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 collec tion; 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 cr eate 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 a ddition, the program provides incentives for certified

professionals (e.g. certified irrigation auditors, designer s, 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 pa rtners 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 availa ble 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 organi zation and its facilities committed to WaterSense. It is signed by a

senior official that has authority to commit his/her or ganization 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 particul ar category of product (e.g.,

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

have earned the WaterSense label a nd their certification information.

WaterSense currently asks all organi zational 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 co llected 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 consumer s, and to recognize partner accomplishments.

EPA offers an awards program to recognize signi ficant 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 pa rtner 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 nu mber and general location of certified

homes, data collected for each home per the inspecti on 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 informati on 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 ot her 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 w ill help EPA monitor market penetration and inform

future product categories and specifications.



### - 2 -Both the Clean Water Act (CWA) and the Sa fe 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 Administ rator 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 pollu tion. 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 po llution. 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 wa ter 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 respon se, 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 fo r 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 pa rtners. EPA will use information collected for a

variety of purposes, described below:

Partnership Agreement

EPA will use information submitted in the Pa rtnership 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 c ontact 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 m eet specifications developed by WaterSense. Information submitted by

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

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

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



### - 3 -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 th e market, to determine the impact

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

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

and recognize partner accomplishments.

Awards Application Form

EPA will use information from the awards appli cation 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 quarter ly 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 resu lts 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, CONSULTATION S, 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 wate r 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 promotio nal 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:



### - 4 -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 improvi ng 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 submitta l 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 a nd 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-efficien t counterparts, can have a positive impact on the

environment and save money on utility bills. Pa rtners 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 effo rts to generate relevant and timely case studies, provide up-to-date

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

participants. It also would hinder the ability of the Agency to review th e 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 othe r 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 ge neral location (city, state) of certified homes, data



### - 5 -collected for each home per the inspection docume ntation, and a summary of issues and concerns

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

program) collect similar data from certification providers on the same sc hedule. 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 procedur es outlined in ERG’s CBI security plan entitled Security Plan

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

CBI-handling procedures, as outlined in this plan. On ly 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 part ners, 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 cod es 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,



### - 6 -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 WaterS ense 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 docum ents 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 th at 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, pho ne number, fax number, e-mail address, and

primary function of the partner’s primary contact person.

• Approximate number of employ ees at the joining organization.

• How the partner heard about WaterSense.

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

(ii) Respondent activities :



### - 7 -Participants conduct the following activit ies 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, manuf acturing 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 speci fication, 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, m odel number, product URL, product,

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

(ii) Respondent activities :

Participants conduct the following activit ies 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.



### - 8 -Annual Reporting Form

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

describes the participant's Pr ogram-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, na me, 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 bo th WaterSense and non-WaterSense labeled

products (option to provide data confiden tially), 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), p ast 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 activit ies in order to complete and submit the Annual

Reporting Form :



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

or services, number of professionals certifie d, number of homes built/sold, promotional

activities, and/or rebate inform ation 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 r eceive 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 gui delines. These applications will be used to recognize

outstanding accomplishments in each award category. Subm ission of this applicati on 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, ser vice, 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 prov ider partners will complete and submit a list of

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

(i) Data items :



### - 10 -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 locati on 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 documen tation, 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 Wate rSense (how did they hear about it).

 Identification of WaterSense labeled products.

 Message retention.

 Opinion on the value of water.

 Likelihood of purchasing a WaterSense labele d 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.



### - 11 - 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 particip ants regarding membership in the program.

• Review completed agreements, record/ent er 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.



### - 12 -• Communicate reporting requirements to part ners 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 reco rd/enter information into database.

• Develop and make publicly available an a nnual 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.



### - 13 -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 su fficient 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. Licen sed 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 re peat 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 r espondents. 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 responde nt 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 benef its. 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.



### - 14 -Estimating Capital and Operation s 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 r eason, EPA estimates minimal copying, faxing, and mailing

costs ($10 per partner, plus an additional $35 if a pplying 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 incu r an average of $3,565 per product to engage

WaterSense Licensed Certifying Bodies (independent t esting 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 cove red under this ICR. The hourly labor rates used to

determine the estimated costs to the Agency are c onsistent 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, St ep 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 elect ronically rather than mailing paper, so we

have included minimal photocopying and postage costs.

Exhibit 2 shows the aggregate annual Agency bu rden 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 va ries depending upon the specific activity. The

respondent universe for each information collec tion 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 distribut ors, 156 manufacturers, 11 professional certifying organizations, 150

builders/developers, 60 licensed certification provid ers, and 50 commercial an d 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 exis ting categories. Each product category has specific

information that must be submitted by partners who d esire 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.



### - 15 -This translates to 500 products annually. EPA will c ontinue updating the Web regi stry of labeled products

and services on a bi-monthly basis



### .

Annual Reporting Form

EPA requires submission of one A nnual 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 categ ory (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 re ceiving a total of 2,154 annual reporting forms over

three years, with an average of 561 per year for orga nizational partners and 157 fo r irrigation partners.

Awards Application

EPA plans to continue its successful WaterSense awar ds 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 Repor ting 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 burde n 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 Partners hip 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 Fo rm. The annual burden to the universe of respondents

is approximately 21,250 hours, at a cost of approxi mately $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 estim ates 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 a nnual burden over three years. Table 2 summarizes

the total estimated annual and three year costs by sector.



### - 16 -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 bur den hours and costs for respondents and for the

Agency. The total cost for respondents is $3,336,8 14 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 info rmation 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 si nce the current ICR was

approved. The change in burden reflects the substa ntial 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 recordkeepi ng burden for this collection of information is 19

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

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



### - 17 -Product Notification Forms). Award applicants are esti mated 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 progr am is completely voluntary, and thus the entire

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

WaterSense.

Partnership Agreement

The reporting burden for information collection require ments 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 re quirements associated with completing the New

Certified Product Notification Form for product or servi ce 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 collecti on 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 applica tion, gathering data and information for submission,

completing the application, reviewing the informa tion 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 estimat ed to be 26 hours per year. This estimate includes

collecting and reviewing records, reviewing instru ctions, 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.



### - 18 -Burden means the total time, effort, or financ ial resources expended by persons to generate,

maintain, retain, or disclose or provide information to or for a Federal Agen cy. This includes the time

needed to review instructions; develop, acquire, install, and utilize technology and systems for the

purposes of collecting, validating, and verifying informa tion; 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 in formation. An agency may not conduct or sponsor,

and a person is not required to respond to, a collecti on 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-HQ

OW-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-OW

2006-0408.



### - 19 -Exhibit 1. Estimated Annual Respondent Burden and CostInformation Collection ActivityHours and CostsPer Respondent/Labeled ProductTotal Hours and CostsManagerProfessionalClericalRespondHours/YearLabor Costsper Activityper YearAnnualCapitalStartupCostsAnnualO&MCostsNo. ofRespond./ActivitiesTotalRespond.Hours/YearTotalCost/YearHourly Rate87.4273.8936.38Partnership AgreementReview the EPA WaterSense Web site, brochure,agreement, and other necessary materials1203$235.204241,272$99,725Select a primary contact person for the program0.5000.5$43.71424212$18,533Complete the PA, obtain signature of senior official0.51.513$190.934241,272$80,952Send the completed agreement to EPA via fax, mail, email, or online000.50.5$18.19$5.00424212$9,833Subtotal23.51.57$488.032,968$209,043Partnership Agreement: Certified ProfessionalsReview the EPA WaterSense Web site, brochure,agreement, and other necessary materials0101$73.89333333$24,605Complete the PA, locate certification proof document0101$73.89333333$24,605Send the completed agreement and certification proof toEPA via fax, mail, e-mail, or online00.500.5$36.95$5.00333167$13,968Subtotal02.502.5$184.73833$63,178New Certified Product Notification FormApply for label from approved licensed certifying body1809$678.54$3,500.00$50.005004,500$2,114,270Collect records of each service or product0202$147.78$5.005001,000$76,390Select a primary contact person to answer questions fromEPA's WaterSense Team0.250.2500.5$40.33500250$20,164Complete the notification form1102$161.315001,000$80,655Send the completed application to EPA via fax, mail, email or online000.50.5$18.19$10.00500250$14,095Answer questions from EPA1102$161.315001,000$80,655Subtotal3.2512.250.516$1,207.468,000$2,386,229Annual Reporting FormCollect and review records to assess product shipment orsales data, purchased products or services, promotionalactivities, rebate information during the reporting year1506$456.875613,366$256,304- 20 -Review instructions00.500.5$36.95561281$20,726Complete the Annual Reporting Form1304$309.095612,244$173,399Send the completed update to EPA via fax, mail, e-mail, oronline000.50.5$18.19$5.00561281$13,010Respond to EPA questions to clarify data0101$73.89561561$41,452Subtotal29.50.512$894.996,732$504,892Annual Reporting Form: Certified ProfessionalsCollect information to assess the practice of efficientirrigation design and maintenance or use of labeledproducts0101$73.89157157$11,601Review instructions00.500.5$36.9515779$5,800Complete the Annual Reporting Form00.500.5$36.9515779$5,800Send the complete update to EPA via fax, mail, e-mail, oronline00.500.5$36.95$5.0015779$6,585Respond to EPA questions to clarify data00.500.5$36.9515779$5,800Subtotal0303$221.67471$35,587Awards ApplicationsReview instructions and eligibility requirements1102$161.3183166$13,389Gather data2507$544.29$5.0083581$45,591Complete application and supplemental materials28010$765.96$10.0083830$64,405Submit the application via fax, mail, e-mail, or online0011$36.38$20.008383$4,680Subtotal514120$1,507.941,660$128,064Provider Quarterly Reporting Form (Annualized)*Collect and review records48012$940.8020240$18,816Review instructions0101$73.892020$1,478Complete report012012$886.6820240$17,734Submit the report via fax, mail, e-mail, or online0011$36.38$20.002020$1,128Subtotal421126$1,937.75520$39,155Consumer Awareness SurveyReceive survey request and instructions and respond toquestions0.1250.1250.25$13.7826667$3,666Subtotal0.1250.1250.25$13.7826667$3,666TOTAL16.2565.8754.62586.75$6,456.342,34421,250$3,369,814*Quarterly Reports will be requested 4 times a year; datapresented on annual basisThree Year Burden63,750$10,109,442- 21 -Exhibit 2. Estimated Annual Agency Burden andCostInformation Collection ActivityHours and CostsPer Respondent/Labeled ProductTotal Hours and CostsManagerTechnicalClericalRespondHours/YearLabor Costsper Activityper YearAnnualCapitalStartup CostsAnnualO&MCostsNo.ofAgency/ActivitiesTotal AgencyHours/YearTotalCost/YearHourly Rate70.6051.7920.79Partnership AgreementDevelop Partnership Agreements and post to Web site260.58.5$462.34325.5$1,387Answer questions posed by potential participantsregarding membership in the program0202$103.58379758$39,257Review completed agreements, record/enterinformation into a database, and update WaterSenseWeb site1427$319.347575,299$241,740Respond to the partner to welcome them toWaterSense or explain why organization is ineligible forpartnership0.5000.5$35.30757379$26,722Sign agreement0.50.512$81.99$2.0075710,200$63,577Subtotal412.53.520$1,002.5416,661$372,683New Certified Product Notification FormDevelop application materials to be submitted bypartners and post to Web site28010$555.52880$4,444Answer partner questions about form, reviewcompleted forms submitted by partner and clarify anyinconsistencies between the form and the certificationfile0.50.523$102.78$5.005001,500$53,888Enter data into program database0011$20.79500500$10,395Respond to partner to inform them that the form hasbeen accepted, or to explain why it could not beaccepted0.5000.5$35.30500250$17,650Compile list of products by product type to post onEPA’s WaterSense Web site0404$207.165002,000$103,580Disseminate updated list as requested0123$93.37$20.005001,500$56,685Subtotal313.5521.5$1,014.925,830$246,642Annual Reporting FormsDevelop/revise standard data reports andcommunicate reporting requirements10401060$2,985.50160$2,986Answer questions regarding the Annual ReportingForm0202$103.58$2.00359718$37,903- 22 -Receive and review the reports for consistency andcompleteness and place any follow-up calls necessary1304$225.97$1.007182,872$162,964Maintain a tracking system to record/enter informationinto database0022$41.587181,436$29,854Develop annual data summary1010020130$6,300.80$5.001130$6,306Subtotal2114532198$9,657.435,216$240,013Awards ApplicationsMaintain a tracking system to record each participant’saward application status020525$1,139.75125$1,140Develop application to be submitted by partners, postto Web site, and communicate requirements forapplying0202$103.5883166$8,597Respond to partner questions about award applications28212$597.10$2.0042504$25,162Determine which applications deserve recognition460064$3,389.80$10.00835,312$282,183Subtotal6907103$5,230.236,007$317,082Provider Quarterly Reporting Form (Annualized)*Develop reporting form48012$696.72112$697Maintain a tracking system to record results of report indatabase10301454$2,550.7610540$25,508Answer partner questions about information to besubmitted0044$83.162080$1,663Compile list of number of homes and general locationto post on Web site0808$414.3220160$8,286Subtotal14461878$3,744.96792$36,154Consumer Awareness SurveyCraft sampling methodolgy824032$1,807.76264$3,616Select sample024024$1,242.96248$2,486Develop survey script and instructions1020030$1,741.80260$3,484Implement survey8040040520$27,195.60$2,000.0021,040$58,391Analyze data201200140$7,626.802280$15,254Subtotal11858840746$39,614.921,492$83,230TOTAL166895105.51166.5$60,265.0035,998$1,295,804*Quarterly Reports will be requested 4 times a year;data presented on annual basisThree Year Burden107,994$3,887,413- 23 -