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SUPPORTING STATEMENT FOR

LANDFILL METHANE OUTREACH PROGRAM,

EPA INFORMATION COLLECTION REQUEST NUMBER 1849.06

April 12, 2012
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1. IDENTIFICATION OF THE INFORMATION COLLECTION

1(a) Title of the Information Collection

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

Outreach Program”, ICR number 1849.06.

1(b) Short Characterization/Abstract

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

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

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

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

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

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

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

tools to evaluate LFG energy potential. 

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

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

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

LFG Energy Project database, LMOP must gather basic physical and operational data from 

municipal solid waste (MSW) landfills without LFG energy projects. Improving the data quality 

in this tool will enable LMOP to identify landfills that are good candidates for LFG energy

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

prioritize LFG energy project development assistance activities.

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

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

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

 electronic memoranda of understanding (MOU);

 pre-populated Excel spreadsheets; and

 electronic periodic information updates.

The LMOP information collection is expected to involve an average of 1,220 existing 

Partners and an additional 113 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 $251. The total annual 

reporting and recordkeeping burden averaged over three years is 4,215 hours and $334,298.
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This ICR provides a comprehensive description of the information collections under

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

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

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

2. NEED FOR AND USE OF THIS COLLECTION

2(a) Need/Authority for the Collection

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

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

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

encourage the implementation of LFG energy projects. This information collection will assist 

LMOP in decreasing methane emissions from landfills, increasing the use of methane as a 

renewable energy resource, and reducing emissions due to the burning of non-renewable energy

resources such as coal and fuel oil.

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

 Community Partners;

 State Partners;

 Industry Partners (developers and non-developers); 

 Energy Partners; and

 Endorsers.

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

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

Partners agree to provide information on LFG energy projects with which they have been 

involved. Community Partners 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 Partners. 

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

information in spreadsheet attachments submitted by Industry Developer, Energy, and 

Community Partners to monitor the progress of LFG energy projects and identify opportunities 
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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 energy projects to demonstrate to 

existing and potential Partners the cost savings and environmental benefits associated with 

capturing and using LFG. General information about the Partners, operational and under 

construction LFG energy projects, and landfills that may have potential for developing LFG

energy projects is also provided on the LMOP website, making it available to other LMOP 

Partners as well as the public. During EPA fiscal year 2011, 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 Partners, the information to be collected has not previously been collected by

EPA or any other Federal Agency. For existing Partners with LFG energy projects, some of the 

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

information that has already been collected, spreadsheets sent to existing Partners will be prepopulated with information from the LMOP database. Recipients of the spreadsheets will be asked 

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

recipients be requested to provide updated or additional information.

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 currently 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 Notice Required Prior to ICR Submission to OMB

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

ICR through an announcement in the Federal Register on January 27, 2012 (77 FR 4297). The 

Agency did not receive any comments on this ICR renewal. 

3(c) Consultations
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In 2007, LMOP contacted fewer than nine Partners on the preferred format for making 

updates to their LFG energy projects and landfills. LMOP provided a choice of using the online 

data update forms used in ICR 1849.02, or an email with a pre-populated spreadsheet attachment 

for all of their projects/landfills. All Partners were either indifferent between these two options or 

preferred the new spreadsheet information collection method to the old online form.

Table 1: List of Partner 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 by Partner type is what they would expect for this effort or the amount they 

expect is less than the estimate. 

Table 2: List of Partner 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 amount 
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they expect is less than the estimate.

Table 3: List of Partner 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 Partners of LMOP.

To allow EPA to remain current on LFG energy projects, Industry Developer, Energy, and 

Community Partners directly involved in projects will be asked to update the landfill and LFG

energy project data spreadsheets annually. All Partners may also update company and contact 

information periodically. 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 Partners.

3(e) General Guidelines

This information collection request was prepared in compliance with OMB’s and EPA’s 

guidelines for ICR preparation.

3(f) Confidentiality

Participation in LMOP is voluntary. Participants are not required to reveal confidential 

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

any information that they consider confidential.

3(g) Sensitive Questions

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

Partners include local agencies and municipalities that own landfills. State agencies involved in 
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energy, air pollution, and solid waste management are represented through State Partners. Industry

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

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

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

groups: (1) developers are organizations that facilitate, finance, and implement LFG energy

projects; (2) non-developers are manufacturers or suppliers of equipment or expertise needed to 

collect and utilize LFG. Energy Partners include utility companies who purchase energy generated 

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

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

either in manufacturing products or in heating the facility is a potential LFG end user. Finally,

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

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

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

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

Table 4: Respondents to Information Collection

Partner Type NAICS Code NAICS Description

Community Partners 

and State Partners 924 Public Administration, Administration of

Environmental Quality Programs

924110 Public Administration, Administration of Air and

Water Resource and Solid Waste Management

Programs

926130 Public Administration, Regulation and Administration

of Communications, Electric, Gas, and Other Utilities

Industry Partners 333611 Turbine and Turbine Generator Set Units Manufacturing

333618 Other Engine Equipment Manufacturing

541330 Engineering Services

541620 Environmental Consulting Services

562212 Administrative and Support and Waste Management

and Remediation Services, Solid Waste Landfill

541110 Offices of Lawyers

522110 Commercial Banking

523910 Financial Investments and Related Activities,

Miscellaneous Intermediation

Energy Partners

 Direct usersa

611310 Colleges, Universities, and Professional Schools

325412 Pharmaceutical Preparation Manufacturing

327121 Brick and Structural Clay Tile Manufacturing

327310 Cement Manufacturing
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Partner Type NAICS Code NAICS Description

334210 Telephone Apparatus Manufacturing

334220 Radio and Television Broadcasting and Wireless

Communications Equipment Manufacturing

336111 Automobile Manufacturing

325411 Medicinal and Botanical Manufacturing

331511 Iron Foundries

311111 Dog and Cat Food Manufacturing

311421 Fruit and Vegetable Canning

311911 Other Food Manufacturing

Power marketers

and utilities

221121 Electric Bulk Power Transmission and Control

221122 Electric Power Distribution

221119 Other Electric Power Generation

Endorsers 813910 Business Associations

a. There is a wide variety of entities that could become direct 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 Requirements

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

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

 Name of the organization;

 Signature, including electronic signature, of authorized representative with

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

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

number, fax number, and email address;

 Brief description of the organization;

 Organization’s website address; and

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

Pre-populated electronic spreadsheets request Industry Developer, Energy, and Community

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

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

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

be changes to contact information for LMOP coordinators and experts, but they can also include 
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providing or updating a brief description of the organization which LMOP will post on the LMOP 

website to provide publicity and encourage networking among Partners. LMOP may also call a 

selection of Partners to confirm or update project information that LMOP has received through the 

media or industry contacts.

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

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

(ii) Respondent Activities

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

are responding. In completing the MOU, respondents will:

 review the MOU;

 complete the MOU on line or in hardcopy;

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

 file a copy of the MOU.

In completing the pre-populated spreadsheets, respondents will:

 review the spreadsheet and instructions;

 gather information;

 complete or update information in the spreadsheet;

 email or mail the spreadsheet to EPA; and

 file a copy of the spreadsheet.

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

 gather information; and

 provide information via the LMOP website, email, or telephone interview. 

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION 

METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

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

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

 review the information provided;

 sign the MOU;

 return a copy of the signed MOU to the Partner;
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 enter the information into a database; and

 file the MOU.

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

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

send the spreadsheet via email;

 review the information provided and follow up if necessary;

 enter information into a database; and

 file the spreadsheet.

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

 review the data; and

 revise data in the database based on the update.

In initiating an information update, the agency will:

 call or email the Partner;

 request updated information; and

 revise data in the database based on the updates.

5(b) Collection Methodology and Management

The methods selected for this information collection are chosen based on efficiency and 

minimization of burden for respondents and EPA. The MOU can be downloaded from the LMOP

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

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

Partner and revised if necessary. Spreadsheets will be emailed to all Industry Developer, Energy,

and Community Partners. All information 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. LMOP reviewed company

websites and organization descriptions when available for all Energy Partners and a portion of 

Industry Partners to help determine the companies’ small entity status. LMOP determined whether 

Community Partners are small entities based on the population served by these government 

agencies as further described below. LMOP assumed for this estimate of small entities that all 

State Partners, which represent State governments, are not classified as small entities, since each 

State population is greater than 50,000. LMOP also assumed that all of its Endorsers, which are 
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non-profits, were classified as small entities. LMOP conducted a similar review of its Partners’ 

small entity status in 2007 for the previous ICR renewal. The 2007 analysis 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 analysis focused on Partners joining 

after September 2007, and included a larger number of start-up companies and small consulting 

firms that had not previously joined LMOP.

As a result of these estimates and assumptions, LMOP estimated the number of small 

entities affected per year according to the type of respondent, as shown in Table 5. To estimate the 

number of small entities for existing sources, LMOP summed the number of small entities 

identified in 2007 with the number of small entities identified in 2012 for each Partner category. 

For Industry Partners, LMOP’s partnership currently encompasses most of the larger 

players in the 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 analyzed 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 19

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 2010 city or 

county populations1for Partners joining since September 2007 in order to determine the small 

entity status. (During the previous ICR renewal, LMOP compared existing Partners to a table 

 

1

http://quickfacts.census.gov/qfd/index.html
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corresponding to 2006 city or county populations.) Approximately 16 percent of existing 

Community Partners 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 to 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 joined as Partners; the rest of the power providers are utilities or power marketers that 

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

corporations such as Wal-Mart, PepsiCo, Ajinomoto, and Coca-Cola Refreshments, which have a

larger energy demand. Approximately 31 small businesses, such as POET (ethanol plant), State 

Fair Community College, and Lorton Arts Foundation, have a single facility that uses LFG to 

meet its energy needs.

Given the large number of existing Industry Partners, LMOP reviewed websites 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 

websites were not reviewed as part of this 2012 analysis were 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 national presence in the 

LFG industry and are involved in multiple projects, likely meeting the size criteria for large 

businesses, and thus are not considered small businesses. 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 most of these small businesses serve a small niche market, have an obviously

small number of employees, or work within a small service region. LMOP expects future new 

project developer Partners are likely to be smaller companies. 

The non-developer Industry Partner category 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 on 
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a review of websites, 54 percent of non-developers who joined since 2007 were classified as small 

businesses; 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-developer 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 information. Participation in LMOP is 

voluntary. Any small entity that finds the information collection overly 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 Partner upon their agreement to participate in the program. EPA will collect additional 

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

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

periodically at the request of EPA or the Partner.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION 

6(a) Estimating Respondent Burden

In order to obtain accurate hourly burden and cost estimates, EPA consulted with fewer 

than nine Partners regarding burden and cost assumptions in 2007, 2008, and 2012. For this 

renewal ICR, cost estimates were increased to account for an increase in wages and the number of 

Partners. 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 updates for LFG energy projects with 

which they are involved in the ICR going forward. Attachment A presents the estimated average 

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

Partner. Table 6 presents a summary of the respondent burden.

6(b) Estimating Respondent Costs

(i) Estimating Labor Costs
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For private-sector respondents (Industry and Energy Partners), EPA used a national 

average hourly labor rate (hourly rate plus 110% overhead) of $126.66 for legal staff, $119.13 for 

managerial staff, $87.59 for technical staff, and $49.80 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 (NAICS code 541000). Legal rates were based on 

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

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

assistants for May 2010. A June 2011 labor rate for all rates was estimated by applying a 1.9% 

growth factor from the Employment Cost Index to account for increases in wages from June 2010

to June 2011. The Employment Cost Index for wages and salaries, by ownership, occupational 

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

For public-sector respondents (Community and State Partners), EPA used the same labor 

rates used for EPA personnel (see Section 6(c)). These rates are comparable to rates provided by a 

Community Partner in 2000 and using them for all public-sector employees provides consistency. 

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

rate (hourly rate plus 110% overhead) of $97.99 for managerial staff, $79.15 for technical staff,

and $47.16 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 (NAICS code 813900). 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 2010. A June 2011 labor rate for all 

rates was estimated by applying a 1.9% growth factor from the Employment Cost Index to 

account for increases in wages from June 2010 to June 2011. The Employment Cost Index for 

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

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

(ii) Estimating Capital and Operations and Maintenance Costs

Because this information collection requires respondents only to report information that is

already available to them, there are no capital costs. EPA does not expect that the operations and 

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

postage potentially necessary to mail in the MOU and the majority of LMOP Partners 

(approximately 90 percent) submit MOU electronically. A postage cost of $3.00 is attributed to all 

activities involving mailing materials to account for the use of trackable mail. It is assumed that all 
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LFG energy project data updates from Industry Developer, Energy, and Community Partners will be 

submitted electronically, so their only trackable mail costs are associated with submitting their

MOU. The average annual O&M cost over three years is $339.

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 15 63

Industry Non-Developer 267 930 3,590

Energy and Industry-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 $34,761 $112,582

Endorser $464 $1,187 $4,955

Industry Non-Developer $24,934 $81,455 $319,166

Energy and Industry Project Developer $17,027 $170,761 $563,364

State $117 $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

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

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

EPA estimates an average hourly labor cost (labor plus 60% for overhead) of $76.38 for 

managerial staff, $52.37 for technical staff, and $21.02 for clerical staff. To derive these estimates,

EPA used the “Salary Table 2011 - GS” from the Department of Personnel Management, available 

at http://www.opm.gov/oca/11tables/pdf/gs_h.pdf. For purposes of this ICR, EPA assigned staff 

the following government service levels:

 Managerial Staff - GS-15, Step 1

 Technical Staff - GS-12, Step 5

 Clerical Staff - GS-5, Step 1

Table 7: Summary of Agency Burden

2012 2013 2014 Average Total
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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 Partners has grown significantly since the last ICR renewal. Table 

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

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

response rates to previous LMOP ICRs are approximately 25%.

Table 8: Summary of LMOP Partners and Other Respondents

2012 2013 2014 Average

Partner1 Existing New Existing New Existing New Existing New

Community 129 7 136 7 143 7 136 7

Endorser 36 3 39 3 42 3 39 3 

Energy 120 8 128 8 136 8 128 8

Industry

 Non-Developer 662 82 744 82 826 82 744 82

 Project Developer 120 12 132 12 144 12 132 12

State 40 1 41 1 42 1 41 1 

TOTAL 1,107 113 1,220 113 1,333 113 1,220 113

1 Staff with experience in managing the LMOP Partner database provided insight on future program growth by Partner 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-year period covered by this ICR, EPA estimates the total respondent burden of 

the program to be 12,645 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 

over the three-year period, is 4,215 hours and $334,298, of which $420 is O&M, and the annual 

Agency burden, averaged over the three-year period, is 1,832 hours and $94,833.

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

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

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

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

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

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

period.
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6(f) Reasons for Change in Burden

Under this renewal ICR, the total respondent burden over the 3-year period is 12,645

hours, or an average of 4,215 hours per year. The 2008 ICR total respondent burden was 17,656

hours, or an average of 5,885 hours per year.

A significant reason for the decrease in total hourly burden is that under the last ICR 

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 2007 was 719, 

whereas there were 994 Partners as of September 2011.

The total cost estimate over the 3-year period for this renewal ICR is $1,002,893, or an 

average of $334,298 per year, of which $1,260 is O&M costs. In the 2008 ICR renewal, the total 

cost over the 3-year 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 Partners and increases in wages.

6(g) Burden Statement

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

information is estimated to average 3.2 hours and $251 per respondent. The burden per 

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

affected. The average annual burden for new LMOP Partners is 4.6 hours per respondent and the 

average annual burden for existing Partners is 3.0 hours per respondent. Over the 3-year period 

covered by this ICR, EPA estimates the burden of the program to be 12,645 hours and 

$1,002,893 for respondents, and 5,495 hours and $284,498 for EPA. 

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

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

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

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

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

comply with any previously applicable instructions and requirements; train personnel to be able to 
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respond to a collection of information; search data sources; complete and review the collection of 

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

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

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

in 40 CFR part 9 and 48 CFR chapter 15.

The average per 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 Developer, Energy, and 

Community Partner 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 Partners who are developers. The burden estimate includes time to 

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

spreadsheet, and submit the spreadsheet to EPA. The burden for each type of Partner is shown in 

Attachment A and the total burden is summarized in Table 6.

The average per 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 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 EPA-HQ-OAR-2003-0078, 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 Public Reading Room is open from 8 a.m. to 4:30 p.m., Monday through Friday, 

excluding legal holidays. The telephone number for the Reading Room is 202-566-1744, and the 

telephone number for the Air and Radiation Docket is 202-566-1742.

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

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

public docket, and access those documents in the public docket that are available electronically. In 
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the system, select “search,” then key in the Docket ID Number identified above. Alternatively, 

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

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

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

A-1 Existing State Partners

A-2 New State Partners

A-3 Existing Endorsers

A-4 New Endorsers

A-5 Existing Industry Non-Developer Partners

A-6 New Industry Non-Developer Partners

A-7 Existing Community Partners

A-8 New Community Partners 

A-9 Existing Energy and Industry-Project Developer Partners

A-10 New Energy and Industry-Project Developer Partners

ATTACHMENT B - ESTIMATED AGENCY BURDEN AND COST 

B-1 Agency Burden 2012

B-2 Agency Burden 2013

B-3 Agency Burden 2014