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SUPPORTING STATEMENT FOR

LANDFILL METHANE OUTREACH PROGRAM,

EPA INFORMATION COLLECTION REQUEST NUMBER 1849.03

November 12, 2008
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1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

This renewal information collection is entitled “Reporting Under EPA's Landfill Methane 

Outreach Program”, ICR number 1849.03.

1(b) Short Characterization/Abstract

The Landfill Methane Outreach Program (LMOP), created by EPA as part of the Climate

Change Action Plan, is a voluntary program designed to encourage and facilitate the development of 

environmentally and economically sound landfill gas (LFG) energy projects across the United

States in order to reduce methane emissions from landfills. LMOP does this by educating local 

governments and communities about the benefits of LFG recovery and use; building partnerships 

between state agencies, industry, energy service providers, local communities, and other 

stakeholders interested in developing this valuable resource in their community; and providing 

tools to evaluate LFG energy (LFGE) potential. 

To continue to be successful it is critical that LMOP gather information from its Partners

about their activities and how the program can improve its support to them. Additionally, in order 

for LMOP to improve the data quality in one of its critical program tools, the LMOP Landfill and 

Landfill Gas Energy Project database, LMOP must gather basic physical and operational data 

from municipal solid waste (MSW) landfills without LFGE projects. Improving the data quality in 

this tool will enable LMOP to identify landfills that are good candidates for LFGE projects, 

improve estimates of methane emissions from landfills, and help LMOP and its Partners prioritize

LFGE project development assistance activities.

Partners are entities that have volunteered to participate in LMOP. LMOP classifies these 

Partners into one of five categories: Community Partners, State Partners, Industry Partners, Energy

Partners, and Endorsers. There are three mechanisms for collecting information from the Partners:

 electronic memoranda of understanding (MOU);

 pre-populated Excel spreadsheets; and

 electronic periodic information updates.

In addition to collecting data from its Partners, LMOP has identified approximately 1,000 

landfills owned or operated by other organizations that are considered to have LFGE potential.

LMOP plans to initiate a one-time effort to update basic landfill physical and operational data for 

these landfills using a pre-populated Excel spreadsheet. 
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The LMOP information collection is expected to involve an average of 832 existing 

Partners and an additional 114 new Partners per year. Additionally there is a planned one-time 

information collection for 1,000 other landfill owners and operators. The average annual burden

(rounded to one decimal place) and cost per respondent are estimated to be 4.6 hours and $270.

The total annual reporting and recordkeeping burden averaged over three years is 5,885 hours and 

$344,827.

This ICR provides a comprehensive description of the information collections under

LMOP. Sections 1 through 5 of this ICR describe the specific information collections (e.g., from 

the standpoint of need, use, and respondent activities). In Section 6, EPA estimates the annual 

hour and cost burden to respondents and the Agency under these collections.

2. NEED FOR AND USE OF THIS COLLECTION

2(a) Need/Authority for the Collection

EPA needs to collect the information in the MOU to formally establish participation in

LMOP and to obtain general information about new Partners. Additional information collected

from certain types of Partners through spreadsheets is needed to allow EPA to track, facilitate, and 

encourage the implementation of LFGE projects. This information collection will assist LMOP in 

decreasing methane emissions from landfills, increasing the use of methane as a renewable energy

resource, and reducing emissions due to the burning of non-renewable energy resources such as coal 

and fuel oil.

Participation in LMOP is voluntary. The five categories of participants are:

 Community Partners;

 State Partners;

 Industry Partners (developers and non-developers); 

 Energy Partners; and

 Endorsers.

All participants, in completing the MOU, agree to provide EPA with information requested in the 

MOU and provide contact information for their LMOP coordinator. Industry Developer Partners 

agree to provide information on LFGE projects with which they have been involved. Community

Partners agree to provide information on the progress of implementing LFGE projects at their 

landfill(s).
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Additionally, EPA needs to improve the data quality in one of its critical program tools, 

the publicly available LMOP Landfill and Landfill Gas Energy Project database. This is the only

known national database of LFGE projects and landfills with potential. Basic physical and 

operational data for approximately 1,000 (MSW) landfills are either sparsely populated or 

outdated. Since the inception of LMOP in 1994 there has never been a systematic national 

outreach to update landfill data. This outreach to landfills within the LMOP Landfill and Landfill 

Gas Energy Project database tool will serve several functions:

 improve the accuracy of LMOP’s responses to inquiries about landfills and LFG

energy, in particular to help project developers and the general public identify future 

opportunities for developing LFGE projects;

 assist LMOP in identifying landfills that are good candidates for LFGE projects, 

prioritizing resources on the next generation of landfills suitable for LFGE project 

development, and reaching program goals; and 

 provide communities with information they need to assess LFGE potential at their 

landfills, communicate the benefits of LFG energy, and begin developing LFGE 

projects.

2(b) Practical Utility/Users of the Data

EPA uses information submitted in the MOU to update its database of LMOP Partners. 

The database serves as a source of general information and an electronic mailing list. EPA uses 

information in spreadsheet attachments submitted by Industry Developer Partners and 

Community Partners to monitor the progress of LFGE projects and identify opportunities for new 

projects. EPA also uses the data to prepare reports on LFGE projects and the progress of LMOP. 

EPA uses case studies of successful LFGE projects to demonstrate to existing and potential 

Partners the cost savings and environmental benefits associated with capturing and using LFG. 

General information about the Partners, operational and under construction LFGE projects, and 

landfills that may have potential for developing LFGE projects is also provided on the LMOP Web 

site, making it available to other LMOP Partners as well as the public. During EPA fiscal year

2007, LMOP processed over 100 data requests from the public that required accessing data in

the LMOP Landfill and Landfill Gas Energy Project database. 
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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. For existing Partners with LFGE projects, and outreach to 

other landfill owner and operator organizations without a LFGE project, some of the information 

required may be available in the existing LMOP database. To avoid requesting information that 

has already been collected, spreadsheets sent to existing Partners and other landfill owners and 

operators will be pre-populated with information from the database. Recipients of the spreadsheets

will be asked to review the information provided. Only if the information is incorrect or out of date 

will the recipients be requested to provide updated or additional information.

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

In compliance with the Paperwork Reduction Act of 1995, EPA solicited public comments on the 

ICR through an announcement in the Federal Register on June 3, 2008 (73 FR 31681). The 

Agency did not receive any comments on this ICR renewal. 

3(c) Consultations

In 2000, EPA consulted with fewer than nine Partners regarding the burden of this 

information collection. The following Partners were contacted to obtain burden estimates of 

LMOP activities. Since 2000, all of the information collection procedures for LMOP have 

transitioned to a more efficient, electronic, and when possible, pre-populated format. Thus, the 

burden and time associated with completing the MOU, updating landfill and LFGE project data, 

and submitting periodic updates are assumed to be less than were estimated by Partners in 2000.

Table 1: List of Partner Consultations Made in 2000

Partner Type Contact Person, Company Phone Number

Community Partner

Jim Mikolaitis, City of Tucson, Arizona, 

Department of Solid Waste Management 520-791-3175

Industry Partner, 

developer Cindy McCoy, President, Natural Power 919-876-6722

Energy Partner, utility

Kevin Watkins, Vice President, Engineering 

Pacific Northwest Generating Cooperative 503-288-1234

Energy Partner, end user

Gary Faw, Facilities Manager, Ajinimoto USA, 

Inc. 919-231-0100

State Partner

Alexander DePillis, Renewable Energy Engineer, 

Wisconsin Energy Bureau 608-266-1067
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In 2007, LMOP also contacted fewer than nine Partners on the preferred format for 

making updates to their LFGE projects and landfills in the future. LMOP provided a choice of 

using the existing online data update forms used in ICR 1849.02, or an e-mail with a prepopulated spreadsheet attachment for all of their projects/landfills. All Partners were either 

indifferent between these two options or preferred the new spreadsheet information collection 

method to the old online form.

Table 2: List of Partner Consultations Made in 2007

Partner Type Contact Person, Company Phone Number

Industry Partner, 

developer Jerry Leone, Casella Waste 607-435-9996

Industry Partner, 

developer Dawn Semple, Granger Energy 517-371-9722

Industry Partner, 

developer David Mauney, CPL Systems 337-269-4699 x1167

Industry Partner, 

developer John Bean, G2 Energy 281-222-1037

Community Partner Megan Miller, Hillsborough County, FL 813-276-2956

Community Partner Vance Kemler, City of Denton, TX 940-349-8044

In 2008, LMOP also contacted fewer than nine Partners regarding the burden of this 

information collection, considering the new methodology of collecting landfill and LFGE project 

data with pre-populated spreadsheets sent via e-mail. The Partners contacted agreed that the 

estimated burden by Partner type is what they would expect for this effort or the amount they 

expect is less than the estimate. 

Table 3: List of Partner Consultations Made in 2008

Partner Type Contact Person, Company Phone Number

Industry Partner, 

developer Jerry Leone, Casella Waste 607-435-9996

Industry Partner, 

developer David Mauney, CPL Systems 337-278-7899

Community Partner Megan Miller, Hillsborough County, FL 813-276-2956
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3(d) Effects of Less Frequent Collection

The MOU are submitted once by organizations that choose to become Partners of LMOP.

To allow EPA to remain current on LFGE projects, Industry Developer and Community Partners 

directly involved in projects will be asked to update the landfill and LFGE project data

spreadsheets annually. All Partners may also update company and contact information 

periodically. For others that own or operate landfills without a LFGE project, EPA will conduct a 

one-time information collection effort to update critical landfill data necessary for evaluating 

future LFGE project potential. EPA believes that any reduction in the frequency of this 

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

LFGE 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 LMOP is voluntary. Participants are not required to reveal confidential 

business information. Additionally, participants will be given specific instructions to not provide 

any information that they consider confidential.

3(g) Sensitive Questions

No questions of a sensitive nature are asked in the MOU, pre-populated landfill and LFGE 

project data spreadsheets, or periodic information updates.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondent NAICS Codes

This information collection will encompass a wide variety of respondents. Community

Partners include local agencies and municipalities that own landfills. State agencies involved in 

energy, air pollution, and solid waste management are represented through State Partners. Industry

Partners include engine and turbine manufacturers, engineering firms, construction companies, 

environmental consultants, and other companies involved in the logistics of developing LFGE 

projects such as law firms and financing companies. Industry Partners are further divided into two 

groups: (1) developers are organizations that facilitate, finance, and implement LFGE projects; (2) 

non-developers are manufacturers or suppliers of equipment or expertise needed to collect and 
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utilize LFG. Energy Partners include utility companies who purchase energy generated from 

landfills, power marketers, and direct end users of energy from the landfill. The end user category is 

potentially the most diverse category. Any facility located near a landfill that utilizes fuel either in 

manufacturing products or in heating the facility is a potential energy end user. Finally, Endorsers

are non-profit organizations coordinating with EPA to publicize and promote the use of LFG 

among their members or constituents. These include several trade associations representing the 

solid waste industry, public works, municipalities, and renewable energy. Table 4 provides the 

North American Industry Classification System (NAICS) code and description for the respondents.

Table 4: Respondents to Information Collection

Partner Type NAICS Code NAICS Description

Community Partners 

and State Partners 924 Public Administration, Administration of

Environmental Quality Programs

924110 Public Administration, Administration of Air and

Water Resource and Solid Waste Management

Programs

926130 Public Administration, Regulation and Administration

of Communications, Electric, Gas, and Other Utilities

Industry Partners 333611 Turbine and Turbine Generator Set Units Manufacturing

333618 Other Engine Equipment Manufacturing

541330 Engineering Services

541620 Environmental Consulting Services

562212 Administrative and Support and Waste Management

and Remediation Services, Solid Waste Landfill

541110 Offices of Lawyers

522110 Commercial Banking

523910 Financial Investments and Related Activities,

Miscellaneous Intermediation

Energy Partners

 Direct usersa

611310 Colleges, Universities, and Professional Schools

325412 Pharmaceutical Preparation Manufacturing

327121 Brick and Structural Clay Tile Manufacturing

327310 Cement Manufacturing

334210 Telephone Apparatus Manufacturing

334220 Radio and Television Broadcasting and Wireless

Communications Equipment Manufacturing

336111 Automobile Manufacturing

325411 Medicinal and Botanical Manufacturing

331511 Iron Foundries

311111 Dog and Cat Food Manufacturing

311421 Fruit and Vegetable Canning

311911 Other Food Manufacturing
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Partner Type NAICS Code NAICS Description

Power marketers

and utilities

221121 Electric Bulk Power Transmission and Control

221122 Electric Power Distribution

221119 Other Electric Power Generation

Endorsers 813910 Business Associations

a There is a wide variety of entities that could become direct energy users. Any facility near a landfill that 

uses fuel is a potential direct user. A subset of the NAICS codes and descriptions from current direct 

energy users are included in Table 4.

4(b) Information Requested

(i) Data Items, Including Recordkeeping Requirements

Information will be collected in MOU, pre-populated electronic spreadsheets, and through 

periodic updates. The MOU request the following information from all Partners:

 Name of the organization;

 Signature, including electronic signature, of authorized representative with

authorized representative’s printed name and the date of the signature;

 Information about the LMOP coordinator including name, title, address, phone

number, fax number, and e-mail address;

 Brief description of the organization (except for Endorsers);

 Organization’s Web site address; and

 A camera-ready copy of the organization’s logo or seal.

Pre-populated electronic spreadsheets request Industry Developer Partners and Community 

Partners to update existing critical LFGE project data necessary for tracking greenhouse gas

reductions from LFGE projects, such as project size and start year. 

All Partners may provide information through periodic updates. These updates will mainly

be changes to contact information for LMOP coordinators and experts, but they can also include 

providing or updating a brief (optional) description of the organization which LMOP will post on 

the LMOP Web site to provide publicity and encourage networking among Partners. LMOP may

also call a selection of Partners to confirm or update project information that LMOP has received 

through the media or industry contacts.

The pre-populated electronic spreadsheets sent to other landfill owners/operators without a 

LFGE project request that landfill owners/operators update information on landfill physical and 
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operational data, waste data, and gas collection system. The data fields requested are limited to 

fields critical for evaluating a landfill’s LFGE potential and for estimating potential methane 

emissions reductions.

Participation in LMOP does not require any records to be kept, although Partners will

likely keep file copies of MOU and spreadsheets submitted to EPA.

(ii) Respondent Activities

The respondent activities depend on the aspect of the information collection to which they

are responding. In completing the MOU, respondents will:

 review the MOU;

 complete the MOU online or in hardcopy;

 sign and submit the form electronically or in hardcopy to EPA; and

 file a copy of the MOU.

In completing the pre-populated spreadsheets, respondents will:

 review the spreadsheet and instructions;

 gather information;

 complete or update information in the spreadsheet;

 e-mail or mail the spreadsheet to EPA; and

 file a copy of the spreadsheet.

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

 gather information; and

 provide information via the LMOP Web site, e-mail, or telephone interview. 

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

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

information collection that the agency has received. In receiving the MOU, the agency will:

 review the information provided;

 sign the MOU;

 return a copy of the signed MOU to the Partner;

 enter the information into a database; and
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 file the MOU.

In requesting and receiving information through a pre-populated spreadsheet, the agency will:

 populate the spreadsheet with landfill and/or project data specific to the Partner or 

other landfill owners/operators and send the spreadsheet via e-mail when an electronic 

address is available or via mail when an electronic address is not available;

 review the information provided and follow up if necessary;

 enter information into a database; and

 file the spreadsheet.

In receiving an information update from a Partner, the agency will:

 review the data; and

 revise data in the database based on the update.

In initiating an information update, the agency will:

 call or e-mail the Partner;

 request updated information; 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 MOU can be downloaded from the LMOP

Web site and returned to EPA either by fax or mail, or submitted electronically. General Partner

information will be posted on the LMOP Web site where it can be reviewed for accuracy by the 

Partner and revised if necessary. Spreadsheets will be e-mailed to all Industry Developer and 

Community Partners. When an e-mail address is available, spreadsheets will be e-mailed to other

landfill owners/operators. To maximize electronic communication, LMOP will spend time 

reviewing appropriate Web sites for e-mail addresses for other landfill owner/operator contacts. If 

no e-mail address is available, LMOP will mail a cover letter and pre-populated spreadsheet

printout to the other landfill owner/operator and will offer to e-mail an electronic copy of the 

spreadsheet if the landfill owner/operator sends their e-mail address. The landfill owner/operator 

can e-mail LMOP with the updates or mail a hardcopy of the completed spreadsheet back to 

LMOP.

All information received through the spreadsheets (electronically or via hard copy) will be 

reviewed by EPA before being entered into the Landfill and Landfill Gas Energy Project database.
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5(c) Small Entity Flexibility

EPA expects that some LMOP Partners and other landfill owners/operators are small 

entities. LMOP reviewed company Web sites and organization descriptions when available for all 

Energy Partners and a portion of Industry Partners to help determine the companies' small entity

status. LMOP determined whether Community Partners are small entities based on the population

served by these government agencies as further described below. LMOP assumed for this estimate 

of small entities that all State Partners, which represent State governments, are not classified as 

small entities, since each State population is greater than 50,000. LMOP also assumed that all of 

its Endorsers, which are non-profits, were classified as small entities. For other respondents, 

LMOP assumed that public sector landfill owners/operators would have the same distribution of 

small entities as Community Partners, and private sector landfill owners/operators would have the 

same distribution of small entities as Industry non-developer Partners. As a result of these 

estimates and assumptions, LMOP estimated the number of small entities affected per year 

according to the type of respondent, as shown in Table 5. The numbers in Table 5 reflect LMOP’s 

assumption that the distribution of small entities within each new Partner category will be similar 

to the distribution analyzed for each existing Partner category.

Table 5: Estimate of Small Entities for Each Respondent Category

Respondent Category New Existing

State Partners 0 0

Community Partners 1 10

Endorsers 3 26

Energy 2 18

Industry Partner, developers 4 26

Industry Partner, non-developers 11 76

Other (public sector) 0 72

Other (private sector) 0 40

Total 20 258

For Community Partners, which represent local or regional government entities, LMOP 

reviewed the list of Community Partners and compared it to a table corresponding to 2006 city or 

county populations1in order to determine the small entity status. Approximately nine percent of 

existing Community Partners were in cities or counties with populations less than 50,000, which is 

the threshold for small entities within the public administration sector.

The majority of Energy Partners are power providers, marketers, or energy end users. 

Within the power provider sector, the only small businesses are a number of rural cooperatives 

 

1

http://www.census.gov/popest/datasets.html
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that have joined as Partners; the rest of the power providers are utilities or power marketers that 

are large businesses. Within the energy end-user sector, many of the companies are large 

corporations such as Wal-Mart, PepsiCo, Ajinomoto, and Nucor Steel, which have a larger energy

demand. Approximately seven small businesses, such as Ohio Valley Creative Energy and Novus 

Energy, have a single facility that uses LFG to meet its energy needs.

Given the large number of Industry Partners, LMOP reviewed Web sites and organization

descriptions for 58% of the project developer Partners and 51% of the non-developer Partners. 

The companies whose Web sites were not reviewed were assumed to contain a similar 

percentage of small businesses to those reviewed. Within the developer category, a majority of 

these Partners have a national presence in the LFG industry and are involved in multiple projects, 

likely meeting the size criteria for large businesses, and thus are not considered small businesses.

Seventeen percent of the developers reviewed were classified as a small business. Most of these 

small businesses serve a small niche market, have an obvious small number of employees, or 

work within a small service region. The non-developer Industry Partner category includes 

manufacturers or suppliers of equipment or expertise needed to collect and utilize LFG. Again, a 

majority of these businesses are large and supply multiple solid waste facilities with 

the engineering, equipment, or construction services needed to build and maintain a LFGE project 

or LFG collection system. Based on a review of Web sites, 20% of non-developers were classified 

as small businesses; these businesses may include smaller local engineering companies, or other 

niche products that are not needed in all LFGE applications.

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

respondents while obtaining sufficient and accurate information. Since the previous ICR, LMOP 

has reduced the number of data fields requested from Industry Developer Partners and 

Community Partners. Additionally, LMOP no longer requests updates on LFGE project data from 

Energy Partners. LMOP also polled Partners on the preferred format for making updates to project 

data, and Partners considered the pre-populated spreadsheet to be more efficient or no less 

efficient than the old online forms. Participation in LMOP is voluntary. Any small entity that finds

the information collection overly burdensome is not required to participate.
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5(d) Collection Schedule

EPA will collect general information in the MOU, which are completed and submitted by

each Partner upon their agreement to participate in the program. EPA will collect additional 

information through pre-populated spreadsheets. These spreadsheets will be completed annually

by Industry Developer Partners and Community Partners. Information may also be updated 

periodically at the request of EPA or the Partner. For other landfill owners/operators, EPA will 

conduct a one-time information collection using pre-populated spreadsheets.

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 fewer 

than nine Partners regarding burden and cost assumptions in 2000. For this renewal ICR, the 

hourly burden estimates for Industry Developer Partners, Energy Partners, and Community Partners

were decreased because the number of data fields has been reduced and the collection 

methodology was simplified. Cost estimates were increased to account for an increase in wages 

and the number of Partners. Attachment A presents the estimated average annual Partner 

respondent burden and costs during the next 3-year ICR period for each type of Partner. Attachment 

B presents the estimated first year (and only year) of other owners/operators' respondent burden and 

costs for information collection activities associated with LMOP. Table 6 presents a summary of 

the respondent burden.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs

For private-sector respondents (Industry and Energy Partners and other privately-owned or 

operated landfills), EPA used a national average hourly labor rate (hourly rate plus 110% 

overhead) of $124.74 for legal staff, $105.26 for managerial staff, $78.22 for technical staff, and 

$43.51 for clerical staff. Managerial, technical, and clerical labor rates were obtained from the 

Bureau of Labor and Statistics average rates for Professional, Scientific, and Technical Services 

(NAICS code 541000). Legal rates were based on lawyers, management wages were based on 

managers (all other), technical wages were based on environmental engineers, and clerical rates 

were based on executive secretaries and administrative assistants for May 2006. A June 2007

labor rate for all rates was estimated by applying a 3.5% growth factor from the Employment Cost 
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Index to account for increases in wages from June 2006 to June 2007. The Employment Cost 

Index for wages and salaries, by ownership, occupational group, and industry is located at:

http://www.bls.gov/news.release/eci.t02.htm.

For public-sector respondents (Community and State Partners, and other publicly-owned 

or operated landfills), EPA used the same labor rates used for EPA personnel (see Section 6(c)). 

These rates are comparable to rates provided by a Community Partner in 2000 and using them for 

all public-sector employees provides consistency. 

For non-profit sector respondents (Endorsers), EPA used a national average hourly labor 

rate (hourly rate plus 110% overhead) of $113.06 for legal staff, $85.46 for managerial staff, 

$86.59 for technical staff, and $42.01 for clerical staff. Managerial, technical, and clerical labor 

rates were obtained from the Bureau of Labor and Statistics average rates for Business, 

Professional, Labor, Political, and Similar Organizations (NAICS code 813900). Legal rates were 

based on lawyers, management wages were based on managers (all other), technical wages were

based on environmental engineers, and clerical rates were based on executive secretaries and 

administrative assistants for May 2006. A June 2007 labor rate for all rates was estimated by

applying a 3.5% growth factor from the Employment Cost Index to account for increases in wages 

from June 2006 to June 2007. The Employment Cost Index for wages and salaries, by ownership, 

occupational group, and industry is located at: http://www.bls.gov/news.release/eci.t02.htm.

(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 this program will be significant. The only O&M costs expected are for 

postage potentially necessary to mail in the MOU and possibly spreadsheets. A postage cost of 

$3.00 is attributed to all activities involving mailing materials to account for the use of trackable 

mail. It is assumed that all LFGE project data updates from Community and Industry Developer 

Partners will be submitted electronically, so their only trackable mail costs are associated with 

submitting their MOU. It is assumed that some of the other landfill owners/operators will submit 

their one-time only spreadsheet updates by mail. The average annual O&M cost over three years is 

$342.
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Table 6: Summary of Respondent Burden

New Existing

Partner Average Annual Burden Total for 3-year 

ICR Period

Hours

Community 149 668 2,450

Endorser 6 10 47

Energy and Industry Non-Developer 228 608 2,505

Industry Project Developer 456 1,178 4,901

State 2 16 54

Subtotal Hours 840 2,479 9,956

Average Burden per Partner 7.4 3.0 --

Other Landfill Owners/Operators1

Public owners and/or operators 1,333 0 4,000

Private owners and/or operators 1,233 0 3,700

Subtotal Hours 2,567 0 7,700

Average Burden per Landfill Owner/Operator 7.7 -- 7.7

Total Hours 3,406 2,479 17,656

Average Burden per Respondent 7.6 3.0 --

Cost

Partner

Community $6,913 $30,381 $111,881

Endorser $460 $844 $3,913

Energy and Industry Non-Developer $19,365 $47,521 $200,660

Industry Project Developer $33,856 $88,927 $368,348

State $110 $770 $2,640

Subtotal Cost $60,703 $168,444 $687,442

Average Cost per Partner $532 $203 --

Other Landfill Owners/Operators

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Public owners and/or operators $61,203 $0 $183,610

Private owners and/or operators $54,477 $0 $163,430

Subtotal Cost $115,680 $0 $347,039

Average Cost per Landfill Owner/Operator $347 -- $347

Total Cost $176,383 $168,444 $1,034,482

Average Labor and O&M Cost per Respondent $394 $203 --

1 For other landfill owners/operators, burden and costs are only associated with 2008. To get an average annual 

burden for the 3-year ICR period, the 2008 burden was divided by 3.

6(c) Estimating Agency Burden and Costs

Attachment C presents the estimated Agency burden hours and costs for the information

collection activities associated with LMOP. Table 7 presents a summary of the agency burden. 

EPA estimates an average hourly labor cost (labor plus 60% for overhead) of $71.34 for 

managerial staff, $48.91 for technical staff, and $19.65 for clerical staff. To derive these estimates,

EPA used the “Salary Table 2007 - GS” from the Department of Personnel Management. For 
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purposes of this ICR, EPA assigned staff the following government service levels:

 Managerial Staff - GS-15, Step 1

 Technical Staff - GS-12, Step 5

 Clerical Staff - GS-5, Step 1

Table 7: Summary of Agency Burden

2008 2009 2010 Average Total

Hours 4,001 1,401 1,551 2,318 6,953

Cost $190,352 $67,485 $74,822 $110,886 $332,658

6(d) Estimating the Respondent Universe

The number of LMOP Partners has grown significantly since the last ICR renewal. Table 

8 presents a summary of the respondent universe by LMOP Partner category for the next 3-year 

ICR period. The burden estimates are based on the total respondent universe. The historical 

response rates to previous LMOP ICRs are approximately 30%.

Table 8: Summary of LMOP Partners and Other Respondents

2008 2009 2010 Average

Partner Existing New Existing New Existing New Existing New

Community1108 19 127 19 146 19 127 19 

Endorser223 3 26 3 29 3 26 3 

Energy193 14 107 14 121 14 107 14 

Industry1

 non-developers 323 56 379 56 435 56 379 56 

 developers 131 21 152 21 173 21 152 21 

State340 1 41 1 42 1 41 1 

TOTAL 718 114 832 114 946 114 832 114

Other LF Owner/Oper. 0 1,000 0 0 0 0 0 333

1 Staff with experience in managing the LMOP Partner database provided insight on future program growth by Partner category. 

The number of new Community, Industry, and Energy Partners increased significantly from 2004 to 2005, and again from 2005 to 

2006. The number of new Partners anticipated for both 2007 and 2008 is expected to be similar to the number of Partners that 

joined in 2006. Higher numbers of Partners are expected in the future due to: enhanced media coverage of LFG energy, climate 

change, and LMOP in recent months, and the benefit of improved LMOP resources for Partners-only such as LFGcost-Web. 

Additionally, planned outreach to the 1,000 other landfill owners/operators with landfills potentially able to support LFG energy

will introduce many communities to LMOP.

2 The number of new Endorsers was assumed to equal an average of the number of Endorsers that joined during the 3-year period 

from 2004 to 2006.

3 Staff with experience in managing the LMOP Partner database provided insight on future program growth by Partner category.

The number of new State Partners is anticipated to be one per year. The majority of states have already joined LMOP and there is 

not expected to be any significant increase in the growth rate during this 3-year ICR period.
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6(e) Bottom Line Burden Hours and Costs

Over the 3-year period covered by this ICR, EPA estimates the respondent burden of the 

program to be 17,656 hours and $1,034,482, of which $4,026 is O&M. EPA estimates the 

Agency burden to be 6,953 hours and $332,658. The total annual burden, averaged over the 

three-year period, is 5,885 hours and $344,827, of which $1,342 is O&M for respondents, and 

2,318 hours and $110,886 for EPA.

The total burden for existing Partner respondents will increase gradually over each year of 

the 3-year ICR period to reflect an increase in the total number of existing Partners, although the 

burden per respondent will remain constant. The burden and costs shown for each existing Partner 

category in Attachment A reflect the average number of Partners during the 3-year ICR period. The 

bottom line burden for new Partners will stay the same for each year of this ICR, since the number 

of new Partners joining each year is expected to remain relatively constant over the 3-year ICR 

period. The bottom line burden and costs for other landfill owners/operators will exist only during 

the first year of this ICR, since this is a one-time information collection effort.

6(f) Reasons for Change in Burden

Under this renewal ICR, the total respondent burden over the 3-year period is 17,656

hours, or an average of 5,885 hours per year. Of this, the total burden on LMOP Partners is 9,956

hours or 3,318 hours per year. The 2003 ICR total burden was 4,598 hours, or an average of 1,533 

per year.

Since the last ICR renewal, LMOP no longer collects information annually from Energy, 

State, and non-developer Industry Partners, the information forms have been simplified into prepopulated spreadsheets, and other collection efficiencies have been implemented such as the 

option to submit MOUs electronically. As a result of these changes, the average number of 

hours per Partner has decreased, but the total hourly burden for LMOP 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 2003 was 365, whereas there were 675 Partners as 

of July 2007. In addition, 49 new Partners joined LMOP in 2004 while the number of new 

Partners in 2006 was 117.

The remainder of the increase in total hourly burden is due to the initiative to collect 

from other landfill owners/operators critical landfill data that are necessary to evaluate the future 

potential of LFG energy. This type of data collection has not occurred during LMOP’s history.
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The total cost estimate over the 3-year period for this renewal ICR is $1,034,482, or an 

average of $344,827 per year, of which $4,026 is O&M costs. The total cost to LMOP Partners 

is $687,442 ($1,026 is O&M), or $229,148 ($342 is O&M) per year. In the previous 2003 ICR 

renewal, the total cost over the 3-year period was $268,893. The total cost estimate increase for 

Partners is due to an increase in the number of Partners and increases in wages. The total cost 

estimate increase for other landfill owners/operators is due to the planned initiative to collect 

data from this new group of respondents.

6(g) Burden Statement

The overall annual public reporting and recordkeeping burden for this collection of 

information is estimated to average 4.6 hours and $270 per respondent. The burden per 

respondent is determined by which types of information collection requests the respondent is 

affected. The average annual burden for new LMOP Partners is 7.4 hours per respondent, the 

average annual burden for existing Partners is 3.0 hours per respondent, and the average burden 

for other landfill owners/operators is a one-time burden of 7.7 hours per respondent. Over the 3-

year period covered by this ICR, EPA estimates the burden of the program to be 17,656 hours 

and $1,034,482 for respondents, and 6,953 hours and $332,658 for EPA. 

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

generate, maintain, retain, and disclose or provide information to or for a Federal agency. This 

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

and systems for the purposes of collecting, validating, and verifying information, processing and 

maintaining information, and disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; train personnel to be able to 

respond to a collection of information; search data sources; complete and review the collection of 

information; and transmit or otherwise disclose the information. An agency may not conduct or 

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

currently valid OMB control number. The OMB control numbers for EPA's regulations are listed 

in 40 CFR part 9 and 48 CFR chapter 15.

The average per facility reporting burden for activities associated with completing the 

MOU is estimated to be 1.8 hours. The burden estimate includes time to review, complete, sign,

and submit the MOU.
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The average per facility reporting burden for Industry Developer and Community Partner 

activities associated with completing the pre-populated spreadsheets is estimated to be 8.5 hours. 

The burden ranges from 4 hours for existing Community Partners to 18.5 hours for new Industry

Partners who are developers. The burden estimate includes time to review the spreadsheet and 

instructions, gather the requested information, complete/update the spreadsheet, and submit the 

spreadsheet to EPA. The burden for each type of Partner is shown in Attachment A and the total 

burden is summarized in Table 6.

The average per facility reporting burden for activities associated with periodic 

information updates is estimated to be 2.5 hours for Energy, Industry, and Community Partners. 

The average per facility reporting burden for activities associated with periodic information 

updates is estimated to be 1 hour for State Partners and Endorsers. The burden estimate includes 

time to gather the requested information and provide the information to EPA.

The average per facility reporting burden for activities associated with completing the

other landfill owners/operators' pre-populated spreadsheets is estimated to be 11.75 hours. The 

burden ranges from 5 hours for public-sector respondents (who likely have only a single landfill) 

to 18.5 hours for private-sector respondents (who may have to complete information for more 

than one site). 

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

burden estimates, and any suggested methods for minimizing respondent burden, including the use 

of automated collection techniques, EPA has established a docket for this ICR under Docket ID 

EPA-HQ-OAR-2003-0078, which is available for online viewing at www.regulations.gov, or in 

hard copy at EPA Docket, EPA/DC, EPA West, Room 3334, 1301 Constitution Ave., NW, 

Washington, DC. The EPA/DC Public Reading Room is open from 8 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 Center is 202-566-1742.

An electronic version of the public docket is available at www.regulations.gov. This site 

can be used to submit or view public comments, access the index listing of the contents of the 

public docket, and access those documents in the public docket that are available electronically. In 

the system, select “search,” then key in the Docket ID Number identified above. Alternatively, 

send comments to the Office of Information and Regulatory Affairs, Office of Management and 

Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please 

include the EPA Docket ID No. EPA-HQ-OAR-2003-0078 in any correspondence.
ATTACHMENT A - ESTIMATED AVERAGE RESPONDENT BURDEN AND COST

A-1 Existing State Partners

A-2 New State Partners

A-3 Existing Endorsers

A-4 New Endorsers

A-5 Existing Energy and Non-Developer Industry Partners

A-6 New Energy and Non-Developer Industry Partners

A-7 Existing Community Partners

A-8 New Community Partners 

A-9 Existing Project Developer Industry Partners

A-10 New Project Developer Industry Partners

ATTACHMENT B - ESTIMATED YEAR 1 RESPONDENT BURDEN AND COST: 

B-1 Publicly-Owned and/or Operated Landfills with LFGE Potential

B-2 Privately-Owned and/or Operated Landfills with LFGE Potential 

ATTACHMENT C - ESTIMATED AGENCY BURDEN AND COST 

C-1 Agency Burden 2008 

C-2 Agency Burden 2009 

C-3 Agency Burden 2010