1 **SUPPORTING STATEMENT FOR LANDFILL METHANE OUTREACH PROGRAM,**  **EPA INFORMATION COLLECTION REQUEST NUMBER 1849.03** 

**November 12 ,**  **200 8** 2

**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”, IC R 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 enviro nmentall y and economicall y sound landfill gas (LFG) energy projects across the United States in order to reduce methane emissions from landfills . LM OP does this by educating local governments and communities about the benefits of LFG recovery and use; building partnerships between state agencies, industry, energy s ervice providers, local communities, and other stakeholders interested in developing this valuable resource in their community ; and providin g tools to evaluate LFG energy (LFGE) potential . To continue to be successful it is critical that LM OP gather information from its Partner s 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 LM OP Landfill and Landfill Gas Energy

P roject database, LMOP must gather basic phy sical and operational data from municipal solid waste (MSW) landfills without LF GE projects . Improving the data quality in this tool will enable LMOP to identify l andfills that are good candidates for LFGE projects , improve estimates of methane emissions from landfills, and help LMOP and its Partner s prioritize LFGE project development assistance activities. P artners are entities that have volunteered to participate in LMOP. LM OP classifies these Partners into one of five categories: C ommunity Partners, S tate Partners, Industry Partner s, Energy Partner s , and Endorsers. There are three mechanisms for collecting information f rom the Partner s:  electronic memoranda of understanding (MOU);

 pre - populated E xcel 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. LM OP plans to initiate a one - time effort to update basic landfill physical and operational data for these landfills using a pre -populated Excel spreadsheet.3

The LMOP information collec tion is expected to involve an average of 832 existing Partners and an additional 114 new Partners per year. Additionall y there is a planned one - time information collection for 1,000 other landfill owners and operators. The average annual burden (rounded t o one decimal place) and cost per respondent are estimated to be 4. 6 hours and $27 0 . The total annual reporting and recordkeeping burden averaged over three years is 5, 885 hours and $ 34 4 , 827 . This I CR provides a comprehensive description of the i nformation 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 formall y establish participation in LMOP and to obtain general information about new Partner s. Additional information collected from certain ty

pes 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 re source, and reducing emissions due to the burning of non - renewable energy re sources such as coal and fuel oil. Participation in LMOP is voluntary . The f ive categories of participants are:  C ommunity Partner s;  State Partner s;  Industry Partner s (dev elopers and non - developers);

 Energy Partner s; and

 Endorsers . All participant s , in completing the MOU, agree to provide EPA with information requested in the MOU and provide contact information for th eir LMOP coordinator. Industry Developer Partner s agree to provide information on LFGE projects with which they have been involved. Community Partner s agree to provide information on the progress of implementing LFGE projects at their landfill(s).4

Additionally , EPA needs to improve the data quality in one of its critical program tools, the publicly

available LMOP L andfill 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 approx imately 1,000 (MSW) landfills are either sparse ly populated or outdated. Since the inception of LMOP in 199 4 there has never been a s ys tematic national outreach to update landfill data. This outreac h to landfi lls within the LMOP L andfill and Landfill Gas Energy

P roject database tool will serve several functions:

 i mprove the accura cy of LMOP ’s responses to inquiries about landfills and LFG energy , in particular to help project developers and the general public i dentify future opportunities for developing LFGE projects ;

 a ssist 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 landfill s , c ommunicate the benefits of LFG energy , and begin developing LFGE projects. **2(b) Practical Utility/Users of the Data** EPA uses information submitted i n the MOU to update its database of LMOP Partner s. The database serves as a source of general information and a n electronic mailing list. EPA use s information in spreadsheet attachments submitted by Industry Developer Partners and Community

Partners to mon itor 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 Partner s 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 al so provided on the LMOP Web site, making it available to other LMOP Partner s 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 LM OP Landfill and Landfill Gas Energy Project database .5

**3 . NONDUPLICATION**  **, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3(a)**  **Nonduplication** For new Partner s, the information to be collected has not previously been collected by EPA or any other Federal Agency. For existing Partner s with LFGE proje cts, 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 Partner s and other landfill owners and operators will be pre -populated with information from the database. Recipients of the spreadsheet s will be asked to review the information provided. Only if the information is incorrect or out of date wil l the recipients be re quested to provide updated or additional information. **3(b) Public Notice Required Prior to ICR Submission to OMB**  Incompliance with the Paperwork Reduction Act of 1995, EPA solicited public comments on the ICR through an announcement in th e Federal Register on June 3 , 200 8 ( 73 FR 3 1681 ) . The Agency did not receive any

comments on this ICR renewal. **3(c) Consultations**  In 2000, EPA consulted with fewer than nine Partner s regarding the burden of this information collection. Th e fo llowing Partner s 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 assoc iated with completing the MOU, updating landfill and LFG E project data, and submitting periodic updates are assumed to be less than w ere estimated by Partner s in 2000.

**Table 1**  **: List of Partner Consultations Made in 2000 Partner**  **Ty p**  **e 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 Ke vin 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 - 10676

In 2007, LMOP also contacted fewer than nine P artners on the preferred format for making updates to their LFGE projects and landfills in the future . LM OP provided a choice of using the existing online data update forms used in IC R 1849.02 , or an e - mail with a pre populated spreadsheet attachment f or all of their projects /landfills . All P artners were either indifferent between these two options or preferred the new spreadsheet inf ormation collection method to the old online form.

**Table 2**  **: List of Pa rtner 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 - 8 044 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 cont acted agreed that the estimated burden b y Partner type is what they would expect for this effort or the amount they expect is less than the estimate.

**Table 3**  **: List of Pa rtner 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 - 29567

**3(d) Effects of Less Frequent Collection**  The MOU are submitted once by organizations that choose to become P artners of LMOP. To allow EPA to remain current on LFGE projects, Industry Developer and Community P artners directl y involved in projects will be asked to update the landfill and LFGE project data spreadsheets annuall y. All Partners may also update company

and contact information periodicall y. F or others that own or operate landfills without a LFGE project, EPA will conduct a one - time information collection effort to update critical landfill data n ecessary 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 P artners. **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. Additionall y, 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 l andfill 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 P artners include local agencies and municipalities that own landfills. State agencies involved in energy, air pollution, and solid waste management are represented through State P artners. Industry Partners include engine and turbine manufacturers, engineering fir ms, construction companies, environmental consultants, and other companies involved in the logistics of developing LFGE projects such as law firms and financing companies. Industry P artners are further divided into two groups: (1) developers are organizati ons that facilitate, finance, and implement LFGE projects; (2) non - developers are manufacturers or suppliers of equipment or expertise needed to collect and8

utilize LFG . Energy

P artners 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 potentiall y the most diverse category . Any facility located near a landfill that utilizes fuel either in manufacturing products or in heating the facility is a po tential energy end user. Finall y, 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, publ ic works, municipalities, and renewable energy . Table 4 provid es the North American Industry

Classification S ys tem (NAICS) code and description for the respondents . **Table 4**  **: Respondents to Information Collection Partner Type**  **NAICS Code NAICS Description**  C ommunity 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 Env ironmental 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,

Miscellane ous Intermediation Energy Partners Direct users a 611310 Colleges, Universities , and Professional Schools

325412 Pharmaceutical Preparation Manufacturing 327121 Brick and Structural Clay Tile Manufacturing 327310 Cement Manufacturing 334210 Telephone Apparatus Manufacturing 33422 0 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 Manufacturing9 **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 Gene ration Endorsers 813910 Business A ssociations 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** In formation will be collected in MOU, pre -populated electronic spreadsheets, and through periodic updates. The MOU reques t the following information from all P artners:  Name of the organization;

 Signature, including electronic signature, of authorized representative with authorized representative’s printed name and the date of the signature;

 In formation 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 cop y of the organization’s logo or seal. Pre -populated el ectronic spreadsheets request Industry Developer Partners and Community P artners to up date existing critical LFGE project data necessary for tracking greenhouse gas reductions from LFGE projects , such as project size and start year. All P artners may

provi de information through periodic updates. These updates will mainly be changes to contact information fo r LMOP coordinators and experts, but th ey 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 enco urage 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 electron ic spreadsheets sent to other landfill owners/operators without a LFGE project request that landfill owners/ operators update information on landfill phy sical and10

operational data, waste data, and gas collection s ystem. 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 P artners 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 on line or in hardcop y ;  sign an d submit the form electronically or in hardcopy to EPA; and

 file a cop y of the MOU . Incompleting the pre -populated spreadsheets , respondents will :  review the spreadsheet and instructions;  gather information;

 complete or update information in the spreadsh eet ;  e - mail or mail the spreadsheet to EPA; and  file a cop y of the spreadsheet . In repl yi ng to or initiating an information update, respondents will:  gather information; and  provide information via the LMOP Web site , e - mail, or telephone interview. **5. TH**  **E 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 rece ived. In receiving the MOU, the agency will:

 review the information provided;  sign the MOU ;  return a cop y of the signed MOU to the P artner;  enter the information into a database; and11

 file the MOU . In requesting and receiving information through a pre - popul ated spreadsheet, the agency will:  populate the spreadsheet with landfill and/or project data specific to the Partner or other landfill owner s /operators and s end the spreadsheet via e - mail when an electronic address is available or via mail when an electro nic address is not available ;  review the information provided and follow up if necessary ;  enter information into a database; and  file the spreadsheet . In receivin g an information update from a P artner, 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 P artner;  request updated information; and  revise data in the database based on the updates. **5(b) Collection Methodology and Management** The methods sel ected 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 b y fax or mail, or submitted electronically . General P artner information will be posted on the LMOP Web site where it can b e reviewed for accuracy by the Partner and revised if necessary . Spreadsheets will be e - mailed to all Industry Developer and Community

P artners. When an e - mail address is available, spreadshee ts will be e - mailed to other landfill owners/ operators. To maximize electronic communication , LM OP wil l 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 cop y of the spreadsheet if the landfill owner/operator sends their e - mail address . The landfill owner/operator can e - mai l LMOP with the updates or mail a hardcopy of the completed spreadsheet back to LMOP. All inform ation received through the spreadsheets (electronicall y or via hard copy ) will be reviewed by

EPA before being entered into the Landfill and Landfill Gas Energy Project database.12

**5(c) Small Entity Flexibility**  EPA expects that some LMOP Partners and other landfill owner s /operators are small entities. LM OP reviewed company Web sites and organization descriptions when available for all Energy Partners and a portion of In dustry Partners to help determine the companies' small entity status. LM OP determined whether Community Partners are small entities based on the population served b y these government agencies as further described below. LMOP assumed for this estim ate of sm all entities that all State Partners, which represent S tate governments , are not classified as small entities, since each State population is greater than 50,000. LMO P also assumed that all of its Endorsers, which are non - profits, were classified as small entities. For other respond ents, 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 enti ties as Industry non - developer Partners. As a result of these estimates and assumptions, LMOP estimated the number of small entities affected per ye ar according to the type of respondent, as shown in Table 5 . The numbers in Table 5 reflect LMOP’s assumptio n that the distribution of small entities within each new Partner category will be similar to the distribution analy

zed for each existing Partner category . **Table 5 : Estimate of Small Entities for Each Respondent Category**  **Respondent Category New**  **Existing** S tate 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 repre sent local or regional government entities, LMOP reviewed the list of Community Partners and compared it to a table corresponding to 2006 city or county populations 1 in order to determine the small entity status. Approximately

nine percent of existing C ommunity P artners 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.html13

that have j oined 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 use s 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 as sumed 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 fo r 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 emplo yees, or wor k within a small service region. The non - developer Industry Partner cat egory

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 fa cilities with the engineering, equipment, or construction services needed to build and maintain a LFGE project or LFG collection sy stem. Based on a review of Web sites, 20% of non - developers were classified as small business es; 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 informatio n. Since the previous I CR, LMOP has reduced the number of data fields requested from Industry Developer P artners and Community

P artners. Additio nally, LMOP no longer requests updates on LFGE project data from Energy Partners. LMOP also polled P artners o n the preferred format for makin g updates to project data, and P artners considered the pre - populated spreadsheet to be more efficient or no less efficient than the old online forms . P articipation in LMOP is voluntary . Any small entity that finds the inform ation collection overly burdensome is not required to participate.14

**5(d) Collection Schedule**  EPA will collect general information in the MOU, which are completed and submitted by each P artner 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 P artners and Community P artners. Information may also be updated periodicall y at the request of EPA or the P artner. For other land fill owner s /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 estimate s, EPA consulted with fewer than nine P artners regarding burden and cost assumptions in 2000. For this renewal I CR, the hourl y burden estimates for Industry Developer Partners, Energy Partners, and Community P artners 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 incre ase in wages and the number of P artners. Attachment A presents the estimated average annual P artner respondent burden and costs d uring the next 3 - ye ar ICR period for each typ e of Partner . Attachment B presents the estimated first year (and onl y ye ar) 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**  F or private - sector respondents (Industry and Energy

P artners and other p rivately- owned or operated landfills ), EPA used a national average hourly labor rate (hourl y rate p lus 110% overhead) of $124.74 for legal staff, $105.26 for managerial staff, $ 78 . 22 for technical staff, and $ 4 3. 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 (NAI CS 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 Employ ment C ost15

Index to account for increases in wages from June 2006 to June 2007. The Employ ment Cost In dex 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 P artners , 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 b y a Community P artner in 2000 and using them for all public - sector employees provides consistency . For non - prof

it sector respondents (Endorsers ), EPA used a national average hourly labor rate (hourl y rate plus 110% overhead) of $113.06 for legal staff, $ 85.46 for managerial staff, $ 86 . 59 for technical staff , and $4 2 . 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 we re based on law yers, 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 Employ ment C ost Index to acco unt for increases in wages from June 2006 to June 2007. The Employ ment Cost Index for wages and salaries, b y ownership, occupational group, and industry is located at: http://www.bls.gov/news.rele ase/eci.t02.htm . **(ii) Estimating Capital and Operations and Maintenance Costs**  Because this information collection requires respondents onl y 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 onl y 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 P artners will be submitted electronicall y, so the ir only trackable mail costs are associated with submitting the ir MO U. It is assumed that some of the other landfill own er s/operators will submit their one - time onl y spreadsheet updates by mail. The average annual O&M cost over three years is $342 .16 **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 84 0 2, 479 9,956 Average Burden per Partner 7.4 3. 0 -- **Other Landfill Owner s**  **/Operators 1**  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 3,4**  **06 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 S tate $1 10 $ 770 $ 2,640 Subtotal Cost $6 0 , 703 $1 68 , 444 $6 87 , 442 Average Cost per Partner $53 2 $20 3 -- **Other Landfill Owner s**  **/Operator s**  **1** Public owners and/or operators $61,203 $0 $183,610 Private owners and/or operators $54,477 $0 $163,430 Subtota l Cost $115,680 $0 $347,039 Average Cost per Landfill Owner/Operator $347 -- $347 **Total Cost $176,**  **383 $1**  **68 ,**  **444 $1,0**  **34 ,**  **482 Average Labor and O&M Cost per Respondent**  **$39 4**  **$20 3**  -- 1 For other landfill owner s /operators , burden and costs are only associ ated 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**  Attachm ent C presents the estimated Agency burden hours and costs for the information collection activiti es ass ociated with LMOP. Table 7 presents a summary of the agency

burden. EPA estimates an average hourly labor cost (lab or plus 60% for overhead) of $71 . 34 for managerial staff, $4 8 . 91 for technical staff, and $19.65 f or clerical staff. To derive these estimate s, EPA used the “Salary

Table 2007 - GS” from the Department of Personnel Management. For17

purposes of this I CR, 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 P artners has grown significantly since the last ICR renewal. Table 8 presents a summary

of the respondent universe by LMOP P artner 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 a pproximately 3 0 %. **Table 8 : Summary of LMOP Partners and**  **Other Respondents** 

**2008 2009**  **2010 Average**  **Partner Existing**  **New Existing**  **New Existing**  **New Existing**  **New** Community 1 108 19 127 19 146 19 127 19 Endorser2 23 3 26 3 29 3 26 3 Energy 1 93 14 107 14 121 14 107 14 Industry 1 non - developers 323 56 379 56 435 56 379 56 developers 131 21 152 21 173 21 152 21 State 3 40 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 LMO P P artner database provided insight on future program growth by P artn er category. The number of new Community, Industry, and E nergy P artners increased significantly from 2004 to 2005, and again from 2005 to 2006. The number of new P artners anticipated for both 2007 and 2008 is expected to be similar to the number of P artners that joi ned in 2006. Higher numbers of P artners are expected in the future due to: enhanced media coverage of LFG energy , climat e 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 Endorser s that joined during the 3 - year period from 2004 to 2006. 3 Staff with e xperience in managing the LMOP P artner database provided insight on future program growth by P artner category. The number of new State P artners 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.18

**6(e) Bottom Line Burden Hours and Costs**  Over the 3 - ye ar period covered by this ICR, EPA estimates the respondent burden of the program to be 17, 656 hours and $ 1, 0 34 , 482 , of which $ 4 ,026 is O&M . EPA estimates the Agency burden to be 6 ,9 53 hours and $33 2, 658 . The total annual burden, averaged over the three - ye ar period, is 5, 885 hours and $ 34 4 , 827 , of which $ 1 , 342 is O&M for respondents , and 2,318 hours and $ 110 , 886 for EPA. The total burden for existing P artner respondents will increase gradual ly over each ye ar of the 3 - ye ar I CR period to reflect an increase in the total number of existing P artners , although the burden per respondent will remain constant . The burden and costs shown for each existing P artner category in Attachment A reflect the average number of P artners during the 3 - ye ar ICR period. The bottom line burden for new P artners will stay the same for each year of thi s I CR, since the number of new P artners joining each year is expected to remain relativel y constant over the 3 - ye ar ICR period. The bottom line burden and costs for other landfill owners/operators will exist onl y during the first ye ar 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 b urden over the 3 - year period is 17, 656 h ours , or an average of 5, 885 hours per ye ar . Of this, the total burden on LMOP P artners is 9 , 956 hours or 3,3 18 hours per year . The 2003 ICR total burden was 4,598 hours, or an average of 1,533 per year. Since the last I CR renewal, LMOP no longer collects information annuall y from Energy, State, and non - developer Industry Partners, the information forms have been simplified into pre populated spreadsheets, and other collection efficiencies have been implemented such as the optio n to submit MOUs electronicall y . 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 hourl y burden is due to the initiative to collect from other land fill owners / operators critical landfill data that are necessary to evaluat e the future potential of LFG energy . Th is ty pe of data collection has not occurred during LMOP ’s history .19

The tot al cost estimate over the 3 - ye ar period for this renewal ICR is $1,0 34 , 482 , or an average of $34 4 , 827 per year , of which $ 4 ,026 is O&M costs . The total cost to LMOP Partners is $6 87 , 442 ($1,026 is O&M) , or $2 29 , 148 ($34 2 is O&M) per year . In the previous 2003 I CR renewal, the total cost over the 3 - ye ar period was $268,89 3 . The total cost estimate increase for P artners is due t o an increase in the number of P artners and increases in wages. The total cost estimate increase for other landfil l 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 $ 27 0 per respondent . The burden per respondent is determined by which ty pes of information collection requests the respondent is affected. The average annual burden for new LMOP P artners is 7.4 hours per respondent, the average annual burden for existing P artners is 3. 0 hours per respondent, and the average burden for other landfill owner s /operators is a one - time burden of 7.7 hours per respondent. Over the 3 - ye ar period covered by

this I CR, EPA estimates the burden of the program to be 17, 656 hours and $1,0 34 , 482 for respondents, and 6,953 hours and $332,658 for EPA. Burden means the total time, effort, or financial resources expended b y 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 sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjus t the existing ways to compl y 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 currentl y 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.20

The average per facility

reporting burden for Industry D eveloper and Community P artner a ctivities 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 P artners who are developers. The burden estimate includes time to review the spreadsheet and instructions, gather the requested information, complete/update the spreadsheet , an d submit the spreadsheet to EP A. The burden for each typ e of P artner 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 avera ge 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 EP A. The average per facility

reporting burden for activiti es associated with completing the other landfill owners/operators ' pre - populated spreadsheet s 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 - 200 3 - 0078 , which is available for online viewing at www.regulations.gov, or in hard cop y 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 holiday s. The telephone number for the Reading Room is 202 - 566 - 17 44, 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 electronicall y. In the sy stem, select “search,” then key in the Docket ID Number identified above. Alternativel y, send comments to the Office of Information a nd 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 - 200 3 - 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 C ommunity 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 - O wned 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