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INFORMATION COLLECTION REQUEST

for

GREEN POWER PARTNERSHIP AND COMBINED

HEAT AND POWER PARTNERSHIP

EPA ICR NUMBER 2173.02

OMB CONTROL NUMBER 2060-0578

Note: This is a previously approved ICR. This revised ICR Supporting Statement is provided as 

a reference for the first FR notice of this ICR renewal (2015). This ICR will be revised, where 

noted in the document, prior to submission to OMB. 
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SUPPORTING STATEMENT A

1. IDENTIFICATION OF THE INFORMATION COLLECTION

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

Reporting Requirements under EPA’s Green Power Partnership (GPP) and Combined 

Heat and Power (CHP) Partnership (Renewal) EPA ICR No. 2173.02, OMB Control No. 2060-

0578.

1(b) Short Characterization/Abstract

In 2002, 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. To 

continue to be successful, it is critical that EPA collect information from GPP and CHPP Partners 

to ensure these organizations are meeting their renewable energy and CHP goals and to assure the 

credibility of these voluntary partnership programs.

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 2-

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

projects, new project development and other CHP-related activities. EPA uses the data obtained 

from its Partners to assess the success of these programs in achieving their national energy and 

greenhouse gas (GHG) reduction goals. 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 Partner progress toward meeting their commitments, and 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 
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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 will also help the CHPP to increase the use of more efficient, cleaner power 

generation and reduce GHG emissions.

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 or 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 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. EPA uses case studies of successful CHP projects to 

demonstrate to existing and potential Partners the cost savings and environmental benefits 

associated with more efficient energy production through CHP projects. General information on 

the Partners, green power, and CHP is also provided on the respective Web sites, making it 

available to other Partners as well as the public.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION 

CRITERIA

3(a) Nonduplication

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

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

through a Partner Yearly Report. Existing CHPP Partners with ongoing CHP project 

development activities review and update a CHPP Partners Project Data Form every year. Some 

CHPP Partners, such as certain end-users and city/state programs, have no annual reporting 

requirements. 

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 has already 

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
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Partners who have ongoing project development activities with a simple spreadsheet of previously 

submitted project data that they can review and revise electronically rather than filling out a form. 

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

In 2015, EPA will be soliciting public comments on the ICR through an announcement in 

the Federal Register contained in docket number EPA-HQ-OAR-2004-0501

3(c) Consultations

In 2015, EPA will consult with three Green Power Partnership partners and three CHP 

Partnership partners regarding the burden of information collection for the programs, as the 

agency did in 2004, 2008, and 2011. EPA will follow the same consultation procedure outlined 

for 2004, 2008, and 2011. 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 2011, 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. 
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EPA averaged Partner responses for the labor burden estimates and labor rates for use in this ICR 

renewal.

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 will be asked 

to update an annual report. All CHPP Partners with ongoing project development activities, 

including all project developers, energy service companies, consulting engineers, equipment 

manufacturers, and approximately 33% of utility Partners will review their project information 

and provide updates every year. These differences in reporting requirements reflect the varying 

dynamics of the data contained in the reports for the different subcategories of Partners. Partners 

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

respective partnership Web sites. 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. 

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

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

energy resources through one of three purchasing options. Companies include both service and 

goods providing industries, institutions are comprised of institutes of higher education and NGOs, 

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

NAICS SIC Description

Full-scale Partners a

611310 8221 Colleges, Universities, and Professional Schools

722110 5812 

5461 

Restaurants

423390 5093 Automobile Manufacturing

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

928110 9711 Military bases and camps

927110 9661 Public Administration of Space Research and Technology

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 ten 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 are comprised of a broad range of 

industrial, commercial, or institutional organizations who 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), attorneys, 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. 
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The following list provides the most common NAICS/SIC codes for the various different types of 

CHPP Partners:

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

541110 8111 Offices of Lawyers

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 for a CHPP end-user Partner. For this reason, 

only a subset of the end-users is listed to provide examples.

4(b) Information Requested
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(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 e-mails as needed. Each 

activity is described below. 

The Partnership Agreement requests the following information from all Partners:

• Organization name;

• Scope of entity/entities joining Partnership;

• Total purchased electricity use and green power purchase commitment;

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

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

title address, phone number, fax number and e-mail address; 

• Purchase details such as retailer name, the type of green power product delivered 

(utility product, renewable energy certificates, or on-site generation), type of 

renewable resource; and

• Questions about product certification status and contract dates.

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, annual 

green power commitment;

• Updates purchase details such as retailer name, the type of green power product 

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

type of renewable resource; 

• Updates to product certification status and contract dates; and

• Short paragraph description of Partner’s Green Power Commitment. 

A company profile will be available on the GPP Web site. Partners may submit 

corrections or updates to their profile via the Web site or electronically at any time. EPA will also 

place follow-up 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 
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instance, information may be requested from the twenty-five largest green power purchasers in 

order to feature them on the GPP Web site. Requested information may also be used to target

communications and outreach efforts more effectively.

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

Data Form, as well as through clarification follow-up calls or e-mails 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; and

 Organization web site address and/or CHP-related Web page.

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

projects on a yearly basis, and will be completed by company or institutional Partners involved in 

planned or operational CHP projects. The requested information includes:

• Project Owner;

• Project Name and address;

• Project information including 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; and

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

developer and thermal host.

After the first submittal, EPA will send the Partner spreadsheets containing all previouslysubmitted information on planned projects for the Partner to review annually.

A company profile and contact information will be available on the CHPP Partnership 

Web site. Partners may submit corrections or updates via the Web site at any time. EPA will also 

place follow-up calls to clarify any unclear information submitted by Partners.
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Participation in GPP and CHPP does not require any records to be kept, although Partners 

will likely keep file copies of the LOI and CHPP Partner Projects Data information forms 

submitted to EPA.

The Partnership Agreement form will be updated by removing the approval expiration date, 

which is currently located in the top right corner of the form.

The Partnership Agreement form statement regarding the one year length of time the green 

power purchase must be completed by will be updated to read as follows: "Buy green power that 

meets or exceeds Partnership requirements within six months of signing this Partnership 

Agreement." 

(ii) Respondent Activities

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 spreadsheet) 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 Web site, 

an e-mail, or a telephone interview.
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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 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 Agency will:

• Review the information provided;

• Enter the information into a database; and

• File the form.

(ii) Agency Activities for GPP

Agency activities specific to the GPP will depend on 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 mail 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 e-mail;

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

Partners; and

• Revise data in the database based on these updates.

In receiving information updates via the Web site, the Agency will:

• Review the data received through the GPP Web site; and

• Revise data in the database based on the updates.

(iii) Agency Activities for CHPP
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Agency activities specific to the CHPP will also depend 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:

• Prepare and e-mail 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 through 

a CHP project spreadsheet already populated with information provided on a Partner’s initial 

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

• Populate the Partners’ spreadsheets with the project information from the most 

recent project forms or spreadsheets, which is contained in the CHP project 

database;

• Email the pre-populated spreadsheets to the appropriate Partners;

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

• Enter updated information from the spreadsheet into a database; and

• File the spreadsheet.

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 Web site, the Agency will:

• Review the data received on the CHPP Web site; 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 
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can be downloaded from the appropriate Web site and returned to EPA either by fax or mail, or 

submitted electronically. General Partner information will be posted on the GPP or CHPP Web 

site where it can be reviewed for accuracy by the Partners and revised if necessary. Information 

forms will be available for Partners electronically on each Web site and can be returned by fax, 

mail, or e-mail. In addition, the GPP will send pre-populated Yearly Reports to Partners each year 

containing the information previously submitted. Partners need only review the information for 

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

reduce burden, EPA will provide CHPP Partners who have ongoing project development activities 

with a simple spreadsheet of previously submitted project data that they can review and revise 

electronically rather than filling out a form. All information received through the forms 

(electronically or via hard copy) will be 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 includes only the most critical 

information and may be submitted electronically. As discussed above, for both Partnership 

programs EPA pre-populates Yearly Report forms or spreadsheets 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 30 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 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 
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sector Partners, GPP determined the small entity status of a portion of Partners, following the U.S. 

Small Business Administration’s 2007 Table of Small Business Size Standards Matched to North 

American Industry Classification System Codes. GPP reviewed company profiles and Web sites 

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 base load under which 

a company could reasonably be considered a small entity. This base load was different for 

companies in manufacturing industries than for companies in non-manufacturing industries. The 

companies whose small entity status was not determined were assumed to follow a similar 

correlation to those reviewed. Following this assumption, EPA estimates that 65 percent of its 

private sector Partners are small entities. Overall, 60 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. Since the previous ICR, GPP 

has strived to lessen the reporting burden on Partners by introducing reporting efficiencies, such as 

a writeable Portable Document Format (PDF) version of the Partnership Agreement that improves 

readability, and thereby reduces the frequency of Agency follow up with Partners.

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. 

For project developer partners, the CHPP reviewed Web sites and organization descriptions 

for 25 percent of the partners. The companies whose Web sites 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 also evaluated the number of projects developed by these partners as 

an additional gauge of whether the project developer is a small business or not. In most cases, if 
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the project developer reviewed by the CHPP had zero projects, it was assumed to be a small 

business. The CHPP estimates that 20 percent of the project developer partners are small 

businesses.

For consultant/engineer partners, the CHPP reviewed Web sites and organization 

descriptions for 25 percent of the partners. The companies whose Web sites 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 also evaluated the number of projects developed by these 

partners as an additional gauge of whether the consultant/engineer is a small business or not. In 

most cases, if the consultant/engineer reviewed by the CHPP had zero projects, it was assumed to 

be a small business. CHPP estimates that 23 percent of the consultant/engineer partners are small 

businesses.

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

the partners. CHPP estimates at 15 percent of the ESCO partners are small businesses.

For financier partners, the CHPP reviewed Web sites and organization descriptions for all 

of the partners. CHPP estimates at 18 percent of the financier partners are small businesses.. 

Table 1 summarizes the small entities affected per year according to partner category. The 

numbers in Table 1 reflect the CHPP’s assumption that the distribution of small entities within 

each new partner category over the years 2009-2011 will be similar to the distribution analyzed for 

each existing partner category.

Table 1: CHPP Estimate of Small Entities for Each Respondent Category

Respondent Category New Existing

Project Developer* 4 12

Consultant/Engineer* 5 12

ESCO** 0 1

Financier** 0 2

NGO** 0 19

Utility* 0 0

Government* 0 0

Equipment Manufacturer* 0 0

End-User* 0 0

Total 9 46

* The CHPP ICR burden estimate assumes the following number of new partners for each of the years 2009-2011: 

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

(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 

2009-2011.
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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 may occasionally be asked to provide 

additional information specific to their industry sector or to an aspect of the GPP program. 

Company and institutional CHPP Partners with operational projects will fill out a Partner Projects 

Data Form one time for each operational project. Certain CHPP Partners with ongoing project 

development activities will be asked to review and update a project data spreadsheet every year.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

As previously noted, EPA will consult with Partners in 2015 to re-evaluate the burden and 

cost estimates of the collection. In 2011 EPA consulted with six Partners (respondents) from the 

GPP and the CHPP to obtain accurate hourly burden and cost estimates. 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 Paper Reduction Act, Federal Partners were excluded from the burden 

estimate although we summarize their burden in Table 5. 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 5 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 3 in Section 6(e) of this supporting statement presents a 
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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 the last ICR’s direct consultations with GPP Partners 

and CHPP Partners, as discussed in section 6(a). For GPP Partners, loaded rates are $123.47 for 

legal staff, $109.47 for managerial staff, $89.29 for technical staff, and $39.05 for clerical staff. 

For CHPP Partners, loaded rates are $114.85 for legal staff, $88.30 for managerial staff, $56.40 for 

technical staff, and $21.46 for clerical staff. These labor rates will be re-evaluated in the 2015 ICR 

renewal.

For public sector respondents (Local and State Partners), EPA used the same labor rates 

used for EPA personnel (see Section 6(c)). The Labor rates for management staff of public-sector 

respondents were used to represent labor rates for legal staff of public-sector respondents.

(ii) Estimating Capital and Operations and Maintenance Costs

Because this information collection requires respondents only to report 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 $5,466. 

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 2 presents a 

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

hourly labor cost (labor plus 60% for overhead) of $88.30 for managerial staff, $56.04 for 

technical staff, and $21.46 for clerical staff. To derive these estimates, EPA used the “Salary 

Table 2015 - GS Salary Table of Annual Rates by Grade and Step” dated January 2015, from the 
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Department of Personnel Management. For purposes of this ICR, EPA assigned staff the 

following government service levels:

• Managerial Staff - GS-15, Step 5 $88.30 ($55.19 +60% OH)

• Technical Staff - GS-13, Step 1 $56.04 ($35.03+60% OH)

• Clerical Staff - GS-5, Step 1 $21.46 ($13.41+60% OH)

Table 2: Summary of Agency Burden

2016 2017 2018 Total Annual Average 

Hours 3,806 4,208 4,947 12,961 4,320

Cost $201,811 $222,237 $261,739 $685,787 $228,596

6(d) Estimating the Respondent Universe

GPP. A total of 1,555 GPP Partners is expected by the end of 2015. 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 250 new Partners will join the program each year in 2016, 2017, and 

2018. Of these new 250 Partners joining each year, EPA expects that 219 will be from the private 

sector, 27 from local and state governments, and 4 from Federal Government 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. These estimates will be re-evaluated in the 

2015 ICR renewal. 

The average annual number of respondents over three years is 2,030. The number of 

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

year period is shown in Table 3 in Section 6(e) of this supporting statement.

CHPP. A total of 473 Partners is expected by the end of 2015. EPA anticipates 30 new 

Partners will join the program each year in 2016, 2017, and 2018. Of these new respondents, it is 

assumed that there are 6 to 7 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 end-users, project developers, consulting 

engineers, and equipment manufacturers and 33% of new utility Partners will complete the CHPP

Partner Projects Data Form within the same year they join the Partnership. New State/Local/Tribal 
19

Agency Partners do not fill out project forms. All of the existing project developers, ESCOs, 

consulting engineers and equipment manufacturers, and 33% of the existing utilities will continue 

to review their project information and provide updates every year in a project spreadsheet starting 

in the year they join the Partnership.

The average annual number of respondents over three years is 535. 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 3.

6(e) Bottom Line Burden Hours and Costs

The bottom line burden hours and costs will be revised in the 2015 ICR renewal, based on 

responses from Partners. 

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 3 and 4. The total annual burden, averaged over the three-year period, is 

6,284 hours and $566,992 per year for respondents and 2,564 hours and $129,260 per year for the 

Agency. (See Tables 3 and 4 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 

only ask 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 3 and 4 for respondent and Agency burdens in each of the three years.

Table 5 summarizes the total annual respondent burden for Federal Partners, although these 

are not included in Table 3 since, in accordance with the Paperwork Reduction Act, Federal 

respondents are excluded from Information Collection Requests. The total annual burden for 

Federal Partners, averaged over the three-year period, is 38 hours and $7,296 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 3 and 4. The total annual burden, averaged over the three-year 
20

period is1907 hours and $139,717 for Partners, and 1756 hours and $99,336 for the Agency. (See 

Tables 3 and 4 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 an LOI. If a new Partner has direct involvement in CHP projects, 

they will submit project forms in the year they join. In years 1, 2, and 3, existing Partners will be 

updating information only as needed. For Partners with ongoing project development activities, 

EPA will provide the information previously submitted by the existing Partners in a spreadsheet 

and only ask 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 3 and 4 for the respondent and Agency burdens in each of the three years.

The CHPP has no Federal Partners so no burden is calculated in Table 5.

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

(averaged over a 3-year period) is 8,191 hours and $706,709 per year for respondents and 4320

hours and $228,596 per year for the Agency. Tables 3 and 4 show the breakout between labor 

costs. The burden estimates reflect an average of 2,602 respondents per year. The average annual 

burden per respondent is 3.25 hours and $275 per year.
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TABLE 3.

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* 1,784 2,030 2,276 6,090 2,030

Number of Company/Institutional 

Respondents

1,555 1,774 1,993 5,322 1,774

Number of Local/State Respondents 229 256 283 768 256

Hours 5,581 6,284 6,986 18,851 6,284

Labor Costs $497,883 $560,990 $624,098 $1,682,971 $560,990

O&M Costs $5,238 $6,014 $6,753 $18,004 $6,001

TOTAL Costs $503,121 $567,004 $630,851 $1,700,975 $566,991

CHP Partnership Program

Number of Respondents 505 535 565 1605 535

Number of Company/Institutional 

Respondents

503 533 563 1599 533

Number of State Respondents 2 2 2 6 2

Hours 1,802 1,907 2,012 5,721 1,907

Labor Costs $130,675 $138,239 $145,805 $414,717 $138,239

O&M Costs $1,375 $1,482 $1,578 $4,434 $1,478

TOTAL Costs $132,050 $139,721 $147,381 $419,151 $139,717

Combined Totals for Both Programs

Number of Respondents 2,289 2,565 2,841 7,695 2,565

Hours 7,383 8,191 8,998 24,572 8,191

Labor Costs $628,558 $699,229 $769,901 $2,097,688 $699,299

O&M Costs $6,612.42 $7,496 $8,330 $22,438 $7,479

TOTAL Costs $635,170 $706,725 $778,231 $2,120,126 $706,709

Average annual hours per respondent 3.2

Average annual costs per respondent $275

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

Table 3 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 5.

TABLE 4.

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 1,818 2,068 2,318 6,204 2,068

Hours 2,248 2,564 2,880 7,692 2,564

Labor Costs $113,642 $129,260 $144,877 $387,779 $129,260

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

TOTAL Costs $113,642 $129,260 $144,877 $387,779 $129,260
22

Year 1 Year 2 Year 3 Total Annual Average

CHP Partnership Program

Number of Respondents 505 535 563 1,603 534

Hours 1,558 1,644 2,067 5,269 1,756

Labor Costs $88,169 $92,977 $116,862 $298,008 $99,336

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

TOTAL Costs $88,169 $92,977 $116,862 $298,008 $99,336

Combined Totals for Both Programs

Number of Respondents 2,323 2,603 2,881 7,807 2,602

Hours 3,806 4,208 4,947 12,961 4,320

Labor Costs $201,811 $222,237 $261,739 $685,787 $228,596

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

TOTAL Costs $201,811 $222,237 $261,739 $685,787 $228,596

TABLE 5.

ESTIMATED RESPONDENT BURDEN FOR FEDERAL GOVERNMENT PARTNERS

Year 1 Year 2 Year 3 Total Annual Average

Green Power Partnership Program

Number of Respondents 34 38 42 114 38

Hours 105 116 128 349 116

Labor Costs $6,581 $7,296 $8,011 $21,888 $7,296

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

TOTAL Costs $6,581 $7,296 $8,011 $21,888 $7,296

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 34 38 42 114 38

Hours 105 116 128 349 116

Labor Costs $6,581 $7,296 $8,011 $21,888 $7,296

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

TOTAL Costs $6,581 $7,296 $8,011 $21,888 $7,296

Average annual hours per respondent 14

Average annual costs per respondent 192

6(f) Reasons for Change in Burden

The burden hours noted in this paragraph will be revised in the 2015 ICR renewal, based on 

responses from Partners. Under this renewal ICR, the average annual total respondent burden is 

8,191 hours. The 2011 ICR average annual respondent burden was 5,823 hours per year. 
23

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

to reduce program burden and simplified collection forms into pre-populated spreadsheets or 

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

from 3.3 hours to 3.2 hours, but the total hourly burden for Partners still increased because of an 

increase in the number of Partners. For perspective on the magnitude of Partner growth, the 

number of Partners at the end of 2008 was 1,308, whereas by year-end 2014 there was an 

estimated 2041 (GPP has 1568, and CHP has 473). 

6(g) Burden Statement

The burden statement will be revised in the 2015 ICR renewal, based on responses from 

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

is estimated to average 3.2 hours per respondent. The average number of annual burden hours per 

type of response is: 8.8 hours for a Partnership Agreement (a one-time burden for GPP); 3.5 hours 

for a Letter of Intent (a one-time burden for CHPP Partners), 2.6 hours for the Partner Yearly 

Report for the GPP, 3.94 hours for the Partner Yearly Report for the CHPP. 

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

such as contact information or company profiles, via the Web site. These updates would take from 

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

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

LOI, GPP Partner Yearly Report, or CHPP Partner project reporting. 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 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 to access those documents in the public docket that 
are available electronically. Once in the system, select “search,” then key in the docket ID number 

identified 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.
ATTACHMENT A: Green Power Partnership Respondent Burden for Years 1 through 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