is 1, 7 02 . The number of respondents in each of the three ye ars of this information collection and the average over the 3
- ye ar 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 20 11 . EPA anticipates approximately 30 new Partners will join the program each ye ar in 20 12 , 20 1 3 , and 20 1 4 . Of these new respondents, it is assumed that there are 5 or 6 new Partners per ye ar 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/Lo cal/Tribal governments per ye ar. 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 ye ar in a project CHPP Partners Project Data Form starting in the ye ar they join the Partnership. The average annual number of respondents over three ye ars is 514 . The number of respondents in each of the three ye ars of this information collection and the av erage over the 3
- ye ar 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
- ye ar period, is 2,896 hours and $ 1 47,103 per year for respondents and 2,347 hours and $ 156,455 per ye ar 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 graduall y increase in years 2 and 3. This is because there are more Partners responding in ye ars 2 and 3. The burden per respondent is similar in all 3 years. In ye ars 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 Yearl y 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 l east in year 1 and will increase graduall y in ye ars 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 ye ars. 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, Federal19

respondents are excluded from Information Collection Requests. The total annual burden for Federal Partners, averaged over the three
- ye ar period, is 30 hours and $ 2,0 38 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
- ye ar 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 graduall y in years 2 and 3. This is because there are more Partners responding in ye ars 2 and 3. The burden per respondent is similar in all 3 years. In ye ars 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 provi de 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 graduall y increase in years 2 and 3 as EPA has more information su bmittals 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 ye ar for respondents and 3, 436 hours and $ 241,490 per year for the Agency. Tables 5 and 6 show the breakout between lab or costs and O&M costs. The burden estimates reflect an average of 2,2 16 respondents per ye ar. The average annual burden per respondent is 2.17 hours and $ 11 8 per year.20 **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, 83 6 5,106 1,702 Number of Company/Institutional Respondents 1, 392 1, 511 1, 630 4,533 1, 511 Number of Local/State Respondents 1 76 1 91 20 6 573 1 91 Hours 2, 681 2,896 3,111 8, 688 2,8 96 Labor Costs $ 131,399 $ 1 41,997 $ 152,593 $ 425,989 $ 141,997 O&M Costs $ 4,704 $ 5,106 $ 5,508 $ 15,318 $ 5,106 TO TAL 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 3 2 34 36 102 34 Hours 1,790 1,904 2019 5,71 4 1,90 5 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 TO TAL 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 $ 2 66,344 $ 7 47,923 $ 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
- - - - $ 11 5 *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 1,720 8 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 TO TAL 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 1,08 9 1,15 2 3,26 6 1,08 921 **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 TO TAL 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 8 9 30 Labor Costs $1,928 $2,038 $2,148 $6,114 $2,303 O&M Costs $51 $54 $57 $162 $54 TO TAL 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 TO TAL 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 $2,0 38 $2, 148 $6, 114 $2, 038 Average annual hours per respondent 1. 65 Average annual costs per respondent $ 11 3 **6(f) Reasons for Change in Burden**  Under this renewal ICR, the total annual respondent burden is 4, 800 hours . The 200 8 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 h as decreased from22

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 typ e 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 Yearl y 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 LO I, GPP Partner Yearl y 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 provide d 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 IC R 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 ele ctronic version of the pu blic 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 avai lable electronically . Once in the s ys tem, 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, Washingto n, DC 20503, Attention: Desk Officer for EPA. Please include EPA ’s Docket ID No. EPA - HQ - OAR- 2004 - 0501 and OMB C ontrol 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 **ATTACHM E**  **NT B: CHP Partnership Respondent Burden for Years 1 through 3**  B - 1 CHP Partnership P rivate 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 (EP A) 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 **A TTACHMENT**  **D :**  **CHP Par t**  **nership 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