1 **INFORMATION COLLECTION REQUEST**

**for GREEN PO**  **W ER PARTNERSHIP AND COMBINED**  **HEAT AND POWER PARTNERSHIP**  **EPA ICR NUMBER 2173.02 OMB CONTROL NUMBER 2060**  **- 0578**  **Note: This previously -** **approved ICR is provided as a reference for**  **the first FR notice**  **of this ICR renewal (2012)**  **. This ICR will be revised, where noted in the document, prior to submission to OMB.** 2 **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 C ombined H eat and P ower (CHP) Partnership (Renewal) EPA I CR No. 2173.02, OMB Control No. 2060
- 0578 **1(b) Short Characterization/Abstract**  In an effort to aid implementation of then President George W. Bush’s May 2001 National Energy Strategy , as well as President George W. Bush’s February 2002 Climate Change Strategy , EPA launched two new partnership programs with industry and other stakeholders: the GPP an d the CHP 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 co llect 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 collec t 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 deve lopment 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 CHP3

projects, and to determine progress in meeting the programs’ national energy and GHG reduction goals. This information collection will assist the GPP in increasing demand for the use of qualifying renewable energy sources for power generation thereby reducing GHG emissions. The information 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 database s of GPP or 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 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. 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 a s 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 updat es to existing information through a Partner Yearly Report. Existing CHP P Partners with ongoing CHP project development activities review and update a CHPP Partners Project Data Form every ye ar. Some CHPP Partners , such a s certain end
- users and city /stat e 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 collect ed, 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. Onl y if the information is incorrect or out of date will the recipients b e required to4

provide updated or additional information. To further reduce burden, EPA provide s 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. **3(b) Public Notice Required Prior to ICR Submission to**  **OMB** On October 31, 2008, in compliance with the Paperwork Reduction Act of 1995, EPA solicited public comments on the I CR through an announcement in the Federal Register ( 73 FR 64941). EPA received no comments. **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 associate d 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 e ither 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 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. **3(d) Effects of Less Frequent Collection**  The Partnership Agreement or LOI are submitted once b y organizations that choose to become Partners of the GP P 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 ye ar. These differences in reporting requirements reflect the varying5

dy namics 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 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. **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 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 Stores6

**NAICS SIC**  **Description** 323110 2752 Print shops 621111 8093 Offices of Phy sicians 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 a Given 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 supplier s 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 comp anies (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
. 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 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, manufacturing7

**NAICS SIC**  **Description** 541512 7373 Information management computer systems integration design services 541614 8742 Manufacturing operations improvement consulting services **CHP project prom oters 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 -**  **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 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**  **(i) Data Items, Including Recordkeeping Requirements**  **GPP** . Information will be collected through the Partnership Agreement and Partner Yearl y Report, as well as through clarification follow
- ups and calls or e
- mails as needed. Each activity is described below. The Partnership Agreement request s 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;8

• 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 ty pe of green power product delivered (utility product, renewable energy certificates , or on - site generation), ty pe of renewable resource ; and

• Q uestions about product certification status and contract dates
. The GPP Partner Yearl y Reports collect or update the following information :

• Updates to l iaison information listed above;

• Updates to c ommitment details, including total annual energy consumption, annual green power commitment;

• Updates purchase details such as retailer name, the ty pe of green power product delivered (utility product, renewable energy certificates , or on - site generation), ty pe 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 availa ble 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. 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 twenty
- five largest green po wer 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 LO I and the CHPP Partners Project Data F orm , 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 ;

 Organizatio n CHP
- related service or activity ; and9  Organization web site address and/or CHP
- related W eb page
. CHPP Partner s Project Data Forms are used to collect information on completed or planned CHP projects on a ye arl y basis , and will be c ompleted 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;

• Ty

pes 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 previously
submitted 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. 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 Pro jects 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 ye ar length of time the green power purchase must be completed b y will be updated to read as follows: "Buy green power that meets or exceeds Partnership requirements within six months of signing this Partnership Agreement."10

**(ii) Respondent Activiti** **es** 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 -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 ;

• S ubmit the yearl y report (or CHP project spreadsheet) 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 provide information to the GPP or CHPP via the Web site, an e - mail, 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 on the aspect of the information collection that the Agency has received. In receiving the Partnership Agreement or LO I for either the GPP or CHPP , the Agency will:

• Review the informati on provided;

• Enter the information into a database; and

• F ile the form. **(ii) Agency Activities for**  **GPP** Agency activities specific to the GPP will depend on the ty pes of activities the Agency will initiate and receive. In requesting and receiving the info rmation through a Partner Yearl y11

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 mail 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 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**  Agency ac tivities 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:

• P repare 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

• F ile the form. In requesting and receiving information on ongoing project development activities through a CHP project spreadsheet already populat ed with information provided on a Partner’s initial project reporting form or most recent project spreadsheet, the Agency will, once a ye ar:12

• P opulate 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

• F ile the spreadsheet. 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 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 can be downloaded from the appropriate Web site and returned to EPA either b y fax or mail, or submitted electronicall y. 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 Yearl y 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 Fl**  **exibility**13

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 electronicall y. As discussed above, for both Partnership programs EPA pre
-populates Yearl y 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 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 30 percent of existing Local Government Partners are in cities or counties with populations less than 50,0 00, which is the threshold for small entities within the public administration sector. GPP assumed that all State Government Partners are not classified as s mall 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 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, fol lowing 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 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 . This baseload 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 its14

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 P o rtable Document Format (PDF) version of the Partnership Agreement that improves readability, and thereb y reduces the frequency of Agency follow up with Partners
. EPA expects that some CHPP Partners are small e ntities. 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 as sumed 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 19 NGO partners. 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 b y thes e partners as an additional gauge of whether the project developer is a small business or not. In most cases, if the project developer reviewed by the CHPP had zero projects, it was assumed to be a small business. At the end of 2008, the CHPP expects to have 62 project developer partners, so 16 were evaluated for small business applicability . Of the 16 project developers evaluated, three were categorized as small businesses, representing 18.75 percent. Applying this percentage to those companies not reviewe d, the CHPP estimates that 12 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. In15

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 2008, the CHPP expects to have 51 project developer partners, so 13 were evaluated for small business applicability . Of the 13 consultants/engineers evaluated, three were categorized as small businesses, representing 23 percent. Appl yi ng this percentage to those companies not reviewed, the CHPP estimates that 12 consultant/engineer partners are small businesses. For ESCO partners, the CHPP reviewed Web sites and organization descriptions for all of the partners. At the end of 2008, the CHPP expects to have six ESCO partners. Of the six ESCOs evaluated, one was categorized as a small business due to it employing only 60 employees. For financier partners, the CHPP reviewed Web sites 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 2008, the CHPP expects to have 11 financier partners. Of the 11 financiers evaluated, two were categorized as a small business because they employ less than 50 employees. 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 ye ars 2009
- 2011 will be similar to the di stribution analy zed 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 year s 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. **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 upon16

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 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**  In order to obtain accurate hourly burden and cost estimates, EPA consulted with six 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 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 ye ar of the collection. Table 3 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**17

Respondent labor rates came from direct consultations with three current GPP Partners and three current CHPP Partners , as discussed in section 6(a) . These consultations did not include benefits. For private
- sec tor respondents, a loaded labor rate to reflect benefits and overhead for the respondent organizations was calculated b y appl yi ng a 110% factor to the average of the base rates received from the consultations. For GPP Partners, l oaded rates are $1 23
. 47 for legal staff, $ 109
. 47 for managerial staff, $ 8 9
. 29 for technical staff, and $3 9
. 05 for clerical staff. For CHPP Partners, loaded rates are $114.85 for legal staff, $91.90 for managerial staff, $81.44 for technical staff, and $38.62 for clerical staff. 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 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 $ 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 o verhead) of $82.88 for managerial staff, $ 52.60 for technical staff, and $2 0.13 for clerical staff. To derive these estimates, EPA used the “Salary Table 200 8
- GS Salary

Table of Annual Rates by Grade and Step” dated January 2008, from the Department of Personnel Management. For purposes of this I CR, EPA assigned staff the following government service levels:

• Managerial Staff
- GS
- 15, Step 5 $82.88 ($51.80 +60% OH)18

• Technical Staff
- GS
- 13, Step 1 $52.60 ($3 2.88+60% OH)

• Clerical Staff
- GS
- 5, Step 1 $20.13 ($12.58+60% OH)

**Table 2**  **: Summary of Agency Burden 200**  **9 2**  **010 2011**  **Total Annual**  **Average** Hours 2,470 2,889 3,307 8,666 2,889 Cost $122,079 $142,056 $162,033 $426,168 $142,056 **6(d) Estimating the Respondent Universe**  **GPP** . A total of 1 , 040 GPP Partners is expected by the end of 2008
. 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 246 new Partners will join the program each ye ar in 2009, 2010 , and 2011. Of these new 246 Partners joining each ye ar , EPA expects that 219 will be from the private sector and 27 from local and state governments, as is consistent with the Partnership’s current makeup
. Each new Partner is required to complete and submit a Partnership Agreement form, and all participating Partners are expected to fill out or update the Partner Yearly Report, starting the ye ar after they

join
. The ave rage annual number of respondents over three ye ars is 1, 532 . The number of respondents in each of the three ye ars of this information collection and the average over the 3
- ye ar period is shown in Table 3 in Section 6(e) of this supporting statement. **CHPP** . A total of 2 0 6 Partners is expected b y the end of 200 8. EPA anticipates 30
- 40 new Partners will join the program each year in 200 9 , 20 10 , and 20 11 . Of these new respondents, it is assumed that there are 6 to 7 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/Local/T ribal governments per year. Each of th e 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 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 proje ct information and provide updates every year in a project spreadsheet starting in the year they

join the Partnership.19

The average annual number of respondents over three ye ars is 2 6 2 . 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 3
. **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 3 and 4
. The total annual burden, averaged over the three
- ye ar period, is 4 , 862 hours and $ 433,302 per year for respondents and 1, 921 hour s and $ 90,884 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 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 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
- ye ar period, is 82 hours and $ 4,818 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 as sociated with CHPP
. The results are summarized in Tables 3 and 4
. The total annual burden, averaged over the three
- ye ar period is 9 61 hours and $ 8 3 , 816 for Partners, and 968 hours and $ 51,172 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 ye ars 2 and 3. The burden per respondent is similar in al l 3 years. In ye ars 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 be20

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 graduall y 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. 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 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 5,823 hours and $ 517,119 per ye ar for respondents and 2,889 hours and $ 142 , 056 per year for the Agency
. Tables 3 and 4 show the breakout between labor costs and O&M costs. The burden estimates reflect an average of 1,794 respondents per ye ar. The average annual burden per respondent is 3. 2 5 hours and $ 28 8 per ye ar.21 **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* 1,286 1,532 1,778 4,596 1,532 Number of Company/Institutional Respondents 1,138 1,357 1,576 4,071 1,357 Number of Local/State Respondents 148 175 202 525 175 Hours 4,160 4,862 5,564 14,586 4,862 Labor Costs $ 366,648 $ 428,706 $ 490,765 $ 1,286,119 $ 428,706 O&M Costs $ 3,858 $ 4,596 $ 5,334 $ 13,788 $ 4,596 TO TAL Costs $ 370,506 $ 433,302 $ 496,099 $ 1,299,907 $ 433,302 **CHP Partnership Program** Number of Respondents 234 262 290 786 262 Number of Company/Institutional Respondents 232 260 288 780 260 Number of State Respondents 2 2 2 6 2 Hours 8 61 9 6 0 1,0 6 1 2, 882 9 61 Labor Costs $74, 382 $8 2 , 942 $91, 515 $248,839 $82,946 O&M Costs $786 $870 $954 $2,610 $870 TO TAL Costs $75, 168 $8 3 , 812 $92, 469 $25 1 , 449 $8 3 , 816 **Combined Totals for Both Programs** Number of Respondents 1,520 1,794 2,068 5,382 1,794 Hours 5,021 5,822 6,625 17,468 5,823 Labor Costs $ 441,030 $ 511,648 $ 582,280 $ 1,534,958 $ 511,653 O&M Costs $ 4,644 $ 5,466 $ 6,288 $ 16,398 $ 5,466 **TOTAL Costs** $ 445,674 $ 517,114 $ 588,568 $ 1,551,356 $ 517,119 Average annual hours per respondent
- - - - 3.25 Average annual costs per respondent
- - - - $ 288 *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 1,308 1,558 1,808 4,674 1,558 Hours 1,605 1,921 2,236 5,762 1,921 Labor Costs $76,311 $90,884 $105,456 $272,651 $90,884 O&M Costs $ 0 $ 0 $ 0 $ 0 $ 0 TO TAL Costs $76,311 $90,884 $105,456 $272,651 $90,884 **CHP Partnership Program** Number of Respondents 234 262 290 786 262 Hours 866 968 1,071 2,90 5 96822 **Year 1 Year 2**  **Year 3 Total**  **Annual Average** Labor Costs $45,768 $51,172 $56,577 $153,517 $51,172 O&M Costs $0 $0 $0 $0 $0 TO TAL Costs $45,768 $51,172 $56,577 $153,517 $51,172 **Combined Totals for Both Programs** Number of Respondents 1,542 1,820 2,098 5,460 1,820 Hours 2,470 2,889 3 , 307 8,666 2,889 Labor Costs $12 2 , 0 79 $142,056 $162,033 $426,168 $142,056 O&M Costs $0 $0 $0 $0 $0 **TOTAL Costs** $122,079 $142,056 $162,033 $426,168 $142,056 **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 22 26 30 78 26 Hours 71 82 94 247 82 Labor Costs $4,083 $4,740 $5,397 $14,220 $4,740 O&M Costs $66 $78 $90 $234 $78 TO TAL Costs $4,149 $4,818 $5,487 $14,454 $4,818 **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 22 26 30 78 26 Hours 71 82 94 247 82 Labor Costs $4,083 $4,740 $5,397 $14,220 $4,740 O&M Costs $66 $78 $90 $234 $78 **TOTAL Costs** $4,149 $4,818 $5,487 $14,454 $4,818 Average annual hours per respondent 3.15 Average annual costs per respondent $185 **6(f) Reasons for Change in Burden**  Under this renewal ICR, the average annual total respondent burden is 5,823 hours
. The 200 4 IC R average annual respondent burden was 3,980 hours per ye ar. Since the last ICR renewal, both the GPP and CHPP have introduced program efficiencies to reduce program burden and simplified collection for ms into pre
-populated spreadsheets or documents . As a result of these changes, the average number of hours per Partner has decreased from 3.4 hours to 3. 25 hours , but the total hourly burden for Partners still increased because of an23

increase in the number of Partners . For perspective on the magnitude of Partner growth, the number of Partners at the end of 200 4 was 8 65, whereas by year - end 2008 their will be an estimated 1,308
. **6(g) Burden Statement**  The annual public reporting and recordkeeping burden for this collection of information is estimated to average 3 .25 hours per respondent. The average number of annual burden hours per ty pe 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 Yearl y 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 LO I, GPP Partner Yearl y 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 I CR 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 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 to access those documents in the public docket that are available 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, Wa shington, 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.**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 L ocal & State Go vernment Respondent Burden for Year 1 A
- 5 Green Power Partnership L ocal & State Government Respondent Burden for Year 2 A
- 6 Green Power Partnership L ocal & 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 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 fo**  **r 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 **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