**INFORMATION COLLECTION REQUEST SUPPORTING STATEMENT**  **ENVIRONMENTAL PROTECTION AGENCY Federal Supplier (Small Business) Greenhouse Gas Inventory Pilot (Renewal)**  **1. IDENTIFICATION OF THE INFORMATION COLLECTION REQUEST**  **1(a) Title of the**  **Information Collection** Federal Supplier (Small Business) Greenhouse Gas Inventory Pilot (Renewal) , EPA ICR No. 2100.0 5 , OMB Control No. 2060 - 0532 . **1(b) Short Characterization** **/Abstract** On September 30, 2011, the U.S. Environmental Protection Agency officially ended its Climate L eaders program. One element of the Climate Leaders program was the Small Business Network (SBN) which offered small businesses tools and resources to assist them with managing and reducing their GHG emissions. In direct response to E .O. 13514, EPA and the U.S. General Services Administration (GSA) utilized the Climate Leaders SBN as the foundation to launch the Federal Supplier Greenhouse Gas Emissio ns Inventory Pilot (“the Pilot” ) in August 2010 to assess the benefits and challenges experienced b y small businesses in completing and reporting a GHG emissions inventory . The Pilot is a voluntary, three - year program in which small businesses are required to develop annual GHG emissions inventories through September 2013. The small busines ses are also required to develop and implement GHG emissions reductions strategies and review their progress towards meeting their reduction goals and the associated benefits. Through this interagency

agreement, EPA continues to support the Pilot with educ ation and technical assistance. EPA has developed this renewal ICR to ensure that the Pilot remains credible by obtaining continued authorization to collect information from its participants to ensure that they are meeting their GHG goals. Companies that j oined the Pilot voluntarily agree t o the following: s etting a corporate GHG reduction goal; submitting a GHG inventory man agement plan; reporting to the EPA on an annual basis the company's GHG emissions inventory and progress toward their GHG reduction go al via the Annual GHG Inventory Summary

and Goal Tracking Form. The information contained in the inventories of the companies that participate in the Pilot may be considered confidential business information and is maintained as such. EPA uses the data obtained from the companies to assess the success of the Pilot in achieving its goals and to identify the typ e of2

outreach, training, and other direct assistance and incentives that will help small business federal suppliers meet the objectives of E.O. 13514. Responses to the information collection are voluntary . This I CR provides a comprehensive description of the information collections under what formerl y was the Climate Leaders program. 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 THE COLLECTION**  **2(a) Need** **/ Authority**  **for the Collection** In an effort to mitigate global climate change, the President announced a Climate Change Strategy on February

14, 2002, wherein he set a national U.S. GHG intensity goal of 18 percent b y 2012 . Part of that strategy challenges companies t o set GHG emissions reduction goals by working with EPA through the Climate Leaders program . After the end of the Climate Leaders program in September 2011, EPA continues to support the Federal Supplier Greenhouse Gas Emissions Inventory Pilot (“the Pilot” ) . EPA also provides technical assistance to companies participating in the Pilot to help them develop a company- specific Inventory Management Plan, base year GHG inventory, corporate - wide GHG reduction goal and subsequent year corporate GHG inventories us ing the Annual GHG Inventory Summary

and Goal Tracking Form. Participating companies report their GHG inventory to EPA annually , which allows EPA to evaluate the Pilot participant’s progress and performance and to assess overall program results. This GHG inventory data and supporting documentation collected through this Partnership p rovides the necessary level of detail for accurately

measuring each company’s contribution towards reducing GHG emissions. **2 (b)**  **Practical Utility/Users of the Data** EPA uses information submitted in the Inventory Management Plans to assure that the Pilot participant’s GHG inventory is of sufficient quality

for recognition in the Pilot and to provide te chnical assistance and example plans to other participants that are developing their own GHG management strategies . EPA uses information submitted in the Annual GHG Inventory Summary and Goal Tracking Form to accuratel y monitor the progress of Pilot participants in reducing GHG3

emissions, in order to provide them with credib le public recognition when they meet or exceed their goal. **3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION**  **CRITERIA 3(a)**  **Nonduplication** In order to maintain the reputable standing of the voluntary Pilot , and credibly discuss participating comp anies as “leaders” in reducing emissions of GHGs, the data collected under this ICR is very

specific to each Pilot participant’s GHG inventory and is subject to a rigorous review process. The information to be obtained under this I CR has not been collected by EPA or any other Federal agency , nor is it available from any other source. **3(b) Public Notice Required Prior to ICR Submission to OMB**  In compliance with the Paperwork Reduction Act of 1995 (PRA), EPA issued a public notice in the Federal Register o n November 30, 20 1 1 (7 6 FR 74053 ) . No comments were received . **3(c) Consultations**  EPA followed the approved method of consultations with Pilot participants to obtain their views on this method of data collection and burden estimate. Various participants provided their input , which, along with the previously obtained data from Climate Leaders Partners , was used to estimate the burdens of this Information Collection Request. EPA provided the participant s with a list of reporting requirements for the Pilot and asked them to estimate the associated hourl y labor burden. Labor wage rates from the previous Information Collection Request were provided for reference , and EPA requested comments on whether these labor rates were appropriate. The participants prov ided hourly estimates for each activity and either provided labor rates or indicated that the labor rates from the initial I CR were representative. Generall y, the estimates provided b y the participants were consistent with EPA expectations of the labor burden. **3(d) Effects of Less Frequent Collection**  The development of an Inventory Management Plan and GHG emissions reduction goal are one - time information submittals from companies that choose to become Pilot participants . EPA also4

asks Pilot partic ipants to prepare and submit the Annual GHG Inventory Summary

and Goal Tracking Form . EPA believes that any reduction in the frequency of this information collection would impede efforts by

EPA to evaluate results of the program and to provide credible publ ic recognition. Further, since this is a voluntary program, ongoing evaluation of results is critical to the program’s success. **3(e) General Guidelines**  This information collection request was prepared in compliance with OMB’s implementing regulations and EPA’s guidelines for ICR preparation. **3(f) Confidentiality**  Participation in the Pilot is voluntary . Additionally , for this Pilot EPA focuses its information collection at the corporate level and does not retain records of facility specific data. For Pilot participants that are concerned about data confidentiality , EPA will consider proposals to review sensitive data via a web - based data platform to ensure credibility . Another alternative that EPA offers Pilot participants is to have a third party cond uct a credible GHG inventory audit and provide that audit to EPA for review. EPA will not make company- or agency- specific information that is collected under this I CR and that is claimed as conf idential business information ( CBI) available to the general public without a Pilot participant’s permission, except in accordance with EPA’s CBI regulations at 40 CFR, Part 2, subpart B. If a Pilot participant asserts a claim of confidentiality covering all or part of the information collections covered in this IC R, EPA must and will treat the information in accordance with these regulations. EPA will also ensure that the information collections comply with the Privacy

Act of 1974 and OMB Circular 108. **3(g) Sensitive Questions**  No questions of a sensitive nature are asked in the Inventory Management Plan or Annual GHG Inventory

Summary

and Goal Tracking Form.5

**4. THE RESPONDENTS AND THE INFORMATION REQUESTED**  **4(a) Respondents**  **/SIC Codes**  Following are the Standard Industrial Classification ( SI C ) codes associated w ith the majority of companies currentl y participating in the Pilot . No other companies may join the voluntary Pilot in the future.

**Industry Type SIC Code**  Commercial & Machinery Manuf. 3590 Services

– Mgmt Consulting 8742 Misc Electrical Machinery 3690 Building Cleaning/Maintenance Serv. Supplies 7349 Construction 1600 Consulting 8742 Consumer Goods 5000 Consumer Goods Manufacturing 5000 Engineering Professional Serv. 8700 Furniture Manufacturing 2510 Industrial Manufacturing 3560 Information Technology 7373 Retail 2675 Telecommunications 1731 **4(b) Information Requested**  Pilot participants are required to develop and submit an Inventory Management Plan, base ye ar inventory , and work to develop a GHG emissions reduction goal . In order to measure the progress toward meeting the GHG reduction goals, Pilot participants also complete and submit the Annual GHG Inventory

Summary

and Goal Tracking Form. This form document s a Pilot participant’s GHG emissions during the past year. Each information collection activity is described6

below . EPA provides a variety of forms of technical assistance to help Partners complete their Reporting Forms, including assistance filling out the forms and assistance using electronic too ls such as spreadsheets. **( 1**  **) Annual GHG Inventory**  **Summary and Goal Tracking Form** In order to assist the Agency in evaluating whether Partners are on track to meet their GHG reduction targets, EPA asks Pilot participants to update the base ye ar inventory each subsequent ye ar with the Annual GHG Inventory Summary

and Goal Tracking Form . (i) Data items , including record keeping requirements . Partners provide the following information to EPA.

 For all categories of base year data entered, input the annual emission values for the current ye ar inventory  New source categories and corresponding emissions, as necessary  If the inventory

is re - baselined , the new base ye ar estimat e  Number of times the base year data has been adjusted since the first invento ry submittal year with an explanation of each adjustment  Description of any changes in calculation methodologies or any other significant differences from the prev ious year data submittal to EPA  Year of inventory represented and the date the form was compl eted (ii) Respondent activities . In completing s ubsequent years of the Annual GHG Inventory Summary and Goal Tracking Form, Pilot participants p erform the following activities.  Collect and calculate annual GHG emissions data  S ubmit to EPA for review **( 2**  **) Additional Activities**  During participation in the program, Pilot participants may be requested to notify

EPA of any change, such as a change in Company Representative. (i) Data items , including record - keeping requirements . Pilot participants provide the following information to EPA.  Changes in information, such as the name of a new company representative or change in address (ii) Respondent activities . In updating information, Pilot participants perform the following activity7  Provide EPA with new information, such as the name of a new liaison or change in address via e - mail or phone **5. THE INFORMATION COLLECTED**  **– AGENCY**  **ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT**  **5(a) Agency Activities**  This section discusses the forms and associated Agency activities under the Federal Supplier Greenhouse Gas Emissions Inventory Pilot . **( 1**  **) Annual GHG Inventory Summ**  **ary and Goal Tracking Form**  Receive, review, and enter updated information from spreadsheet form into database . **( 2**  **) Additional Activities**   Enter revised contact or profile information updates submitted by Pilot participants through e - mail . **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 . Resources for developing Inventory Management Plans, calculating a base year inventory , setting a GHG emission s reduction goal , and completing the Annual GHG Inv entory Summary

and Goal Tracking Form can be downloaded from EPA’s Corporate GHG Resources website (www.epa.gov/climateleaders) . All o f these reporting requirements are submitted to EPA electronically . For the annual inventory submission by the Pilot parti cipants , EPA has developed an electronic spreadsheet (

Annual GHG Inventory Summary and Goal Tracking Form ) , with detailed instructions and embedded macros and calculations in order to reduce the amount of data a Pilot participant must enter . The Annual GH G Inventory Summary and Goal Tracking Forms are submitted to EPA electronically . All information received through the forms will be reviewed b y EPA for accuracy

and completeness before being entered into the database , **5(c) Small Entity Flexibility**  The Pilot was designed solely for smaller companies , and EPA has created reporting forms to minimize respondent burden while obtaining sufficient and accurate information. The Pilot8

program was designed to be highl y flexible , and the hourly burden estimates fo r reporting requirements under the Pilot will be lessened due to the less complex structure of GHG emissions inventories at small entities . As discussed above, EPA provides technical assistance to participants and facilitates electronic submittal of inform ation. Inconclusion , the burden associated with the Pilot is inherently reduced , since the agreement to participate is voluntary . **5(d) Collection Schedule**  EPA collects information annually via the Annual GHG Inventory Summary

and Goal Tracking Form to m onitor progress towards the GHG emissions reduction goal . Finall y, EPA may collect other program information on a periodic basis or as the information is submitted; these items in clude notification of changes such as company representative or address . **6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION**  **6(a) Estimating Respondent**  **Burden** In order to obtain an accurate cost estimate, EPA consulted with and obtained burden estimates from Pilot participants (respondents) as well as using anecdotal data from the Climate L eaders Partnership . **6(b) Estimating Respondent Costs**  In order to obtain an accurate cost estimate, EPA consulted with P ilot participants (respondents) as well as using anecdotal data from the Climate L eaders Partnership on hourl y wage rates for each ty

pe of labor . EPA presented the se participants with hourly wage rates from the previous IC R and asked them if these rates were still appropriate, and if not, to include an estimate of a revised hourl y rate . **(i )**  **Estimating Labor Costs**  For purposes of this analy sis, EPA estimates an average hourl y respondent labor cost (including fringe and overhead) of $1 09 for legal staff, $ 98 for managerial staff, $ 94 for technical staff and $47 for clerical staff. **( ii**  **) Estimating**  **Capital and Operations and Maintenance**  **Costs**9

Capital costs usually

include any

produced phys ical good needed to provide the needed information, such as machinery , computers, and other equipment . EPA does not anticipate that respondents will incur capital costs in carrying out the information collection requirements covered in this I CR. **(iii )**  **Capital/Start**

**- Up**  **Operat**

**ing and Maintenance (O&M) Costs**  O&M costs are those costs associated with a paperwork requirement incurred continually over the life of the ICR . They are defined by

the Paperwork Reduction Act of 1995 as "the recurring dollar amount of cost associated with O&M or purchasing services." For this ICR, EPA does not anticipate that respondents will incur any costs. **(iv) Annualizing Capital Costs**  There are no capital costs associated with this information collection. **6(c) Estimating Agency**  **Burden and Cost**  EPA 's estimate of the Agency hour and cost burden associated with all of the requirements covered in this ICR is summarized in Exhibit 2 . EPA estimates an average hourly labor cost (labor plus 60% for overhead) of $ 8 6 . 8 6 for legal staff, $ 8 6 . 8 6 for managerial staf f , $ 4 6 . 3 6 for technical staff , and $ 2 1 . 1 0 for clerical staff . To derive these hourly

estimates, EPA used the “20 11 GS Salary Table of Annual Rates by Grade and Step,” from the Department of Personnel Management . For purposes of this I CR, EPA assigned staff the follo wing government service levels. Legal Staff - GS - 15, Step 5 Managerial Staff - GS - 15, Step 5 Technical Staff - GS - 12, Step 1 Clerical Staff - GS - 5, Step 1 EPA then divided annual compensation estimates by 2,080, which is the number of hours in the Federal work - year. EPA then multiplied hourly rates by the standard Federal government overhead factor of 1.6. EPA also estimated an average hourl y labor rate of $147.00 (including overhead) for technical labor from EPA contractor staff . To derive these h ourl y estimates, EPA examined the10

technical work performed by contractors and estimated an hourl y rate for GHG inventory assistance activities based on an average of the fully- loaded labor rates from the contractor invoices on the current contract . **6(d) Estimating the Respondent Universe and Total**  **Burden and Costs (1)**  **Respondent Universe** Table 1 presents the number of companies expected to participate in the program over the three - ye ar period of this ICR . At the beginning of 20 12 , EP A had 46 enrolled Pilot participants . **Table 1 :**  **Number of Respondents Expected to Participate in the Pilot**  **O ver the Three**  **- Year**  **Period of the ICR Type of Respondent**  **Year 1 (20**  **12 )**  **Year 2**

**(20 13**  **) Year 3** 

**(20 14**  **) Average** 

**(over 3 years)** Existing (at beginning of year) 46 46 0 31 New (during year) 0 0 0 0 Existing (at end of year) 46 46 0 31 In the following paragraphs, EPA uses these respondent universe estimates in its respondent hour and cost burden calculations. **(2) Annual Respondent Hour and**  **Cost Burden** Based on the respondent universe data presented in Table 1, EPA estimates respondent burden associated with all of the requirements covered in this I CR in Exhibit 1 . A discussion of the assumptions used in developing these burden estimates are detailed below and in the footnotes of Exhibit 1. ( i ) Annual GHG Inventory and Goal Tracking Form . For each subsequent year of reporting to the base ye ar inventory , Pilot participants must update this form with the ir current ye ar GHG inventory data and make any corrections to the contact information or revised goal or base ye ar information . Based on the projected number Pilot participants , EPA estimates that all 46 Partner s will make updates to their subsequent year inventories each ye ar.11

( ii ) Miscellaneous Activities . As needed, participants should submit updated contact information . These updates would notify EPA of a change such as a new Partner representative or address change . EPA estimates that approx imately 10 percent of participants , or on average 5 Pilot participants , will submit this update each ye ar. **6(e) Bottom Line**  **Burden Hour**  **s and Cost**  **Tables (**  **i )**  **Respondent Tally** Exhibit 1 shows the aggregate annual hour and cost burden to respondents . As shown in the exhibit, EPA estimates the annual respondent burden to be 966 hours and $ 90,804 . **( ii**  **) Agency Tally**  As is shown in Exhibit 2, the annual Agency hour and cost burden associated with all the requirements covered in this I CR is estimated to be 690 hours and $ 92,184 . **(iii) Variations in the Annual Bottom Line**  EPA anticipates minimal variation in the annual respondent reporting/recordkeeping burden over the three - ye ar period covered b y this ICR. **6(f) Reasons for Change in Burden**  The previousl y approved I CR estimated the annual hourly burden for respondents to be 1 9 , 636 . This renewal estimates the annual hourl y burden for respondents to be 966 hours . This is a difference of 18,670 hours . This decrease reflects EPA’s phase down of the Climate Leaders program on September 30, 2011. As a result, the number of respondents included in this I CR decreased to include onl y those 46 small businesses participating in the joint EPA - GSA Federal Supplier Greenhouse Gas Emissions Inventory Pilot. The burden outlined below for the information collection envisioned under this I CR is necessary to help EPA determine that the Pilot participants merit recognition as corporate leaders in GHG reduction and to determine whether the Pilot is achieving its goals. Th e activities undertaken by Pilot participants are anticipated to offset some of this burden as they identify new emission reduction o pportunities that result in savings to the company through, for example, enhanced energy efficiency .12

**6(g) Burden Statement**  Burden Statement : The annual public reporting and recordkeeping burden for this collection of information is estimated to be 3 1 hours per year per response . Burden means the total time, effort, or financial resources expended b y persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency . This includes the time needed to review instructions; develop, acquire, install, and utilize technology and s ys tems for the purposes of collecting, validating, and verifying i nformation, processing and maintaining information, and disclosing and providing information; adjust the existing way s to compl y with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a 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 sugges ted methods for minimizing respondent burden, including the us e of automated collection techniques, EPA has established a docket for this I CR under Docket ID No. EPA - HQ - OAR - 20 11 - 094 0 , which is available for online viewing at www.regulations.gov, or in pers on viewing at the Air and Radiation Docket in the EPA Docket Center (EPA/DC), EPA West Building, Room 3334 , 1301 Constitution Ave., NW, Washington, DC . The EPA/DC Public Reading Room is open from 8 :30 a.m. to 4:30 p.m., Monday through Friday , excluding leg al holiday s . The telephone number for the Reading Room is 202 - 566 - 1744, and the telephone number for the Air and Radiation Docket Center is 202 - 566 - 1742. An electronic version of the public docket is available at www.regulations.gov . This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronicall y . When in the sy stem, select “search,” then key in the Docket ID Number i dentified above . Also, you can 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 - 20 11 - 094 0 and OMB Control Number 2060 - 0532 in any correspondence.