1 **SUPPORTING STATEMENT FOR LANDFILL METHANE OUTREACH PROGRAM,**  **EPA INFORMATION COLLECTION REQUEST NUMBER 1849.0**  **6**

**April 12**  **, 2012**2

**1. IDENTIFICATION OF THE**  **INFORMATION COLLECTION 1(a)**  **Title of the Information Collection** This renewal information collection is entitled “Reporting Under EPA ’ s Landfill Methane Outreach Program”, IC R number 1849.0 6 . **1(b) Short Characterization/Abstract**  The Landfill Methane Outreach Program (LMOP), created by EPA as part of the Climate Change Action Plan, is a voluntary program designed to encourage and facilitate the development of enviro nmentall y and economicall y sound landfill gas (LFG) energy projects across the United States in order to reduce methane emissions from landfills . LM OP does this by educating local governments and communities about the benefits of LFG recovery and use; building partnerships between state agencies, industry, energy s ervice providers, local communities, and other stakeholders interested in developing this valuable resource in their community ; and providin g tools to evaluate LFG energy potential . To continue to be successful it is critical that LM OP gather information from its Partner s about their activities and how the program can improve its support to them. Additionally, in order for LMOP to improve the data quality in one of its critical program tools, the LM OP Landfill and LFG Energy

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

 pre - populated E xcel spreadsheets; and
 electronic periodic information updates. The LMOP information collection is expected to involve an average of 1,220 existing Partners and an additional 11 3 new Partners per year. The average annual burden (rounded to one decimal place) and cost per respondent are estimated to be 3.2 hours and $2 51 . The total annual reporting and recordkeeping burden averaged over three ye ars is 4,215 hours and $ 3 34,298 .3

This I CR provides a comprehensive description of the i nformation collections under LMOP . Sections 1 through 5 of this ICR describe th e specific information collections (e.g., from the standpoint of need, use, and respondent activities). In Section 6, EPA estimates the annual hour and cost burden to respondents and the Agency under these collections. **2. NEED FOR AND USE OF THIS COLLECTI ON**  **2(a) Need/Authority for the Collection**  EPA needs to collect the information in the MOU to formall y establish participation in LMOP and to obtain general information about new Partner s. Additional information collected from certain ty

pes of Partners thro ugh spreadsheets is needed to allow EPA to track, facilitate, and encourage the implementation of LFG energy projects. This information collection will assist LMOP in decreasing methane emissions from landfills, increasing the use of methane as a renewable energy re source, and reducing emissions due to the burning of non - renewable energy re sources such as coal and fuel oil. Participation in LMOP is voluntary . The f ive categories of participants are:

 C ommunity Partner s;  State Partner s;  Industry Partner s (dev elopers and non - developers);

 Energy Partner s; and

 Endorsers . All participant s , in completing the MOU, agree to provide EPA with information requested in the MOU and provide contact information for their LMOP coordinator. Industry Developer and Energy Partners agree to provide information on LFG energy projects with which they have been involved. Community Partner s agree to provide information on the progress of implementing LFG energy projects at their landfill(s). **2(b) Practical Utility/Users of the**  **Data** EPA uses information submitted in the MOU to update its database of LMOP Partner s. The database serves as a source of general information and a n electronic mailing list. EPA use s information in spreadsheet attachments submitted by Industry Developer , Energy , and Community Partners to monitor the progress of LFG energy projects and identify opportunities4

for new projects. EPA also uses the data to prepare reports on LFG energy projects and the progress of LMOP. EPA uses case studies of successful LFG en ergy projects to demonstrate to existing and potential Partner s the cost savings and environmental benefits associated with capturing and using LFG . General information about the Partners, operational and under construction LFG energy projects , and landfil ls that may have potential for developing LFG energy projects is also provided on the LMOP w ebsite, making it available to other LMOP Partners as well as the public. During EPA fiscal year 20 11 , LMOP processed approximately 90 data requests from the public that required accessing data in the LMOP Landfill and LFG Energy Project database . **3 . NONDUPLICATION**  **, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 3(a)**  **Nonduplication** For new Partner s, the information to be collected has not previously been collected by EPA or any other Federal Agency. For existing Partner s with LFG energy projects, some of the information required may be available in the existing LMOP database. To avoid requesting in formation that has already been collected, spreadsheets sent to existing Partners will be pre populated with information from the LMOP database. Recipients of the spreadsheet s will be asked to review the information provided. Onl y if the information is inc orrect or out of date will the recipients be re quested to provide updated or additional information. EPA began annually

collecting certain technical and informational data from MSW landfills under the Greenhouse Gas Reporting Program (GHGRP) 40 CFR part 98 , subpart HH in 2011. However, the data collected under GHGRP subpart HH are currentl y very limited in scope and therefore do not overlap to much extent with the data that LMOP collects from its Partners about landfills and LFG energy projects. **3(b) Public Noti**  **ce Required Prior to ICR Submission to OMB** Incompliance with the Paperwork Reduction Act of 1995, EPA solicited public comments on the ICR through an announcement in the Federal Register on J anuary 27, 2012 ( 7 7 FR 4297 ) . The Agency did not receive any

comments on this ICR renewal. **3(c) Consultations** 5

In 2007, LMOP contacted fewer than nine P artners on the preferred format for making updates to their LFG energy projects and landfills. LM OP provided a choice of using the online data update forms used in I CR 1849.02 , or an email with a pre - populated spreadsheet attachment f or all of their projects /landfills . All P artners were either indifferent between these two options or preferred the new spreadsheet inf ormation collection method to the old online form. **Table 1**  **: List of Pa rtner Consultations Made in 2007**  **Partner Type Contact Person,**  **Organization Phone Number**  Industry Partner, developer Jerry Leone, Casella Waste 607 - 435 - 9996 Industry Partner, developer Dawn Semple, Granger Energy 517 - 371 - 9722 Industry Partner, developer David Mauney, CPL Systems 337 - 269 - 4699 x1167 Industry Partner, developer John Bean, G2 Energy 281 - 222 - 1037 Community Partner Megan Miller, Hillsborough County, FL 813 - 276 - 2956 Community Partner Vance Kemler, City of Denton , TX 940 - 349 - 8044 In 2008, LMOP also contacted fewer than nine Partners regarding the burden of this information collection, considering the new methodology of collecting landfill and LFG energy project data with pre - populated spreadsheets sent via email . The Partners contacted agreed that the estimated burden b y Partner type is what they would expect for this effort or the amount they expect is less than the estimate.

**Table 2**  **: List of Pa rtner Consultations Made in 2008**  **Partner Type Contact Person,**  **Organization Phone Number**  Industry Partner, developer Jerry Leone, Casella Waste 607 - 435 - 9996 Industry Partner, developer David Mauney, CPL Systems 337 - 278 - 7899 Community Partner Megan Miller, Hillsborough County, FL 813 - 276 - 2956 In 2012 , LMOP contacted fewer than nine Partners regarding the burden of this information collection, in regards to the current methodology of collecting landfill and LFG energy project data with pre - populated spreadsheets sent via email. The Partners contacted agreed that the estimated burden by Partner type is what they would expect for this effort or the amount6

they expect is less than the estimate.

**Table 3**  **: List of Pa rtner Consultations Made in 2012**  **Partner Type Contact Person, Organization**  **Phone Number** Industry Partner, developer Alan Petersen, INGENCO 804 - 521 - 3515 Energy Partner Nathan Schock, POET 605 - 965 - 6428 Community Partner Billy Malone, DeKalb County Sanitation, GA 404 - 294 - 2927 **3(d) Effects of Less Frequent Collection**  The MOU are submitted once by organizations that choose to become P artners of LMOP. To allow EPA to remain current on LFG energy projects, Industry Developer , Energy, and Community

P artners directly

involved in projects will be asked to update the landfill and LFG energy project data spreadsheets annuall y. All Partners may also update company

and contact information periodicall y. EPA believes that any reduction in the frequency of this information collection would impede efforts by EPA to evaluate results of the program, facilitate LFG energy project implementation, and respond in a timely manner to needs of the P artners. **3(e) General Guidelines**  This information collection request was prepared in compliance with OMB’s and EPA’s guidelines for ICR preparation. **3(f) Confidentiality**  Participation in LMOP is voluntary . Participants are not required to reveal confidential business information. Additionall y, participants will be given specific instructions to not provide any information that they

consider confidential. **3(g) Sensitive Questions**  No questions of a sensitive nature are asked in the MOU, pre -populated l andfill and LFG energy project data spreadsheets , or periodic information updates. **4. THE RESPONDENTS AND THE INFORMATION REQUESTED 4(a)**  **Respondent NAICS Codes**  This information collection will encompass a wide variety of respondents. Community P artners include local agencies and municipalities that own landfills. State agencies involved in7

energy, air pollution, and solid waste management are represented through State P artners. Industry Partners include engine and turbine manufacturers, engineering firms, construction companies, environmental consultants, and other companies involved in the logistics of developing LFG energy projects such as law firms and financin g companies. Industry P artners are further divided into two groups: (1) developers are organizations that facilitate, finance, and implement LFG energy projects; (2) non - developers are manufacturers or suppliers of equipment or expertise needed to collect and utilize LFG . Energy P artners include utility

companies who purchase energy generated from landfills, power marketers, and direct end users of energy from the landfill. The direct end user category is potentiall y the most diverse category . Any facility located near a landfill that utilizes fuel either in manufacturing products or in heating the facility is a po tential LFG end user. Finall y, Endorsers are non - profit organizations coordinating with EPA to publicize and promote the use of LFG among their members or constituents. These include several trade associations representing the solid waste industry, public works, municipalities, and renewable energy. Table 4 provid es the North American Industry

Classification S ys tem (NAICS) code and description for the respondents . **Table 4**  **: Respondents to Information Collection Partner Type**  **NAICS Code NAICS Description**  Community Partners and State Partners 924 Public Administration, Administration of Environmental Quality Programs 924110 Public Administration, Administration of Air and

Water Resource and Solid Waste Management Programs 926130 Public Administration, Regulation and Administration

of Communications, Electric, Gas, and Other Utilities Industry Partners 333611 Turbine and Turbine Generator Set Units Manufacturing 333618 Other Engine Equipment Manufacturing 541330 Engineering Services 541620 Environmental Consulting Services 562212 Administrative and Support and Waste Management

and Remediation Services, Solid Waste Landfill 541110 Offices of Lawyers 522110 Commercial Banking 523910 Financial Investments and Related Activities,

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

325412 Pharmaceutical Preparation Manufacturing 327121 Brick and Structural Clay Tile Manufacturing 327310 Cement Manufacturing8 **Partner Type NAICS Code**  **NAICS Description**

334210 Telephone Apparatus Manufacturing 33422 0 Radio and Television Broadcasting and Wireless

Communications Equipment Manufacturing 336111 Automobile Manufacturing 325411 Medicinal and Botanical Manufacturing 331511 Iron Foundries 311111 Dog and Cat Food Manufacturing 311421 Fruit and Vegetable Canning 311911 Other Food Manufacturing Power marketers and utilities 221121 Electric Bulk Power Transmission and Control

221122 Electric Power Distribution 221119 Other Electric Power Generation Endorsers 813910 Business A ssociations a. There is a wide variety of entities that could become direct LFG users. Any facility near a landfill that uses fuel is a potential direct user. A subset of the NAICS codes and descriptions from current direct energy users are included in Table 4 . **4(b) Information Requested**  **(i) Data Items, Including Recordkeeping R**  **equirements** In formation will be collected in MOU, pre -populated electronic spreadsheets, and through periodic updates. The MOU request the following information from all P artners:
 Name of the organization;

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

 In formation about the LMOP coordinator including name, title, address, phone number, fax number, and email address;

 Brief description of the organizati on;

 Organization’s w ebsite address; and

 A camera - ready cop y of the organization’s logo or seal. Pre -populated electronic spreadsheets request Industry Developer , Energy, and Community Partners to up date existing critical LFG energy project data necessary f or tracking greenhouse gas reductions from LFG energy projects , such as project size and start year. All P artners may

provide information through periodic updates. These updates will mainly be changes to contact information fo r LMOP coordinators and exper ts, but th ey

can also include9

providing or updating a brief description of the organization which LMOP will post on the LMOP w ebsite to provide publicity and enco urage networking among Partners. LMOP may also call a selection of Partners to confirm or update project information that LMOP has received through the media or industry

contacts. Participation in LMOP does not require any records to be kept, although P artners will likely keep file copies of MOU and spreadsheets submitted to EPA. **(ii) Responden**  **t Activities** The respondent activities depend on the aspect of the information collection to which they are responding. In completing the MOU, respondents will:

 review the MOU ;  complete the MOU on line or in hardcop y ;  sign and submit the form electronically or in hardcopy to EPA; and

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

 complete or update information in the spreadsheet ;  email or mail the spreadsheet to EPA; and
 file a cop y of the spreadsheet . In repl yi ng to or initiating an information update, respondents will:
 gather information; and
 provide information via the LMOP w ebsite , email, or telephone interview. **5. THE INFORMATION COLLECT**  **ED -**  **AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT**  **5(a) Agency Activities**  Agency activities associated with this information collection depend on the aspect of the information collection that the agency has received. In receiving the MOU, the agency will:

 review the information provided;
 sign the MOU ;  return a cop y of the signed MOU to the P artner;10

 enter the information into a database; and
 file the MOU . In requesti ng and receiving information through a pre - populated spreadsheet, the agency will:
 populate the spreadsheet with landfill and/or project data specific to the Partner and s end the spreadsheet via email ;  review the information provided and follow up if neces sary ;  enter information into a database; and
 file the spreadsheet . In receivin g an information update from a P artner, the agency will:

 review the data; and
 revise data in the database based on the update. In initiating an information update, the agency will:
 call or email the P artner;
 request updated information; and
 revise data in the database based on the updates. **5(b) Collection Methodology and Management**  The methods selected for this information collection are chosen based on efficiency and minimization of burden for respondents and EPA. The MOU can be downloaded from the LMOP w ebsite and returned to EPA either b y fax or mail, or submitted electronically. General P artner information will be posted on the LMOP w ebsite where it can b e reviewed for accuracy by the Partner and revised if necessary . Spreadsheets will be emailed to all Industry Developer , Energy , and Community

P artners. All inform ation received through the spreadsheets will be reviewed by EPA before being entered into the Landfill and LFG Energy Project database. **5(c) Small Entity Flexibility**  EPA expects that some LMOP Partners are small entities. LM OP reviewed company w ebsites and organization descriptions when available for all Energy Partners and a portion of Industry Partners to help determine the companies ’ small entity status. LM OP determined whether Community

Partners are small entities based on the population served b y these government agencies as further described below. LMOP assumed for this estim ate of small entities that all State Partners, which represent S tate governments , are not classified as small entities, since each State population is greater than 50,000. LMO P also assumed that all of its Endorsers, which are11

non - profits, were classified as small entities. LM OP conducted a similar review of its Partners’ small entity

status in 2007 for the previous I CR renewal . The 2007 anal ys is for small entity status covered all Partners since the program inception through those that joined in September 2007, including many of the industry leaders. The 2012 small entity anal ys is focused on Partners joining after September 2007, and included a larger number of start - up companies and small c onsulting firms that had not previously joined LMOP. As a result of these estimates and assumptions, LMOP estimated the number of small entities affected per ye ar according to the type of respondent, as shown in Table 5 . To estimate the number of small entities for existing sources, LMOP summ ed the number of sm all entities identified in 2007 with the number of small entities identified in 2012 for each Partner category . For Industry

Partners, LMOP’s p artnership currently encompasses most of the larger players in th e LFG industry , and new private - sector Partners joining LMOP in the future are more likely to be smaller companies. To estimate the number of small entities expected for new Industry Partners, the numbers in Table 5 reflect LMOP’s assumption that the distribution of small entities within each new Industry Partner category (developer and non - developer) will be similar to the distribution anal yz ed for Partners that joined LMOP between 2007 and 2011 . For new Community and Energy Partners, the average percentage of small entities from both the 2007 and 2012 small entity

searches are applied, since communities or energy consumers of any size are eligible to sign up as LMOP Community or Energy Partners and LMOP cannot predict what size entities will sign up for the program in the future.

**Table 5 : Estimate**  **of Small Entities for Each Respondent Category Respondent Category**  **New Existing**  State Partners 0 0 Community

Partners 3 1 9 Endorsers 9 33 Energy 7 31 Industry Partner, developers 24 87 Industry Partner, non - developers 132 232 Total 175 402 For Community

Partners, which represent local or regional government entities, LMOP reviewed the list of Community Partners and compared it to a table corresponding to 20 10 city or county populations 1 for Partners joining since September 2007 in order to d etermine the small entity status. ( During the previous I CR renewal, LMOP compared existing Partners to a table

1 http://quickfacts.census.gov/qfd/index.html12

corresponding to 2006 city or county

populations. ) Approximately 16 percent of existing C ommunity P artners are in cities or counties with populations less than 50,000 , which is the threshold for small entities within the public administration sector. For solid waste authorities that encompassed more than one jurisdiction, the populations for all member jurisdictions were summed t o determine if the entity was small. The majority

of Energy

Partners are power providers, marketers, or energy end users. Within the power provider sector, the only small businesses are a number of rural cooperatives that have j oined as Partners ; the rest of the power provid ers are utilities or power marketers that are large businesses . Within the energy end - user sector, many of the companies are large corporations such as Wal - Mart, PepsiCo, Ajinomoto, and Coca - Cola Refreshments , which have a larger energy

demand. Approximately 31 small businesses , such as POET (ethanol plant), State Fair Community

College, and L orton Arts Foundation, have a single facility that use s LFG to meet its energy

needs. Given the large number of existing Industry Partners , LMOP reviewed w ebsites and organization descriptions for 60 percent of the project developer Partners and 51 percent of the non - developer Partners. The companies who provided websites when joining LMOP but whose w ebsites were not reviewed as part of this 2012 analy sis w ere assumed to contain a similar percentage of small businesses as those reviewed . A small portion of Industry Partners did not have websites and most of these were assumed to be small businesses with the exception of a few companies that were known to be large after reviewing the company name. Within the developer category , a majority of these Partners have a nationa l presence in the LFG industry

and are involved in multiple projects, likely meeting the size criteria for large businesses , and thus are not considered small businesses. However, the majority of Industry Partners that have joined since 2007 are start - up companies or small consulting firms . Sixty- five percent of the developers who joined since 2007 that had websites reviewed were classified as a small business and m ost of these small businesses serve a small niche market, have an obvious ly small number of employees, or work within a small service region. LMOP expects future new project developer Partners are likel y to be smaller companies. The non - developer Industry Partner cat egory

includes manufacturers or suppliers of equipment or expertise needed to collect and utilize LFG. A majority of these businesses are large and supply

multiple solid waste facilities with the engineering, equipment, or construction services needed to build and maintain an LFG energy project or LFG collection system. Based on13

a review of w ebsites, 54 percent of non - developers who joined since 2007 were classified as small business es; these businesses may include smaller local engineering companies or suppliers of niche products that are not needed in all LFG energy applications. After considering those Partners without websites, 49 percent of the existing project developer Partners and 45 percent of the existing non - deve loper Partners were considered to be small businesses. EPA has designed its approach for this information collection to minimize burden for all respondents while obtaining sufficient and accurate informatio n. P articipation in LMOP is voluntary . Any

small entity

that finds the information collection overl y burdensome is not required to participate. **5(d) Collection Schedule**  EPA will collect general information in the MOU, which are completed and submitted by each P artner upon their agreement to participate in the program. EPA will collect additional information through pre - populated spreadsheets . These spreadsheets will be completed annually by Industry Developer , Energy, and Community P artners . In formation may also be updated periodicall y at the request of EPA or the P artner. **6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 6(a)**  **Estimating Respondent Burden** In order to obtain accurate hourly burden and cost estimates, EPA consulted with fewer than nine P artner s regarding burden and cost assumptions in 200 7, 2008, and 2012 . For this renewal I CR, c ost estimates were increased to account for an incre ase in wages and the number of P artners. The hourly

burden estimates for Industry Developer and Community Partners remained the same as in the 2008 renewal because the data collection methodology and number of data fields is the same as in the 2008 renewal. The hourly burden estimates for Energy Partners were increased as Energy

Partners will be requested to provide upd ates for LFG energy projects with which they

are involved in the I CR going forward. Attachment A presents the estimated average annual P artner respondent burden and costs during the next 3 - ye ar ICR period for each typ e of Partner . Table 6 presents a summary of the respondent burden. **6(b) Estimating Respondent Costs**  **(i) Estimating Labor Costs** 14

F or private - sector respondents (Industry and Energy

P artners), EPA used a national average hourl y labor rate (hourly rate plus 110% overhead) of $12 6.66 for legal staff, $ 1 19.13 for managerial staff, $ 87.59 for technical staff, and $ 4 9.80 for clerical staff. Managerial, technical, and clerical labor rates were obtained from the Bureau of Labor and Statistics average rates for Professional, Scientific, and Technical Services (NAI CS code 541000). Legal rates we re based on lawyers, management wages were based on managers ( all other) , technical wages were based on environmental engineers, and clerical rates were based on executive secretaries and administrative assistants for May 20 10 . A June 20 11 labor rate for all rates was estimated by appl yi ng a 1.9 % growth factor from the E mploy ment C ost Index to account for increases in wages from June 20 10 to June 20 11 . The Employment Cost Index for wages and salaries, b y ownership, occupational group, and industry

is located at: http://www.bls.gov/news.release/eci.t02.htm . For public - sector respondents (Community and State P artners), EPA used the same labor rates used for EPA personnel (see Section 6(c)). These rates are comparable to rates provided b y a Community

P artner in 2000 and using them for all public - sector employees provides consistency . For non - prof

it sector respondents (Endorsers ), EPA used a national average hourly labor rate (hourl y rate plus 110% overhead) of $ 97.99 f or managerial staff, $ 79.15 for technical staff , and $4 7.16 for clerical staff . Managerial, technical, and clerical labor rates were obtained from the Bureau of Labor and Statistics average rates for Business, Professional, Labor, Political, and Similar Organizations (NAI CS code 813900) . M anagement wages were based on managers ( all other) , technical wages were based on environmental engineers, and clerical rates were based on executive secretaries and administrative assistants for May 20 10 . A June 20 11 labo r rate for all rates was estimated b y applying a 1.9 % growth factor from the Employ ment C ost Index to account for increases in wages from June 20 10 to June 20 11 . The Employ ment Cost Index for wages and salaries, b y ownership, occupational group, and industry is located at: http://www.bls.gov/news.release/eci.t02.htm . **(ii) Estimating Capital and Operations and M**  **aintenance Costs** Because this information collection requires respondents onl y to report information that is already available to them, there are no capital costs. EPA does not expect that the operations and maintenance (O&M) costs of this program will be significant. The onl y O&M costs expected are for postage potentially

necessary to mail in the MOU and the majority of LMOP Partners (approximately

90 percent) submit MOU electronically . A postage cost of $3.00 is attributed to all activities involving mail ing materials to account for the use of trackable mail. It is assumed that all15

LFG energy project data updates from Industry Developer , Energy, and Community P artners will be submitted electronicall y, so the ir onl y trackable mail costs are associated with submitting the ir MOU. The average annual O&M cost over three years is $3 39 . **Table 6 : Summary of Respondent Burden**  **New Existing**  **Partner Average Annual Burden**  **Total for 3**  **- year ICR**  **Period**
Hours Community 56 714 2, 309 Endorser 6 1 5 63 Industry Non - Developer 2 67 930 3,590 Energy and In dustry- Project Developer 195 2,015 6,630 State 2 16 54 **Total Hours 525**  **3,690 12,645**  **Average Burden per Partner 4.6**  **3.0 --** 

Cost **Partner** Community $ 2,766 $3 4,761 $11 2,582 Endorser $ 46 4 $ 1,187 $ 4,955 Industry Non - Developer $ 24,934 $ 81,455 $ 319,166 Energy and In dustry

Project Developer $ 17,027 $ 170,761 $ 563,364 State $1 1 7 $ 825 $ 2, 826 **Total Cost $45,309**  **$288,989 $1,002,893**  **Average Cost per Partner $401**  **$237 --**  **6(c) Estimating Agency Burden and**  **Costs** Attachm ent B presents the estimated Agency burden hours and costs for the information collection activiti es associated with LMOP. Table 7 presents a summary of the agency

burden. EPA estimates an average hourly labor cost (lab or plus 60% for overhead) of $7 6.38 for managerial staff, $ 52.37 for technical staff, and $ 21.02 f or clerical staff. To derive these estimates, EPA used the “Salary

Table 20 11 - GS” from the Department of Personnel Management , available at http://www.opm.gov/oca/11tables/pdf/gs_h .pdf . For purposes of this I CR, EPA assigned staff the following government service levels:

 Managerial Staff - GS - 15, Step 1
 Technical Staff - GS - 12, Step 5

 Clerical Staff - GS - 5, Step 1

**Table 7**  **: Summary of Agency Burden 20**  **12 20**  **13 201**  **4 Average**  **Total**16 Hours 1,715 1, 832 1, 949 1,832 **5,495** Cost $ 88,706 $ 94,846 $ 100,947 $ 94,833 **$ 284,498**  **6(d) Estimating the Respondent Universe**  The number of LMOP P artners has grown significantly since the last ICR renewal. Table 8 presents a summary

of the respondent universe by LMOP P artner category for the next 3 - year ICR period . The burden estimates are based on the total respondent universe. The historical response rates to previous LMOP ICRs are approximately 25 %.

**Table 8 : Summary of LMOP Partners and**  **Other Respondents** 

**20 12**  **20 13**  **201 4**  **Average Partner**  1 **Existing New**  **Existing New**  **Existing New**  **Existing New**  Community 1 29 7 1 36 7 14 3 7 1 36 7 Endorser 36 3 39 3 42 3 39 3 Energy 120 8 1 28 8 1 36 8 1 28 8 Industry N on - D eveloper 662 82 744 82 826 82 744 82 Project D eveloper 1 20 12 1 32 12 1 44 12 1 32 12 State 40 1 41 1 42 1 41 1 **TOTAL 1,107**  **11 3**  **1,220 11**  **3 1,333**  **11 3**  **1,220 11**  **3** 1 Staff with experience in managing the LMO P P artner database provided insight on future program growth by P artn er category. The number of new Partners each year for each Partner type is expected to equal the average of the number of Partners for each type that joined the program during the 5 - year period from 2007 through 2011. **6(e) Bottom Line Burden Hours and Costs**  Over the 3 - ye ar period covered by this ICR, EPA estimates the total respondent burden of the program to be 1 2,645 hours and $ 1, 002,893 , of which $ 1,260 is O&M . EPA estimates the total Agency

burden to be 5,495 hours and $ 284,498 . The annual respondent burden, averaged ov er the three - ye ar period, is 4,215 hours and $ 3 34,298 , of which $ 420 is O&M , and the annual Agency burden, averaged over the three - ye ar period, is 1,832 hours and $ 94,833 . The total burden for existing P artner respondents will increase gradual ly over each ye ar of the 3 - ye ar I CR period to reflect an increase in the total number of existing P artners , although the burden per respondent will remain constant . The burden and costs shown for each existing P artner category in Attachment A reflect the average number of P artners during the 3 - ye ar ICR period. The bottom line burden for new P artners will stay the same for each year of thi s I CR, since the number of new P artners joining each year is expected to remain relativel y constant over th e 3 - ye ar ICR period.17

**6(f) Reasons for Change in Burden**  Under this renewal ICR, the total respondent burden over the 3 - year period is 1 2,645 h ours , or an average of 4,215 hours per ye ar . The 200 8 IC R total respondent burden was 17,656 hours, or an average of 5, 885 hours per ye ar. A significant reason for the decrease in total hourly burden is that under the last I CR renewal, LMOP made provisions for a one - time effort to collect critical landfill data from other landfill owners/operators, and this initiative is not included in this current ICR renewal. To a lesser magnitude than the decrease discussed above, there is an increase in total hourly burden for Partners as LMOP will now collect landfill/project data from Energy Partners, and also due to an increase in the number of Partners in all Partner categories. For perspective on the magnitude of Partner growth, the number of Partners at the end of 200 7 was 719 , whereas there were 994 Partners as of September 2011 . The tot al cost estimate over the 3 - ye ar period for this renewal ICR is $1,0 02,893 , or an average of $3 34,298 per year , of which $ 1,260 is O&M costs . In the 200 8 ICR renewal, the total cost over the 3 - ye ar period was $ 1,034,482 . The total cost estimate is slightly lower for this ICR renewal due to the one - time effort related to other landfill owners/operators not occurring which is offset by an increase in the number of P artners and increases in wages. **6(g) Burden Statement**  The overall annual public reporting and recordkeeping burden for this col lection of information is estimated to average 3.2 hours and $2 51 per respondent . The burden per respondent is determined by which ty pes of information collection requests the respondent is affected. The average annual burden for new LMOP P artners is 4.6 hours per respondent and the average annual burden for existing P artners is 3. 0 hours per respondent. Over the 3 - ye ar period covered b y this ICR, EPA estimates the burden of the program to be 1 2,645 hours and $1,0 02,893 for respondents, and 5,495 hours an d $ 284,498 for EPA. Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, and disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and sy stems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to compl y with any previously applicable instructions and requirements; train personnel to be able to18

respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currentl y valid OMB control number. The OMB control numbers for EPA ’ s regulations are listed in 40 CFR part 9 and 48 CFR chapter 15. The average per Partner reporting burden for activities associated with completing the MOU is estimated to be 2.0 hours. The burden estimate includes time to review, complete, sign, and submit the MOU. The average per respondent reporting burden for Industry D eveloper , Energy , and Community

P artner activities associated with completing the pre - populated spreadsheets is estimated to be 5.7 hours. The burden ranges from 4 hours for existing Community Partners to 6 .5 hours for new Industry P artners who are developers. The burden estimate includes time to review the spreadsheet and instructions, gather the requested information, complete/update the spreadsheet , an d submit the spreadsheet to EP A. The burden for each typ e of P artner is shown in Attachment A and the total burden is summarized in Table 6 . The average per respondent reporting burden for activities associated with periodic information updates is estimated to be 2 .5 hours for Energy, Industry, and Community Partners . The average per respondent reporting burden for activities associated with periodic information updates is estimated to be 1 hour for State Partners and Endorsers. The burden estimate includes time to gather the requested information and provide the information to EPA. To comment on the A gency ’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 I CR under Docke t ID EPA - HQ - OAR - 200 3 - 0078 , which is available for online viewing at www.regulations.gov, or in person viewing at the Air and Radiation Docket in the EPA Docket Center ( EPA/DC ) , EPA West, Room 3334, 1301 Constitution Ave. NW, Washington, DC. The EPA/DC Publ ic Reading Room is open from 8 a.m. to 4:30 p.m., Monday through Friday , excluding legal holiday s. The telephone number for the Reading Room is 202 - 566 - 1744, and the telephone number for the Air and Radiation Docket is 202 - 566 - 1742.

An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and access those documents in the pu blic docket that are available electronicall y. In19

the sy stem, select “search,” then key in the Docket ID Number identified above. Alternativel y, send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk Office for EPA. Please include the EPA Docket ID No . EPA - HQ - OAR - 200 3 - 0078 in any correspondence .**ATTACHMENT A -**  **ESTIMATED AVERAGE RESPONDENT BURDEN AND COST**

A - 1 Existing State Partners A - 2 New State Partners A - 3 Existing Endorsers A - 4 New Endorsers A - 5 Existing In dustry Non - Developer Partners A - 6 New In dustry Non - Developer Partners A - 7 Existing Community Partners A - 8 New Community Partners A - 9 Existing Energy and I ndustry - Project Developer Partners A - 10 New Energy and I ndustry - Project Developer Partners **ATTACHMENT B**  **- ESTIMATED AGENCY BURDEN AND COST**  B - 1 Agency Burden 20 12 B - 2 Agency Burden 20 13 B - 3 Agency Burden 201 4