1. IDENTIFICATION OF THE INFORMATION COLLECTION 

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

This Information Collection Request (ICR) is entitled "Environmental Protection Agency 

information collection activities: Proposed collection; Comment Request; Reporting and Recordkeeping 

Requirements Under EPA’s WaterSense Program" ICR number 2040-0272, Agency No. 2233.04. 

1(b) Short Characterization 

WaterSense is a voluntary program designed to create self-sustaining markets for water-efficient 

products and services via a common label. The program provides incentives for manufacturers to design, 

produce, and market water-efficient products. In addition, the program provides incentives for certified 

professionals (e.g. certified irrigation auditors, designers, or installation and maintenance professionals) to 

deliver water-efficient services. The program also encourages consumers and commercial and 

institutional purchasers of water-using products and systems to choose water-efficient products and 

engage in water-efficient practices. WaterSense partners with manufacturers, professional certifying 

organizations, retailers and distributors, and promotional partners (e.g. utilities; federal, state, and local 

governments; non-governmental organizations (NGOs)) to market and adopt WaterSense, and/or stock or 

provide products and services that meet the water-use and performance specifications developed by 

WaterSense. The program was developed and is managed by EPA’s Office of Water (OW). To date, the 

program has developed specifications for the following products/services: 

 Irrigation certification programs
 

 Residential toilets 

 Residential faucets 

Over the three year ICR period, WaterSense plans to develop specifications for up to 9 water efficient 

products and services,1

 including: 

 Flushing urinals 

 Water-efficient single-family new homes 

 Showerheads
 

 Weather- or sensor-based irrigation control technology
 

 Pre-rinse spray valves 

 Flushometer toilets 

 Water softeners 

 Steam sterilizers 

 Cage, rack, and glassware washers 

1

 Note: this list of products may change based on available information obtained via EPA’s research activities. EPA 

will issue a formal notice of intent (NOI) for each product entering the specification process to allow full 

stakeholder input and involvement in the specification development process. 
 

 

 

An organization’s decision to participate in WaterSense is completely voluntary. Participation 

begins with the completion and submittal to EPA of a Partnership Agreement that provides EPA with 

general information about the organization and its facilities committed to WaterSense. It is signed by a 

senior official that has authority to commit his/her organization to the program and also is signed by EPA. 

Individual certified professionals (e.g. irrigation partners) also complete a Partnership Agreement to 

join the program. 

Within 12 months of completing the Partnership Agreement, manufacturers are asked to submit 

the New Certified Product Notification Form, appropriate for the particular category of product (e.g., 

residential faucets, toilets, irrigation controllers). The form provides information about the products that 

have earned the WaterSense label and their certification information. 

WaterSense currently asks all organizational partners to submit an Annual Reporting Form to 

inform EPA of their program-related activities. WaterSense plans to ask irrigation partners and 

professional certifying organizations to submit their first Annual Reporting Form within the next three 

years. Partners are asked to submit results via the Annual Reporting Form in the following areas: 

WaterSense labeled products, services, and new homes; marketing efforts; and product sales and 

shipment information. EPA uses the information collected to track the progress of the program in 

transforming the market for water-efficient products and practices, to provide information on labeled 

water-efficient products and services to consumers, and to recognize partner accomplishments. 

EPA offers an awards program to recognize significant WaterSense partners’ and other deserving 

applicants’ accomplishments. The awards program is voluntary. Those parties who desire to receive 

special recognition are required to submit an Awards Application. EPA encourages applicants to submit 

forms electronically via the Web site. The Agency will also make hard copy forms available. 

During the next three years, WaterSense will partner with certification providers, who oversee 

inspections of new homes to determine if they meet WaterSense specifications, and ask for a Provider 

Quarterly Reporting Form that includes information about the number and general location of certified 

homes, data collected for each home per the inspection documentation, and a summary of any issues or 

concerns identified during the inspection process. 

To assess progress in educating consumers about the WaterSense program, EPA will conduct a 

brief Consumer Awareness Survey of a sample of consumers two times during the next three years. The 

purpose of the survey will be to obtain information at the national level on consumer awareness and 

understanding of WaterSense, the value accrued to the label in the eyes of consumers, influence of the 

program on purchasing decisions, satisfaction with labeled products, and other WaterSense related 

information. 

2. NEED FOR AND USE OF THE COLLECTION 

2(a) Need and Authority for the Collection 

As part of strategic planning efforts, EPA encourages programs to develop meaningful 

performance measures, set ambitious targets, and link budget expenditures to results. Data collected under 

this ICR will assist WaterSense to demonstrate results under and carry out evaluation efforts to ensure 

continual program improvement. In addition, data will help EPA monitor market penetration and inform 

future product categories and specifications. 

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Both the Clean Water Act (CWA) and the Safe Drinking Water Act (SDWA) have water 

conservation provisions and authorities that authorize WaterSense as currently described. Section 104(a) 

and (b) of the CWA broadly authorizes the Administrator to establish national programs for the reduction 

of pollution, which may include cooperation with, encouragement of, and assistance for public and 

private efforts to prevent, reduce, and eliminate pollution. Section 104(o) of the CWA also authorizes the 

Administrator to conduct research on methods of reducing the total flow of sewage, including 

unnecessary water consumption, which is a recognition by Congress that water consumption is directly 

related to sewage flow and thus to potential water pollution. Section 1442(a)(1) and (2) of the SDWA also 

provides a source of authority for some aspects of WaterSense. Those provisions authorize the 

Administrator to provide demonstrations relating to the provision of a dependably safe supply of drinking 

water. Because both a dependable and a safe supply of drinking water depend on water availability, water 

conservation demonstrations are authorized under these sections. 

The 1993 Government Performance and Results Act (GPRA) (PL 103-62) requires federal 

agencies to develop plans for what they intend to accomplish, measure how well they are doing, make 

appropriate decisions based on the information they have gathered, and communicate information about 

their performance to Congress and to the public. In response, EPA develops a 5-year Strategic Plan that is 

submitted to Congress. Goal 2 of this plan focuses on ensuring that the nation’s water is both clean and 

safe. The 2006-2011 EPA Strategic Plan highlighted support for sustainable infrastructure as a key 

strategy in achieving progress for its goal of Clean and Safe Water. EPA’s work in this area is focused 

around “Four Pillars of Sustainable Infrastructure”— better management, full-cost pricing, water 

efficiency, and watershed approaches to protection. The WaterSense Program, which was initiated in 

2006, is a key element of EPA’s strategic planning efforts to promote better water management as a 

means to reduce the need for costly infrastructure. 

Executive Order 13423 calls for federal agencies to purchase WaterSense labeled products as 

available. 

2(b) Practical Utility/Users of the Data 

The information collected by WaterSense is not designed or intended to support regulatory 

decision making by OW or other EPA offices. In the case of programmatic partnership data, it is 

voluntarily reported by individual EPA WaterSense partners. EPA will use information collected for a 

variety of purposes, described below: 

Partnership Agreement 

EPA will use information submitted in the Partnership Agreement to officially establish 

participation in WaterSense and list partners on the WaterSense Web site. Data from Partnership 

Agreements will be entered into a program database that will serve as a source of general information, 

assist EPA in tracking program progress, and provide contact information to allow EPA to keep partners 

informed of activities of interest to them. 

New Certified Product Notification Form 

EPA will use product information submitted by partners to educate and build awareness among 

consumers as to which products meet specifications developed by WaterSense. Information submitted by 

partners will be aggregated into a list and posted on the WaterSense Web site. Consumers and 

institutional purchasers will be directed to the program Web site to locate model names and numbers of 

products and services that meet the Program’s specification in various product and service categories. 

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WaterSense certification bodies will inform partners when their products have been certified to 

WaterSense specifications. 

Annual Reporting Form 

EPA will use updated annual data supplied by partners to monitor the progress of WaterSense in 

stimulating the supply of and demand for water-efficient products in the market, to determine the impact 

of WaterSense on national water conservation, and to ensure information provided to the public on 

labeled products and services is kept current. This information will also be used to promote WaterSense 

and recognize partner accomplishments. 

Awards Application Form 

EPA will use information from the awards application form to select and recognize outstanding 

accomplishments to promote water efficiency and similar efforts. 

Provider Quarterly Reporting Form 

EPA will use information from the provider quarterly reporting forms to track information about 

the number and general location of certified homes, data collected for each home per the inspection 

documentation, and a summary of common issues and concerns identified during the inspection process. 

Consumer Awareness Survey 

EPA will use data from the consumer survey to assess consumer awareness of the WaterSense 

label and brand. In the future, EPA will compare results of this survey with future surveys to assess 

progress in educating consumers. EPA will also use this data to assess the cost effectiveness of our 

outreach efforts and better target future efforts. 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 

3(a) Nonduplication 

The information to be obtained under this ICR has not been collected by EPA or any other federal 

agency. Other nonfederal organizations promote water conservation, but do not offer a comprehensive 

program to label products and services on a national basis. OW is continuing to work with non-EPA 

programs to ensure that water conservation promotional efforts build on each other rather than duplicate 

efforts. 

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

[To be added following public comment period]

 3(c) Consultations 

WaterSense staff asked current partners to provide input on WaterSense data collection efforts. 

The following partners provided input: 

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Name Affiliation 

Gail Donaldson City of Allen, Texas 

Jane Arrington Spartanburg Water 

Joanne Bissetta Concord Public Works 

Jeremy Gerking Amazon LLC 

Mary Henderson Lowe’s Companies Inc. 

C.J. Lagan American Standard 

Fernando Fernandez TOTO USA 

Glenn Bowlin Broussard Associates 

Frank Soukup Emerald Lawns Inc. 

Partners provided feedback on the amount of time needed to respond to WaterSense data 

collection forms and provided suggestions for improving data collection. EPA incorporated feedback on 

the time needed to complete the forms in the burden estimate. Additional suggestions made by partners 

include revising the evaluation criteria for awards, using online or Word forms in addition to Adobe 

forms, and changing the time of year WaterSense requests data. 

3(d) Effects of Less Frequent Collection 

The Partnership Agreement is a one-time information submittal for organizations and certified 

professionals that wish to participate in WaterSense as partners. Less frequent collection of this data is not 

feasible. Manufacturers are asked to submit a New Certified Product Notification Form for each 

product. Less frequent collection of this information is not feasible. 

Partners submit the Annual Reporting Form to inform EPA of their program-related activities. 

Recognizing and promoting water-efficient products and innovative product development is important to 

show consumers that simple everyday decisions, including purchasing WaterSense-labeled products that 

perform as well as or better than their less-efficient counterparts, can have a positive impact on the 

environment and save money on utility bills. Partners are asked to submit results via the Annual 

Reporting Form in the following areas: labeled products, labeled new homes, labeled certification 

programs, promotional activities, and product sales information. Requesting this information less 

frequently would hinder Agency efforts to generate relevant and timely case studies, provide up-to-date 

information on labeled products and services to the public, and assess program results that are helpful to 

participants. It also would hinder the ability of the Agency to review the activities by individual 

organizations and the program as a whole and to gain the information necessary to publicly recognize 

significant partner water efficiency activities. 

The Awards Application is requested for partners and other interested applicants desiring 

additional recognition. Less frequent collection would hinder EPA efforts to provide timely recognition of 

achievements. 

The Provider Quarterly Reporting Form will be requested from licensed certification provider 

partners every 3 months to determine the number and general location (city, state) of certified homes, data 

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collected for each home per the inspection documentation, and a summary of issues and concerns 

identified during the inspection process. Similar programs (e.g., the ENERGY STAR New Homes 

program) collect similar data from certification providers on the same schedule. Thus, EPA is planning on 

collecting data from licensed certification providers on the same schedule as ENERGY STAR. To keep 

the public informed of the availability of WaterSense labeled new homes in a particular area, timely data 

is needed. 

The Consumer Awareness Survey will be conducted two times over the next three years. Less 

frequent collection would not allow the program to track changes in awareness over time. 

3(e) General Guidelines 

All of the collection activities described within this ICR fall within OMB’s General Guidelines. 

3(f) Confidentiality 

WaterSense manufacturer and retailer/distributor partners may claim their shipment and sales 

data as confidential business information (CBI). EPA’s contractor, ERG, is currently managing CBI 

collected on this project using the procedures outlined in ERG’s CBI security plan entitled Security Plan 

for Handling Confidential Business Information Under the Clean Water Act. Project staff are trained in 

CBI-handling procedures, as outlined in this plan. Only staff demonstrating their understanding of CBI 

handling procedures by passing a written test will be permitted access to CBI. 

3(g) Sensitive Questions 

No questions of a sensitive nature are asked in any of the forms. 

4. THE RESPONDENTS AND THE INFORMATION REQUESTED 

4(a) Respondents and NAICS Codes 

Respondents will consist of WaterSense partners, individuals desiring recognition and 

participants in the consumer survey. WaterSense partners include product manufacturers; professional 

certifying organizations; certified professionals; retailers; distributors; utilities; federal, state, and local 

government; builders, developers, irrigation professionals and NGOs. 

Non-partner respondents will not have NAICS codes as they will be randomly sampled citizens. 

NAICS codes for likely partners include: 

NAICS Code 2007 NAICS U.S. Title Index Entry 

327111 Vitreous China Plumbing Fixture 

and China and Earthenware 

Bathroom Accessories 

Manufacturing 

Bathroom accessories, vitreous 

china and earthenware, 

manufacturing 

423720 Plumbing and Heating Equipment 

and Supplies (Hydronics) Merchant 

Wholesalers 

Plumbing fixtures merchant 

wholesalers 

326191 Plumbing Fixture Fitting and Trim Toilet fixtures, plastics, 

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 Manufacturing manufacturing 

444130 Hardware Stores Hardware stores 

444190 Other Building Material Dealers Building materials supply dealers 

221310 Water Supply and Irrigation 

Systems 

Water supply systems 

813312 Environment, Conservation and 

Wildlife Organizations 

Conservation advocacy 

organizations 

339114 Dental Equipment and Supplies 

Manufacturing 

Autoclaves, dental, manufacturing 

339114 Laboratory Apparatus and 

Furniture Manufacturing 

Autoclaves, laboratory-type (except 

dental), manufacturing 

236115 New Single-Family Housing 

Construction (except Operative 

Builders) 

Home builders (except operative), 

single-family 

4(b) Information Requested 

Once a prospective partner organization reviews WaterSense materials and decides to join the 

program, it will submit the appropriate Partnership Agreement for its partnership category (Attachments 

1-6). Within 12 months of registering, manufacturers are asked to complete a New Certified Product 

Notification Form (Attachments 7-8) to provide WaterSense with information on water-efficient 

products. EPA also asks partners to submit an Annual Reporting Form and Awards Application 

(voluntarily at the Partner’s discretion). These documents are included in Attachments 9-19. Licensed 

certification providers for new homes will be asked to submit a Provider Quarterly Reporting Form 

(Attachment 20). The Consumer Awareness Survey is included as Attachment 21. 

Partnership Agreement 

Program participants complete and submit to EPA a two-page Partnership Agreement 

appropriate to their partnership category that provides basic organization information. 

(i) Data items: 

The reporting items include: 

• Organization name (or name of individual for irrigation partner). 

• Name, title, address, county, postal code, phone number, fax number, e-mail address, and 

primary function of the partner’s primary contact person. 

• Approximate number of employees at the joining organization. 

• How the partner heard about WaterSense. 

• Signature, name, and title of senior official and the date signed. 

(ii) Respondent activities: 

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Participants conduct the following activities in order to complete and submit the Partnership 

Agreement: 

• Review the WaterSense Web site, brochure, agreement, and other necessary materials. 

• Select a primary contact person for WaterSense. 

• Complete the Partnership Agreement, including obtaining the signature of a senior 

official. 

• Send the completed form to EPA via fax, mail, e-mail, or online. 

New Certified Product Notification Form 

Within 12 months of joining WaterSense, manufacturing partners complete and submit to EPA a 

New Certified Product Notification Form. This form is filled out upon successful completion of thirdparty testing of product(s) to a WaterSense specification, and approval of a WaterSense third-party 

licensed certifying body. 

(i) Data items: 

The reporting items include: 

 Manufacturer Information (e.g., manufacturer name; name, phone number, fax, and e-mail 

address.) 

 Product Information (e.g., brand name, model name, model number, product URL, product, 

category, name of certifying body, certification ID number, date of certification) 

(ii) Respondent activities: 

Participants conduct the following activities in order to complete and submit the New Certified 

Product Notification Form: 

 Apply for label through approved third-party licensed certifying body.
 

 Collect records from each service or product.
 

 Select a primary contact person to answer questions from EPA's WaterSense Team. 

 Complete the New Certified Product Notification Form upon receipt of certification from
 

the third-party licensed certifying body.
 

 Send the completed form to EPA via fax, mail, e-mail or online. 

 Answer questions about form if EPA needs clarifications. 

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Annual Reporting Form 

Program participants complete and submit to EPA a standard Annual Reporting Form that 

describes the participant's Program-related activities. The Annual Reporting Form may contain both 

descriptive information and quantified results. 

(i) Data items: 

The reporting items include: 

• Participant Information (e.g., organization name, name, phone number, and email 

address of the partner’s primary contact.) 

• Current Water-Efficient Products, Services, and Activities 

 As applicable: 

–	 For manufacturers: shipment data for both WaterSense and non-WaterSense labeled 

products (option to provide data confidentially), information on product availability 

and promotional efforts, program feedback. 

–	 For retailers and distributors, sales data for both WaterSense and non-WaterSense 

labeled products (option to provide data confidentially), information on product 

availability and promotional efforts, program feedback. 

–	 For promotional partners (utilities; state, local, and federal governments, non-profits, 

and professional and trade associations), past and planned promotional activities, 

rebate information, program feedback. 

–	 For irrigation partners, number of WaterSense labeled irrigation products sold or 

installed, gallons of water saved per project, promotional activities. 

–	 For professional certifying organizations, total number of professionals certified 

through WaterSense labeled programs to deliver water-efficient services, 

promotional, recruiting, and educational efforts. 

–	 For licensed certifying bodies, number of products tested and certified to meet 

WaterSense criteria, number of products failed, suspended, withdrawn, and/or 

reinstated, summary of label misuse and dispute actions. 

–	 For builders and developers, total number of homes built/sold, number of WaterSense 

labeled homes built/sold, and marketing efforts to promote WaterSense labeled 

products and services. 

(ii) Respondent activities: 

Participants conduct the following activities in order to complete and submit the Annual 

Reporting Form: 

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•	 Collect and review records to assess product shipment or sales data, purchased products 

or services, number of professionals certified, number of homes built/sold, promotional 

activities, and/or rebate information during the reporting year. 

•	 Review instructions for completing the annual update. 

• Complete the Annual Reporting Form, including obtaining the signature of the 

principal contact. 

• Send the completed form to EPA via fax, mail, e-mail, or online. 

• Respond to EPA questions to clarify data. 

Awards Application 

Partners and non-partners who wish to receive additional recognition will submit awards 

application forms for products and/or services they provided that promote water efficiency or water 

conservation efforts or adhere to water-efficient guidelines. These applications will be used to recognize 

outstanding accomplishments in each award category. Submission of this application is strictly voluntary: 

applicants only need to complete an Awards Application form if they wish to be considered for an award. 

(i) Data items: 

The application items include: 

• Applicant Information (e.g., organization or individual name, name, phone number, and email 

address of the primary contact person.) 

	 Award Information (e.g., category, products or services, qualifications, relevant activities.) 

(ii) Respondent activities: 

Applicants conduct the following activities in order to complete and submit the Awards Application: 

	 Review instructions and eligibility requirements. 

	 Collect and review records to assess product, service, or promotional information during the 

reporting year that qualifies for an award. 

 Complete the Awards Application, including developing supplemental materials and obtaining 

the signature of the principal contact. 

 Send the completed application to EPA via fax, mail, e-mail, or online. 

Provider Quarterly Reporting Form 

On a quarterly basis, licensed certification provider partners will complete and submit a list of 

information about the number and features of homes that have received the WaterSense label. 

(i)	 Data items: 

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The report items include: 

• Participant Information (e.g., organization name, name, phone number, and email address of 

the partner’s primary contact person.) 

	 New Home Information (e.g., number and general location of certified homes, number and 

issues related to homes that did not qualify, builder/developer organization, aggregate data 

collected for the homes per the inspection documentation, summary of any issues and concerns 

identified during the inspection process) 

(ii) Respondent activities: 

 Collect and review records.
 

 Review instructions for submission. 

 Complete the Provider Quarterly Reporting Form. 

 Send the complete report to EPA via fax, mail, e-mail, or online. 

Consumer Awareness Survey 

EPA will conduct two phone surveys of consumers to collect baseline data about consumer awareness of 

the WaterSense label, brand, and messaging. Part B of this supporting statement describes the sampling 

methodology. 

(i) Data items: 

 Awareness of WaterSense label. 

 Source of information related to WaterSense (how did they hear about it).
 

 Identification of WaterSense labeled products. 

 Message retention. 

 Opinion on the value of water. 

 Likelihood of purchasing a WaterSense labeled product versus conventional product. 

 Influence on the presence or absence of the WaterSense label on purchasing decision. 

(ii) Respondent activities: 

 Receive phone call and agree to participate in survey. 

 Listen to survey instructions. 

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 Respond to survey questions. 

5. THE INFORMATION COLLECTED—AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT 

5(a)	 Agency Activities 

WaterSense will require EPA to engage in the following activities related to the Partnership 

Agreement, New Certified Product Notification Form, Annual Reporting Form, Awards Application, 

Provider Quarterly Reporting Form, and Consumer Awareness Survey: 

Partnership Agreement 

	 Develop Partnership Agreements for new partnership categories (e.g., builder/developer, 

certification provider) and post to the WaterSense Web site. 

• Answer questions posed by potential participants regarding membership in the program. 

• Review completed agreements, record/enter information into a database, and update 

WaterSense Web site. 

• Sign agreement. 

	 Respond to the partner to welcome them to WaterSense or explain why the organization is 

ineligible for partnership. 

New Certified Product Notification Form 

 Develop notification form and disseminate form to partners via the WaterSense Web site. 

 Answer partner questions about information to be submitted. 

 Review completed forms submitted by partners and clarify any inconsistencies between the 

form and the certification file. 

 Respond to partner to inform them that the form has been accepted, or to explain why it could 

not be accepted. 

 Enter data into program database. 

 Compile list of labeled products and services by category to post on WaterSense Web site. 

 Disseminate updated lists as needed. 

Annual Reporting Form 

• Develop/revise standard data reports available via the program’s database for EPA 

management review. 

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• Communicate reporting requirements to partners and answer questions regarding the Annual 

Reporting Form. 

• Receive and review the annual update for consistency and completeness and place any 

follow-up calls necessary. 

• Maintain a tracking system and record/enter information into database. 

• Develop and make publicly available an annual summary of WaterSense partners’ activities, 

promotions, and market trends. 

Awards Application 

	 Develop the Award Application and post it to the WaterSense Web site. 

	 Communicate requirements for applying and respond to applicant questions about award 

applications. 

 Compile award applications and maintain a record of each applicant’s award application 

status. 

 Determine which applications deserve recognition. 

 Provide recognition through Web site, award ceremony or other means. 

Provider Quarterly Reporting Form 

 Develop the Provider Quarterly Reporting Form and post it to the WaterSense Web site. 

 Maintain a tracking system and record results of reporting forms in database. 

 Answer partner questions about information to be submitted. 

 Compile list of number of homes and general location to post on Web site and include in 

annual program accomplishments report. 

Consumer Awareness Survey 

 Craft sampling methodology. 

 Select sample. 

 Develop survey script and instructions. 

 Implement survey. 

 Analyze data. 

 Report results via program documents (e.g., annual accomplishments report), presentations, 

and Web site. 

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5(b) Collection Methodology and Management 

In collecting and analyzing the information associated with this ICR, EPA uses a telephone 

system, personal computers, and database software. EPA ensures the reasonableness and completeness of 

collected information by reviewing each submittal. EPA enters the information obtained from the forms 

into a database. 

EPA plans to offer all information collection instruments in hard copy and electronically. 

Electronic submissions do not have a significant impact on respondent or Agency burden. 

5(c) Small Entity Flexibility 

All data collected under this ICR are voluntarily reported. EPA expects that some of the 

participants in WaterSense will be small entities. EPA has designed its reporting materials to minimize 

respondent burden while obtaining sufficient and accurate information. 

5(d) Collection Schedule

 Organizations may submit Partnership Agreements to join WaterSense at any time. Partners 

may submit a New Certified Product Notification Form as needed when products are certified. Partners 

will submit Annual Reporting Forms to EPA every year that the partner participates in the program. 

Partners who submit an Annual Reporting Form may submit one or more Awards Applications for 

review and possible recognition by EPA. Licensed certification providers will submit the Provider 

Quarterly Reporting Form four times per year. EPA will implement the Consumer Awareness Survey 

two times during the next three years and repeat the survey under subsequent ICRs. 

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

6(a) Estimating Respondent Burden 

EPA used input from potential partners and its experience implementing WaterSense and other 

voluntary programs to estimate burden estimates for respondents. Exhibit 1 presents the burden hours and 

costs per respondent as well as for all respondents during each of the three years covered under this ICR. 

6(b) Estimating Respondent Costs 

Exhibit 1 presents the estimated annual respondent costs for information collection activities 

associated with WaterSense. The estimated annual respondent costs are discussed below. 

Estimating Labor Costs 

The labor rates used to determine the estimated costs to respondents are consistent with the 

hourly wage rates published by the Bureau of Labor Statistics publications on employment and earnings. 

Rates include the cost of overhead and fringe benefits. EPA estimates an average respondent hourly labor 

rate (hourly plus overhead) of $87.42 for managerial staff, $73.88 for technical staff, and $36.38 for 

clerical staff. 

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Estimating Capital and Operations and Maintenance (O&M) Costs 

EPA will encourage partners to submit materials electronically and also retain materials in 

electronic format to conserve paper. For this reason, EPA estimates minimal copying, faxing, and mailing 

costs ($10 per partner, plus an additional $35 if applying for an award). EPA estimates that licensed 

certification providers will incur an average of $25 per year as reports are submitted quarterly. 

Manufacturers wishing to label products will incur an average of $3,565 per product to engage 

WaterSense Licensed Certifying Bodies (independent testing organizations) to perform product testing 

and certify products to EPA WaterSense specifications. 

6(c) Estimating Agency Burden and Costs 

EPA used its experience implementing WaterSense and other voluntary programs to estimate 

burden estimates for Agency staff. Exhibit 2 presents the burden hours and costs per respondent as well as 

for all respondents during each of the three years covered under this ICR. The hourly labor rates used to 

determine the estimated costs to the Agency are consistent with annual labor rates published in the 

Federal Register and are based on the 2009 GS pay schedule available from the Office of Personnel 

Management. EPA estimates an average hourly labor cost of $70.60 for managerial staff; $51.79 for 

technical staff; and $20.79 for clerical staff. The labor costs are based on the following GS levels and 

steps: managerial rates were based on GS Level 14, Step 4; technical labor rates were based on GS Level 

12 Step 5; and clerical labor rates were based on GS Level 5, Step 1. EPA multiplied hourly rates by the 

standard government overhead factor of 1.6. 

EPA anticipates communicating with partners electronically rather than mailing paper, so we 

have included minimal photocopying and postage costs. 

Exhibit 2 shows the aggregate annual Agency burden and costs for the information collection 

activities associated with WaterSense. The annual burden to the Agency is approximately 35,998 hours, at 

a cost of approximately $1,295,804. The three-year, bottom-line burden for the life of this ICR is 

therefore 107,994 hours and $3,887,413. 

6(d) Estimating the Respondent Universe and Total Burden and Costs 

The universe of each respondent activity varies depending upon the specific activity. The 

respondent universe for each information collection activity associated with the EPA WaterSense 

Program is presented and explained separately below. 

 Partnership Agreement 

EPA estimates that 2,272 partners will join the program (1,000 irrigation partners, 650 promotional 

partners, 195 retailers and distributors, 156 manufacturers, 11 professional certifying organizations, 150 

builders/developers, 60 licensed certification providers, and 50 commercial and institutional partners) 

over the three year period, for an average of 757 partners per year. 

New Certified Product Notification Form 

During the three-year period covered by this ICR, EPA anticipates developing specifications for 9 

categories of products in addition to the two existing categories. Each product category has specific 

information that must be submitted by partners who desire to label their product(s). EPA anticipates that 

manufacturers will submit a total of 1,500 products for certification over the next 3 years of the program. 

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This translates to 500 products annually. EPA will continue updating the Web registry of labeled products 

and services on a bi-monthly basis. 

Annual Reporting Form 

EPA requires submission of one Annual Reporting Form per organization partner for each year the 

partner participates in the program. To date, the program has generally received annual reporting forms 

from approximately 30-60% of partners in each category (see Part B). In 2011, EPA plans to begin 

collecting annual reporting forms from certified professionals (irrigation partners) and professional 

certifying organizations as well. EPA anticipates receiving a total of 2,154 annual reporting forms over 

three years, with an average of 561 per year for organizational partners and 157 for irrigation partners. 

Awards Application 

EPA plans to continue its successful WaterSense awards program. EPA anticipates receiving a total of 

250 award applications, averaging 83 per year. 

Provider Quarterly Reporting Form 

EPA plans to request a Provider Quarterly Reporting Form four times a year from each licensed 

certification provider. Over the three-year period, EPA expects to partner with 60 licensed certification 

providers, averaging 20 providers per year and 80 Provider Quarterly Reporting Forms per year, for a 

total of 240 reports over 3 years. 

Consumer Awareness Survey 

EPA plans to initiate the collection of information in two consumer awareness surveys. EPA anticipates 

collecting information from 800 individuals over three years, averaging 266 per year. 

Total Burden and Costs 

Exhibit 1 shows the aggregate annual respondent burden and costs for the information collection activities 

associated with WaterSense. Estimated respondent burden hours are presented on a per respondent basis 

for the information collected under the Partnership Agreement, Annual Reporting Form, Awards 

Application, Provider Quarterly Reporting Form, and Consumer Awareness Survey and on a per product 

basis for the New Certified Product Notification Form. The annual burden to the universe of respondents 

is approximately 21,250 hours, at a cost of approximately $3,369,814. The three-year, bottom-line burden 

for the life of this ICR is therefore 63,750 hours and $10,109,442. 

EPA expects respondents from individuals (i.e., certified professionals and consumers), private sector 

businesses, and state and local governments. EPA estimates that 20 percent of the respondents will be 

state and local governments, 50 percent will be private sector businesses, and 30 percent will be 

individuals. Table 1 summarizes the total estimated annual burden over three years. Table 2 summarizes 

the total estimated annual and three year costs by sector. 

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Table 1: Total Estimated Annual Respondents and Burden Hours (Annual and Three-Year) by 

Sector 

Respondents Respondents/ 

Year 

Burden 

Hours/Year 

Respondents over 

Three Years 

Total Burden Hours 

over Three Years 

State, local, and tribal 

government 

357 2,877 1,071 8,631 

Private Sector 1,319 14,024 3,957 42,072 

Individuals 668 4,350 2,004 13,050 

Table 2: Total Estimated Annual and Three-Year Costs by Sector 

Respondents Labor 

Costs/Year 

O&M 

Costs/Year 

Total 

Costs/Year 

Total Costs over Three 

Years 

State, local, and tribal 

government 

$211,843 $4,110 $215,953 $647,859 

Private sector $1,045,192 $1,782,900 $2,828,092 $8,484,277 

Individuals $319,598 $6,171 $325,769 $977,307 

6(e) Bottom Line Burden Hours and Costs Tables 

Table 3 summarizes the total estimated annual burden hours and costs for respondents and for the 

Agency. The total cost for respondents is $3,336,814 and the hourly burden is approximately 21,250 

hours. The total cost for the Agency is $1,295,804 and the hourly burden is approximately 35,998 hours. 

Table 3 displays these combined estimates, as well as the grand total of $4,665,618 and the hourly burden 

of approximately 57,248 hours for all information collection activities under WaterSense. 

Table 3: Total Estimated Annual Burden Hours and Costs for Respondents and EPA 

Burden Hours Total Cost 

Respondents 21,250 $3,369,814 

Agency 35,998 $1,295,804 

Total 57,248 $4,665,618 

6(f) Reasons for Change in Burden 

The overall burden estimate for this collection is 7,167 hours higher than the burden estimated under the 

current ICR because the WaterSense program has been launched and expanded since the current ICR was 

approved. The change in burden reflects the substantial increase in the number of products certified, new 

partners joining and reporting, and the addition of the New Homes portion of the program. EPA also has 

a better understanding of how long it takes partners to complete program forms, now that the program is 

underway. 

6(g) Burden Statement 

The estimated average annual reporting and recordkeeping burden for this collection of information is 19 

hours for organizational partners, who are not manufacturers and who are not applying for an award. The 

average burden increases by 16 to 35 hours for manufacturing partners (to complete New Certified 

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Product Notification Forms). Award applicants are estimated to spend an additional 20 hours on average. 

The respondent reporting burden for each information collection activity for WaterSense is presented 

separately below. Partner participation in the program is completely voluntary, and thus the entire 

reporting and recordkeeping burden will be incurred by partners that voluntarily choose to participate in 

WaterSense. 

Partnership Agreement 

The reporting burden for information collection requirements associated with completing the Partnership 

Agreement is estimated to be 7 hours for organizations and 2.5 hours for irrigation partners. This estimate 

includes times for reviewing the instructions on the Partnership Agreement, completing and reviewing the 

information requested, and submitting it. 

New Certified Product Notification Form 

The reporting burden for information collection requirements associated with completing the New 

Certified Product Notification Form for product or service submitted by a respondent is estimated to be 

16 hours. This estimate includes third-party testing, assembling the data into a report format, reviewing it 

and submitting it. 

Annual Reporting Form 

The reporting burden for information collection requirements associated with the Annual Reporting Form 

is 12 hours for partner organizations and 3 hours for irrigation partners. This estimate includes gathering 

data such as product sales, number of products purchased, and number of rebates issued; compiling this 

information; and submitting it to EPA. 

Awards Application 

The reporting burden for information collection requirements associated with the Awards 

Application for each respondent is estimated to be 20 hours. This estimate includes reviewing the 

eligibility requirements and instruction on the application, gathering data and information for submission, 

completing the application, reviewing the information and narrative description required, and submitting 

the application to EPA. 

Provider Quarterly Reporting Form 

The reporting burden for information collection requirements associated with the Provider 

Quarterly Reporting Form for each respondent is estimated to be 26 hours per year. This estimate includes 

collecting and reviewing records, reviewing instructions, completing the reporting form, and submitting 

the form to EPA. 

Consumer Awareness Survey 

The reporting burden for information collection requirements associated with the Consumer 

Awareness Survey for each respondent is estimated to be 0.25 hours. This estimate includes receiving a 

phone call, agreeing to participate in survey, listening to survey instructions, and responding to survey 

questions. 

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

maintain, retain, or 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; adjust the existing ways to comply with any 

previously applicable instructions; 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. 

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 public docket for this ICR under Docket ID No EPA-HQOW-2006-0408, which is available for public viewing at the Office of Water Docket in the EPA Docket 

Center (EPA/DC), EPA West, Room B102, 1301 Constitution Ave., NW, Washington, DC. The EPA 

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 Office of Water Docket is (202) 566-2426. Use www.regulations.gov to obtain 

a copy of the draft collection of information, submit or view public comments, access the index listing of 

the contents of the docket, and to access those documents in the public docket that are available 

electronically. Once in the system, select “search,” then key in the docket ID number EPA-HQ-OW2006-0408. 

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Exhibit 1. Estimated Annual Respondent Burden and Cost 

Information Collection Activity Hours and Costs Per Respondent/Labeled Product 

Manager Professional Clerical Respond 

Hours/Year 

Labor Costs 

per Activity 

per Year 

Annual Capital 

Startup 

Costs 

Annual 

O&M 

Costs 

Hourly Rate 87.42 73.89 36.38 

Partnership Agreement 

Review the EPA WaterSense Web site, brochure, agreement, and other necessary materials 1 2 0 3 $235.20 

Select a primary contact person for the program 0.5 0 0 0.5 $43.71 

Complete the PA, obtain signature of senior official 0.5 1.5 1 3 $190.93 

Send the completed agreement to EPA via fax, mail, email, or online 0 0 0.5 0.5 $18.19 $5.00 Subtotal 2 3.5 1.5 7 $488.03 

Partnership Agreement: Certified Professionals 

Review the EPA WaterSense Web site, brochure, agreement, and other necessary materials 0 1 0 1 $73.89 

Complete the PA, locate certification proof document 0 1 0 1 $73.89 

Send the completed agreement and certification proof to EPA via fax, mail, e-mail, or online 0 0.5 0 0.5 $36.95 $5.00 Subtotal 0 2.5 0 2.5 $184.73 

New Certified Product Notification Form 

Apply for label from approved licensed certifying body 1 8 0 9 $678.54 $3,500.00 $50.00 

Collect records of each service or product 0 2 0 2 $147.78 $5.00 

Select a primary contact person to answer questions from EPA's WaterSense Team 0.25 0.25 0 0.5 $40.33 

Complete the notification form 1 1 0 2 $161.31 

Send the completed application to EPA via fax, mail, email or online 0 0 0.5 0.5 $18.19 $10.00 

Answer questions from EPA 1 1 0 2 $161.31 

Subtotal 3.25 12.25 0.5 16 $1,207.46 

Annual Reporting Form 

Collect and review records to assess product shipment or sales data, purchased products or services, promotional activities, rebate information during the reporting year 1 5 0 6 $456.87 

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Review instructions 0 0.5 0 0.5 $36.95 

Complete the Annual Reporting Form 1 3 0 4 $309.09 

Send the completed update to EPA via fax, mail, e-mail, or online 0 0 0.5 0.5 $18.19 $5.00 

Respond to EPA questions to clarify data 0 1 0 1 $73.89 

Subtotal 2 9.5 0.5 12 $894.99 

Annual Reporting Form: Certified Professionals 

Collect information to assess the practice of efficient irrigation design and maintenance or use of labeled 

products 0 1 0 1 $73.89 

Review instructions 0 0.5 0 0.5 $36.95 Complete the Annual Reporting Form 0 0.5 0 0.5 $36.95 Send the complete update to EPA via fax, mail, e-mail, or online 0 0.5 0 0.5 $36.95 $5.00 

Respond to EPA questions to clarify data 0 0.5 0 0.5 $36.95 Subtotal 0 3 0 3 $221.67 

Awards Applications 

Review instructions and eligibility requirements 1 1 0 2 $161.31 

Gather data 2 5 0 7 $544.29 $5.00 Complete application and supplemental materials 2 8 0 10 $765.96 $10.00 

Submit the application via fax, mail, e-mail, or online 0 0 1 1 $36.38 $20.00 

Subtotal 5 14 1 20 $1,507.94 

Provider Quarterly Reporting Form (Annualized)* 

Collect and review records 4 8 0 12 $940.80 

Review instructions 0 1 0 1 $73.89 

Complete report 0 12 0 12 $886.68 

Submit the report via fax, mail, e-mail, or online 0 0 1 1 $36.38 $20.00 

Subtotal 4 21 1 26 $1,937.75 

Consumer Awareness Survey 

Receive survey request and instructions and respond to questions 0.125 0.125 0.25 $13.78 

Subtotal 0.125 0.125 0.25 $13.78 TOTAL 16.25 65.875 4.625 86.75 $6,456.34 

*Quarterly Reports will be requested 4 times a year; data presented on annual basis Three Year B

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Exhibit 2. Estimated Annual Agency Burden and 

Cost 

Information Collection Activity Hours and Costs Per Respondent/Labeled Product 

Manager Technical Clerical Respond 

Hours/Year 

Labor Costs 

per Activity 

per Year 

Annual Capital 

Startup Costs 

Annual 

O&M 

Costs 

Hourly Rate 70.60 51.79 20.79 

Partnership Agreement 

Develop Partnership Agreements and post to Web site 2 6 0.5 8.5 $462.34 

Answer questions posed by potential participants regarding membership in the program 0 2 0 2 $103.58 Review completed agreements, record/enter information into a database, and update WaterSense Web site 1 4 2 7 $319.34 Respond to the partner to welcome them to WaterSense or explain why organization is ineligible for partnership 0.5 0 0 0.5 $35.30 Sign agreement 0.5 0.5 1 2 $81.99 $2.00 

Subtotal 4 12.5 3.5 20 $1,002.54 

New Certified Product Notification Form 

Develop application materials to be submitted by partners and post to Web site 2 8 0 10 $555.52 

Answer partner questions about form, review completed forms submitted by partner and clarify any inconsistencies between the form and the certification file 0.5 0.5 2 3 $102.78 $5.00 

Enter data into program database 0 0 1 1 $20.79 Respond to partner to inform them that the form has been accepted, or to explain why it could not be accepted 0.5 0 0 0.5 $35.30 

Compile list of products by product type to post on EPA’s WaterSense Web site 0 4 0 4 $207.16 Disseminate updated list as requested 0 1 2 3 $93.37 $20.00 Subtotal 3 13.5 5 21.5 $1,014.92 

Annual Reporting Forms 

Develop/revise standard data reports and communicate reporting requirements 10 40 10 60 $2,985.50 

Answer questions regarding the Annual Reporting Form 0 2 0 2 $103.58 $2.00 

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Receive and review the reports for consistency and 

completeness and place any follow-up calls necessary 1 3 0 4 $225.97 $1.00 

Maintain a tracking system to record/enter information into database 0 0 2 2 $41.58 

Develop annual data summary 10 100 20 130 $6,300.80 $5.00 Subtotal 21 145 32 198 $9,657.43 

Awards Applications 

Maintain a tracking system to record each participant’s award application status 0 20 5 25 $1,139.75 

Develop application to be submitted by partners, post to Web site, and communicate requirements for applying 0 2 0 2 $103.58 

Respond to partner questions about award applications 2 8 2 12 $597.10 $2.00 Determine which applications deserve recognition 4 60 0 64 $3,389.80 $10.00 

Subtotal 6 90 7 103 $5,230.23 

Provider Quarterly Reporting Form (Annualized)* 

Develop reporting form 4 8 0 12 $696.72 

Maintain a tracking system to record results of report in database 10 30 14 54 $2,550.76 

Answer partner questions about information to be submitted 0 0 4 4 $83.16 

Compile list of number of homes and general location to post on Web site 0 8 0 8 $414.32 

Subtotal 14 46 18 78 $3,744.96 

Consumer Awareness Survey 

Craft sampling methodolgy 8 24 0 32 $1,807.76 

Select sample 0 24 0 24 $1,242.96 Develop survey script and instructions 10 20 0 30 $1,741.80 

Implement survey 80 400 40 520 $27,195.60 $2,000.00 Analyze data 20 120 0 140 $7,626.80 

Subtotal 118 588 40 746 $39,614.92 TOTAL 166 895 105.5 1166.5 $60,265.00 

*Quarterly Reports will be requested 4 times a year; data presented on annual basis Three Year Bu

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