INFORMATION
COLLECTION
REQUEST
FOR
EPA
PERFORMANCE
TRACK
PROGRAM:

June
13,
2003
Prepared
by:

U.
S.
Environmental
Protection
Agency
Office
of
Policy,
Economics,
and
Innovation
1200
Pennsylvania
Avenue
NW
Washington
DC,
20003
2
TABLE
OF
CONTENTS
Table
of
Contents.............................................................................................................................
2
1.
Identification
Of
The
Information
Collection
.......................................................................
4
1(
a)
Title
of
The
Information
Collection............................................................................
4
1(
b)
Short
Characterization/
Abstract...................................................................................
4
2.
Need
For
And
Use
Of
The
Collection.....................................................................................
7
2(
a)
Need/
Authority
for
the
Collection.............................................................................
7
2(
b)
Use/
Users
of
the
Data................................................................................................
7
3.
Nonduplication,
Consultations,
And
Other
Collection
Criteria..........................................
7
3(
a)
Nonduplication.............................................................................................................
7
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB..........................................
8
3(
c)
Consultations................................................................................................................
8
3(
d)
Effects
of
Less
Frequent
Collection............................................................................
8
3(
e)
General
Guidelines.......................................................................................................
8
3(
f)
Confidentiality..............................................................................................................
8
3(
g)
Sensitive
Questions......................................................................................................
9
4.
Respondents
and
the
Information
Requested..............................................................
9
4
(
a
)
R
e
s
p
o
n
d
e
n
t
s
/
N
A
I
C
S
Codes.
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9
4(
b)
Information
Requested.................................................................................................
12
(
i)
Data
Items,
including
recordkeeping
requirements............................................
12
(
ii)
Respondent
Activities.........................................................................................
13
5.
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management.................................................................................................................................
14
5(
a)
Agency
Activities.......................................................................................................
14
5(
b)
Collection
Methodology
and
Management...............................................................
14
5(
c)
Small
Entity
Flexibility..............................................................................................
15
5(
d)
Collection
Schedule....................................................................................................
15
6.
Estimating
the
Burden
and
Cost
of
the
Collection..........................................................
15
6(
a)
Estimating
Respondent
Burden..................................................................................
15
6(
b)
Estimating
Respondent
Costs.....................................................................................
17
(
i)
Estimating
Labor
Costs....................................................................................
17
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs............................
20
6
(
c
)
E
s
t
i
m
a
t
i
n
g
t
h
e
R
e
s
p
o
n
d
e
n
t
3
Unive
r
se
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20
6(
d)
Estimating
State
Burden
and
Cost...............................................................................
20
6(
e)
Estimating
Agency
Burden
and
Cost........................................................................
24
6(
f)
Bottom
Line
Burden
Hours
and
Cost
Tables............................................................
27
(
i)
Respondent
Tally...........................................................................................
27
(
ii)
State
Tally.......................................................................................................
27
(
i
i
i
)
A
g
e
n
c
y
Tally.........................................................................................................
27
(
iv)
Variations
in
the
Annual
Bottom
Line............................................................
27
6(
g)
Reasons
for
Change
in
Burden..................................................................................
27
6(
h)
Burden
Statement.......................................................................................................
27
Index
of
Tables
Appendices
Appendix
A:
Application
to
National
Environmental
Performance
Track
Appendix
B:
Annual
Performance
Report
4
SECTION
I:
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
INFORMATION
COLLECTION
1(
a)
Title
of
Information
Collection
National
Environmental
Performance
Track
Program
1(
b)
Short
Characterization
EPA
announced
the
National
Environmental
Performance
Track
Program
on
June
26,
2000.
The
program
is
voluntary
and
is
designed
to
recognize
and
encourage
facilities
that
consistently
meet
their
legal
requirements,
that
have
implemented
management
systems
to
monitor
and
improve
performance,
that
have
achieved
environmental
improvements
beyond
compliance,
and
that
publicly
commit
to
specific
environmental
improvements
and
report
on
progress.
A
total
of
304
facilities
are
current
members.
Information
is
collected
by
EPA
in
two
areas:
applications
and
annual
performance
reports.
Performance
Track
member
facilities
are
the
respondents
for
this
program,
and
EPA
and
States
are
the
recipients
and
reviewers
of
this
information.

Applications
submitted
by
facilities
are
used
by
EPA
and
participating
regulatory
entities
to
determine
whether
the
applicant
qualifies
for
the
program
(
See
Appendix
A
for
the
application
form).
Environmental
Performance
Track
members
are
also
required
to
submit
an
Annual
Performance
Report
(
APR)
documenting
their
environmental
performance
relative
to
the
commitments
they
made
upon
entry
into
the
program
(
See
Appendix
B
for
the
APR
form).
This
information
is
important
to
determine
whether
participants
are
meeting
their
commitments,
as
well
as
to
evaluate
the
effectiveness
of
the
program.
The
public
reporting
elements
of
the
program
also
provide
information
to
the
local
community.

EPA
seeks
to
grow
Performance
Track
membership
by
approximately
25
percent
annually.
The
25%
growth
goal
is
an
underlying
assumption
to
this
ICR
and
represents
an
upper
bound
estimate.
Based
on
the
EPA's
experience
to
date,
approximately
75
percent
of
applicants
to
the
Performance
Track
program
are
eligible
for
membership;
historical
data
also
define
an
average
attrition
rate
of
17
facilities
annually;
the
annualized
reduction
of
17
facilities
per
year
equates
to
12%;
this
is
another
underlying
assumption
for
this
ICR.
The
Agency
estimates
that
the
burden
required
by
this
action
for
facilities
will
amount
to
267.75
hours
annually
(
40
hours
each
to
apply
or
re­
apply;
187.75
hours
to
undertake
required
program
activities).
Applications
and
reapplications
are
divided
into
two
segments
because
for
any
year
there
are
different
numbers
of
applicants
and
re­
applicants,
resulting
in
different
burden
hours
and
costs
for
each
segment.
Finally,
EPA
estimates
513
respondents
annually
over
the
life
of
this
ICR,
this
is
based
on
the
average
of
each
of
the
annual
estimates
for
the
next
three
years
of
404,
505
and
631
in
2004,
2005
and
2006,
respectively.
5
The
following
summarizes
the
data
presented
in
the
Office
of
Management
and
Budget
(
OMB)
83­
I
form,
`
Paperwork
Reduction
Act
Submission,'
and
in
the
`
Second
Federal
Register
Notice:'

°
Number
of
respondents
513
°
Total
number
of
responses
513
°
Total
hours
requested
in
this
response
109,445
°
Current
OMB
inventory
(
hours)
50,450
°
Difference
58,995
°
Average
hours
per
response
267.75
°
Estimated
total
annual
cost
(
Respondents)
$
6,547,296
°
Estimated
total
annual
cost
(
States)
$
188,416
°
Estimated
total
annual
cost
(
Agency)
$
610,788
6
For
this
ICR,
EPA
considers
respondents
as
member
facilities
in
the
Performance
Track
Program.
Table
1.1
summarizes
the
respondent
burden
for
the
Performance
Track
Program.

Table
1.1:
Summary
of
Annualized
Respondent
Burden,
July
1,
2003
­
June
30,
2006
Facility
Burden
Hours1
Facility
Burden
Cost2
Total
Burden
Hours3
4
Total
Burden
Cost5
Applications
New
Applications
40
$
2,129
26280
$
1,398,595
Member
Re­
applications
40
$
2,129
12920
$
687,589
Application
Subtotal
39200
$
2,086,185
Annualized
Application
Subtotal
13067
$
695,395
Program
Participation
Compliance
Demonstration
77.75
$
4,924
119735
$
7,582,918
EMS
Documentation
and
Reporting
40.5
$
2,403
62370
$
3,701,313
Continuous
Performance
Demonstration
37.5
$
2,272
57750
$
3,499,227
Reporting
and
Public
Outreach
32
$
1,800
49280
$
2,772,246
Participation
Subtotal
187.75
$
11,400
289135
$
17,555,704
Annualized
Participation
Subtotal
96378
$
5,851,901
Summary
Total
Respondent
Burden,
2003­
2006
328335
$
19,641,888
Annualized
Total
Respondent
Burden
267.75
$
15,657
109445
$
6,547,296
1
This
renewal
ICR
retains
the
estimated
facility
burden
hours
from
the
original
ICR
for
the
establishment
of
the
Performance
Track
Program
(
No.
1949.01).
Facilities
that
have
well
documented
and
established
environmental
management
systems
in
place
and
currently
share
some
environmental
performance
information
with
the
public
will
likely
experience
burden
lesser
than
that
assumed
here.
Other
facilities
may
require
more
burden
to
demonstrate
how
they
meet
the
entry
or
continuing
performance
criteria.
2
EPA
estimates
hourly
non­
EPA
labor
rates
from
several
sources.
For
State
Government
and
Respondent
wages,
EPA
uses
the
Bureau
of
Labor
Statistics'
Employer
Costs
for
Employee
Compensation
(
ECEC)
data
from
December
2002
(<
http://
www.
bls.
gov/
news.
release/
ecec.
t04.
htm>
and
<
http://
www.
bls.
gov/
news.
release/
ecec.
t12.
htm>,
respectively).
Legal
Services
wage
rates
for
Respondents,
not
available
from
the
ECEC
data,
are
derived
from
the
Bureau
of
Labor
Statistics'
National
Occupational
Employment
and
Wage
Data
used
for
2001
(
the
most
recent
available
year
<
http://
www.
bls.
gov/
oes/
2001/
oes_
23Le.
htm>).
EPA
uses
the
U.
S.
Office
of
Personnel
Management's
2003
General
Pay
Schedule
(<
http://
www.
opm.
gov/
oca/
03tables/
pdf/
DCB.
pdf>)
for
EPA
labor
rates.
Consistent
with
the
Office
of
Management
and
Budget's
1999
guidance
Estimating
Paperwork
Burden
(<
http://
www.
whitehouse.
gov/
omb/
fedreg/
5cfr1320.
html>),
EPA
uses
an
adjusted
labor
rate
reflective
of
benefits
and
overhead
costs.
3
EPA
estimates
burden
hours
by
projecting
program
membership
levels
against
a
May
2003
baseline.
The
May
2003
baseline
is
calculated
by
adding
an
estimated
19
new
members
anticipated
from
Round
6
applications
(
currently
under
review)
to
the
304
current
Performance
Track
members
to
arrive
at
a
total
of
323
Performance
Track
member
facilities.
Membership
for
ensuing
years
is
projected
using
Performance
Track's
target
annual
growth
rate
of
25%,
less
the
program's
historical
attrition
rate
of
12%
annually.
EPA
projects
the
number
of
new
applications
by
first
determining
the
number
of
successful
applicants
necessary
to
meet
program
growth
targets,
then
using
the
program's
historical
acceptance
rate
to
project
the
number
of
applications
necessary
to
fill
the
target
number
of
new
spots.
Although
there
may
be
some
attrition
associated
with
re­
application,
EPA
assumes
for
purposes
of
estimating
burden
that
all
member
facilities
eligible
to
re­
apply
for
Performance
Track
membership
will
do
so
within
the
required
timeframes.
4,5
Calculated
by
multiplying
the
Facility
Burden
Hours
(
or
Cost)
by
the
Number
of
Facilities.
Facility
numbers
vary
across
the
years
covered
by
this
ICR,
from
323
facilities
in
June
2003
to
631
facilities
in
June
2006.
7
NEED
FOR
AND
USE
OF
THE
COLLECTION
2.
(
a)
Need/
Authority
for
the
Collection
Since
1995
the
EPA
has
launched
a
number
of
reinvention
initiatives
which
emphasize
streamlining
the
regulatory
process
and
making
regulatory
programs
more
efficient.
The
Performance
Track
Program
is
the
outcome
of
the
July
1999
report,
Aiming
for
Excellence:
Actions
to
Encourage
Stewardship
and
Accelerate
Environmental
Progress.
In
this
report,
EPA
committed
to
developing
and
launching
a
National
Performance
Track
Program
that
uses
incentives
and
promotes
environmental
management
systems
to
reward
and
encourage
environmental
leaders.

EPA
views
this
program
as
a
way
to
build
upon
and
integrate
a
range
of
innovative
programs
that
have
been
underway
for
some
time,
at
both
the
federal
and
state
level.
The
Performance
Track
Program
will
increase
the
use
of
environmental
management
systems,
public
participation,
and
performance
reporting,
which
will
help
improve
the
environment,
while
shifting
EPA's
resources
from
the
oversight
of
good
performers.

2(
b)
Use/
Users
of
the
Data
The
applications
collected
for
the
National
Environmental
Performance
Track
program
will
be
used
by
EPA
and
participating
regulatory
entities
to
determine
whether
the
applicant
qualifies
for
the
program.
The
APR
is
used
by
EPA
to
assess
the
participant's
progress
and
environmental
performance
while
in
the
program,
and
to
determine
whether
they
should
remain
in
the
program.
Both
components
protect
the
credibility
of
the
program
by
avoiding
erroneous
recognition
of
facilities
with
poor
environmental
performance.
The
public
reporting
element
of
the
program
will
also
provide
information
to
the
local
community.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
EPA
currently
does
not
have
sources
for
the
other
information
requested
by
the
Performance
Track
Program.
The
information
requested
either
as
part
of
the
Performance
Track
application
or
in
the
required
reports
is
not
available
through
any
other
source
within
the
Agency.
Nor
is
it
available
outside
the
agency.

EPA
is
designing
the
Performance
Track
Program
to
allow
facilities
to
select
a
limited
number
of
performance
measures
upon
which
to
report
past
performance
and
commit
to
future
performance.
EPA
will
encourage
facilities
to
use
the
results
and
goals
they
have
under
existing
local,
state
or
federal
programs
in
order
to
reduce
the
possibility
for
duplication
of
efforts.
For
example,
a
facility
participating
in
an
equivalent
state
leadership
program
could
use
the
8
achievements
documented
in
that
program
to
meet
the
requirements
for
entry
to
the
Performance
Track
program.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
1995
Paperwork
Reduction
Act,
EPA
has
begun
soliciting
public
comments
for
a
60
day
period
prior
to
submission
of
the
ICR
to
OMB.
EPA
issued
a
Federal
Register
Notice
announcing
the
request
to
renew
the
existing
Performance
Track
Program
Level
One:
The
Environmental
Achievement
Track
ICR
1949.02,
OMB
2010­
0032,
scheduled
to
expire
on
June
30,
2003,
on
January
27,
2003
(
68
FR
3879).
EPA
received
two
comments
during
the
comment
period.
The
comments
received
by
EPA
had
no
relevance
to
ICR
1949.

3(
c)
Consultations
This
information
collection
was
developed
by
an
EPA
Performance
Track
workgroup.
Since
the
inception
of
the
Performance
Track
Program,
EPA
has
held
public
stakeholder
meetings,
hosted
periodic
meetings
with
Performance
Track
members
and
state
and
EPA
regional
representatives,
and
sought
the
monthly
input
of
state
and
EPA
regional
representatives
through
teleconference
calls.
The
purpose
of
these
meetings
and
teleconferences
was
to
solicit
comments
and
questions
about
the
implementation
of
the
program,
including
elements
of
information
collection.
Most
recently,
EPA
hosted
the
annual
Performance
Track
Members
Event
on
April
9,
2003
in
Washington,
D.
C.
to
welcome
new
members
to
the
program
and
celebrate
continued
participation
of
existing
members.
Earlier
this
year,
the
4th
Annual
State
and
Regional
Conference
was
held
from
January
27
through
January
30,
2003
in
Denver,
Colorado.

3(
d)
Effects
of
Less
Frequent
Collection
Performance
Track
participants
are
required
to
submit
an
APR
documenting
their
environmental
performance
relative
to
the
commitments
they
made
upon
entry
into
the
program.
This
information
is
important
to
determine
whether
participants
are
meeting
their
commitments,
as
well
as
to
evaluate
the
effectiveness
of
the
program.
Less
frequent
reporting
could
jeopardize
the
credibility
and
success
of
the
program.

3(
e)
General
Guidelines
This
information
collection
adheres
to
the
general
guidelines
set
forth
by
the
Office
of
Management
and
Budget.

3(
f)
Confidentiality
Materials
involving
invasion
of
privacy
or
containing
a
trade
secret
should
not
be
included
in
the
application.
EPA
shall
treat
information
claimed
as
confidential
business
information
(
CBI)
in
accordance
with
the
requirements
of
40
CFR
part
2.
If
the
participant
fails
to
claim
the
9
information
as
confidential
upon
submission,
it
may
be
made
available
to
the
public
without
further
notice.
EPA
cannot
guarantee
that
information
submitted
for
application
or
reporting
to
the
National
Environmental
Performance
Track
Program
and
claimed
as
confidential
will
be
protected
from
release
under
the
Freedom
of
Information
Act
(
FOIA).
State
participants
will
maintain
CBI
confidentiality
to
the
extent
allowed
by
relevant
state
law.
Note
that
some
state
laws
provide
for
a
greater
degree
of
access
to
and
narrower
protections
for
information
considered
confidential
under
federal
law.

3(
g)
Sensitive
Questions
Sensitive
questions
are
defined
in
the
ICR
instructions
as
"
questions
concerning
sexual
behavior
or
attitudes,
religious
beliefs,
or
other
matters
usually
considered
private."
The
reporting
requirements
addressed
in
this
information
collection
request
do
not
include
sensitive
questions.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
North
American
Industry
Classification
System
(
NAICS)
Codes
Potential
applicants
include
all
entities
regulated
by
EPA,
pursuant
to
its
authority
under
the
various
environmental
statutes,
who
voluntarily
elect
to
participate
in
the
Performance
Track
Program.
Thus,
potential
respondents
may
fall
under
any
NAICS
code.
The
following
table
lists
the
Primary
NAICS
Codes
for
all
current
Performance
Track
members.

Table
4.1:
Primary
North
American
Industry
Classification
System
(
NAICS)
Codes
of
Current
Performance
Track
Members
339113
Surgical
Appliance
and
Supplies
Manufacturing
40
339111
Laboratory
Apparatus
and
Furniture
Manufacturing
33
325412
Pharmaceutical
Preparation
Manufacturing
28
325998
All
Other
Miscellaneous
Chemical
Product
and
Preparation
18
221112
Fossil
Fuel
Electric
Power
Generation
12
812320
Dry
Cleaning
and
Laundry
Services
(
except
Coin­
Operated)
12
454311
Heating
Oil
Dealers
10
322121
Paper
(
except
Newsprint)
Mills
8
334220
Radio
and
Television
Broadcasting
and
Wireless
8
339113
Surgical
and
Appliance
and
Supplies
Manufacturing
8
541710
Research
and
Development
in
the
Physical,
Engineering,
and
8
325211
Plastics
Material
and
Resin
Manufacturing
7
321114
Wood
Preservation
6
325199
All
Other
Basic
Organic
Chemical
Manufacturing
6
332991
Ball
and
Roller
Bearing
Manufacturing
6
326211
Tire
Manufacturing
(
except
Retreading)
5
334413
Semiconductor
and
Related
Device
Manufacturing
5
336399
All
Other
Motor
Vehicle
Parts
Manufacturing
5
Table
4.1:
Primary
North
American
Industry
Classification
System
(
NAICS)
Codes
of
Current
Performance
Track
Members
10
311421
Fruit
and
Vegetable
Canning
4
322130
Paperboard
Mills
4
323113
Commercial
Screen
Printing
4
326113
Unlaminated
Plastics
Film
and
Sheet
(
except
Packaging)
4
334111
Electronic
Computer
Manufacturing
4
336322
Other
Motor
Vehicle
Electrical
and
Electronic
Equipment
4
339112
Surgical
and
Medical
Instrument
Manufacturing
4
339115
Ophthalmic
Goods
Manufacturing
4
339999
All
Other
Miscellaneous
Manufacturing
4
221111
Hydroelectric
Power
Generation
3
221121
Electric
Bulk
Power
Transmission
and
Control
3
221122
Electric
Power
Distribution
3
325411
Medicinal
and
Botanical
Manufacturing
3
327999
All
Other
Miscellaneous
Nonmetallic
Mineral
Product
3
334418
Printed
Circuit
Assembly
(
Electronic
Assembly)
3
336211
Motor
Vehicle
Body
Manufacturing
3
311514
Dry,
Condensed,
and
Evaporated
Dairy
Product
2
314110
Carpet
and
Rug
Mills
2
321912
Cut
Stock,
Re­
sawing
Lumber,
and
Planing
2
325188
All
Other
Basic
Inorganic
Chemical
Manufacturing
2
325611
Soap
and
Other
Detergent
Manufacturing
2
325991
Custom
Compounding
of
Purchased
Resins
2
326199
All
Other
Plastics
Product
Manufacturing
2
327331
Concrete
Block
and
Brick
Manufacturing
2
331111
Iron
and
Steel
Mills
2
331521
Aluminum
Die­
Casting
Foundries
2
332812
Metal
Coating,
Engraving
(
except
Jewelry
and
Silverware),
2
333111
Farm
Machinery
and
Equipment
Manufacturing
2
333313
Office
Machinery
Manufacturing
2
333911
Pump
and
Pumping
Equipment
Manufacturing
2
334411
Electron
Tube
Manufacturing
2
334511
Search,
Detection,
Navigation,
Guidance,
Aeronautical,
and
2
334515
Instrument
Manufacturing
for
Measuring
and
Testing
2
334612
Prerecorded
Compact
Disc
(
except
Software),
Tape,
and
2
334613
Magnetic
and
Optical
Recording
Media
Manufacturing
2
335312
Motor
and
Generator
Manufacturing
2
336350
Motor
Vehicle
Transmission
and
Power
Train
Parts
2
336411
Aircraft
Manufacturing
2
336414
Guided
Missile
and
Space
Vehicle
Manufacturing
2
339920
Sporting
and
Athletic
Goods
Manufacturing
2
562213
Solid
Waste
Combustors
and
Incinerators
2
928110
National
Security
2
Table
4.1:
Primary
North
American
Industry
Classification
System
(
NAICS)
Codes
of
Current
Performance
Track
Members
11
212391
Potash,
Soda,
and
Borate
Mineral
Mining
1
311213
Malt
Manufacturing
1
312221
Cigarette
Manufacturing
1
314912
Canvas
and
Related
Product
Mills
1
321219
Reconstituted
Wood
Product
Manufacturing
1
321911
Wood
Window
and
Door
Manufacturing
1
322110
Pulp
Mills
1
322215
Nonfolding
Sanitary
Food
Container
Manufacturing
1
325132
Synthetic
Organic
Dye
and
Pigment
Manufacturing
1
325212
Synthetic
Rubber
Manufacturing
1
325222
Noncellulosic
Organic
Fiber
Manufacturing
1
325413
In­
Vitro
Diagnostic
Substance
Manufacturing
1
325520
Adhesive
Manufacturing
1
325612
Polish
and
Other
Sanitation
Good
Manufacturing
1
325613
Surface
Active
Agent
Manufacturing
1
325910
Printing
Ink
Manufacturing
1
326291
Rubber
Product
Manufacturing
for
Mechanical
Use
1
326299
All
Other
Rubber
Product
Manufacturing
1
332313
Plate
Work
Manufacturing
1
332431
Metal
Can
Manufacturing
1
332995
Other
Ordnance
and
Accessories
Manufacturing
1
333293
Printing
Machinery
and
Equipment
Manufacturing
1
333294
Food
Product
Machinery
Manufacturing
1
333314
Optical
Instrument
and
Lens
Manufacturing
1
333315
Photographic
and
Photocopying
Equipment
Manufacturing
1
333611
Turbine
and
Turbine
Generator
Set
Units
Manufacturing
1
334412
Bare
Printed
Circuit
Board
Manufacturing
1
334414
Electronic
Capacitor
Manufacturing
1
334512
Automatic
Environmental
Control
Manufacturing
for
1
334513
Instruments
and
Related
Products
Manufacturing
for
1
335929
Other
Communication
and
Energy
Wire
Manufacturing
1
335931
Current­
Carrying
Wiring
Device
Manufacturing
1
336111
Automobile
Manufacturing
1
336212
Truck
Trailer
Manufacturing
1
336312
Gasoline
Engine
and
Engine
Parts
Manufacturing
1
336391
Motor
Vehicle
Air
Conditioning
Manufacturing
1
339114
Dental
Equipment
and
Supplies
Manufacturing
1
339992
Musical
Instrument
Manufacturing
1
562219
Other
Nonhazardous
Waste
Treatment
and
Disposal
1
812332
Industrial
Launderers
1
926120
Regulation
and
Administration
of
Transportation
Programs
1
927110
Space
Research
and
Technology
1
12
4(
b)
Information
Requested
(
i)
Data
Items
Facilities
who
are
interested
in
the
Performance
Track
Program
receive
an
application
packet,
including
a
guidance
document
to
assist
them
in
preparing
the
application.
A
copy
of
the
application
packet
is
attached
as
Appendix
A.
EPA
is
attempting
to
utilize
a
self­
certification
approach
to
the
extent
possible.
The
application
consists
of
four
sections:

Section
A
asks
for
general
information,
such
as
the
name,
address,
and
size
of
the
facility,
name
and
phone
number
of
a
contact
person,
the
number
of
employees,
the
nature
of
the
business,
and
the
facility's
NAICS
code.

Section
B
requires
the
applicant
to
verify
that
the
facility's
environmental
management
system
(
EMS)
includes
the
required
attributes,
including
an
EMS
policy,
planning,
implementation
and
operation,
checking
and
corrective
action,
and
management
review.

Section
C
requires
the
applicant
to
choose
a
minimum
of
one
(
small
business)
or
two
(
large
business)
categories
and
document
improvements
that
have
been
made
with
respect
to
performance
during
the
current
year
and
the
previous
year.
Using
the
same
or
a
different
set
of
categories,
the
applicant
must
select
a
minimum
of
two
(
small
business)
or
four
(
large
business)
categories
for
which
the
facility
will
commit
to
report
on
its
performance
during
the
three
years
following
acceptance
into
the
program.
The
categories
include:

°
Energy
Use
°
Water
Use
°
Emissions
of
Air
Pollutants
°
Waste
Generated
°
Discharges
to
Water
°
Product
Performance
°
Restoration/
Preservation
°
Materials
Used
°
Noise/
Odor
In
reporting
on
these
categories,
several
guidelines
apply.
First,
facilities
must
indicate
a
specific
baseline
year
against
which
to
measure
all
future
environmental
improvements.
Reporting
of
improvements
must
include
raw
data
that
incorporates
appropriate
standard
units
of
measure.
Facilities
are
encouraged
to
normalize
the
raw
data
by
production
level
or
number
of
employees,
and
a
normalization
rationale
must
be
included.
Finally,
facilities
are
asked
to
report
on
how
they
plan
to
achieve
the
proposed
improvements
in
environmental
performance.

Section
D
requires
that
the
applicant
answer
three
questions
regarding
how
the
facility
responds
to
community
concerns
regarding
the
environmental
impacts
of
their
operations
13
and
how
often
the
facility
provides
information
to
the
local
community
about
their
environmental
performance.
In
addition,
this
section
requires
a
list
of
three
local
or
state
regulatory
officials,
and
community/
local
references
that
may
be
contacted
by
EPA
in
reviewing
the
application.

The
results
of
the
applicant's
response
to
section
C
of
the
application,
as
well
as
the
facility's
APR,
are
submitted
to
EPA
and
made
generally
available
to
the
public.
For
small
businesses,
EPA
may
make
its
information
available
on
the
EPA
website
to
fulfill
the
generally
available
criteria.
The
APR
requires
members
to
report
on
the
following:

°
A
summary
of
the
results
of
compliance
and
EMS
audits
conducted
during
the
year
°
Actual
and
normalized
progress
on
the
performance
measures
selected
for
continuous
improvement,
as
well
as
the
methods
by
which
improvements
are
made
°
Summary
of
public
outreach
activities
and
results
(
e.
g.,
agendas,
meeting
summaries,
etc.)
°
Public
distribution
mechanism
for
the
APR
(
ii)
Respondent
Activities
The
following
are
activities
a
respondent
must
perform
during
the
application
phase:

1.
Read
the
application
and
guidance
document
2.
Gather
information
to
complete
the
four
sections
of
the
application
3.
Complete
the
four
sections
of
the
application
4.
Submit
the
application
to
the
EPA
5.
Wait
for
notification
from
EPA
of
acceptance
or
rejection
The
following
are
activities
a
respondent
must
perform
while
participating
in
the
National
Environmental
Performance
Track
Program:

1.
Submit
annual
report
addressing
the
topics
listed
above
under
"
data
items."
2.
Make
the
annual
report
available
to
the
local
community
3.
Certify
that
the
facility
will
continue
to
meet
the
Performance
Track
participation
criteria
EPA
and
States
participating
in
the
program
will
be
conducting
the
following
activities:

1.
Environmental
Compliance
Screen
2.
Possible
site
visit
3.
Evaluation
of
applicant
4.
Evaluation
of
APR
The
activities
required
by
the
components
of
this
information
collection
request
are
not
customary
and
usual
business
practice,
except
for
the
submission
of
EMS
information.
For
facilities
that
have
a
well
documented
EMS
in
place,
compiling
and
maintaining
EMS
data
is
a
customary
business
practice.
14
5.
THE
INFORMATION
COLLECTED­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a).
Agency
Activities
Performance
Track
participants
are
selected
by
a
review
team
consisting
of
EPA
representatives.
EPA
coordinates
with
the
relevant
state
environmental
agency
during
review
of
the
applicants.
Selection
decisions
are
based
on
whether
the
applicant
facility
meets
all
of
the
requirements
outlined
in
the
application,
including
a
compliance
screen.
The
compliance
screen
is
based
on
the
Agency's
Screening
Guidance
for
Partnership
Programs.
If
the
applicant
does
not
meet
the
criteria,
the
facility
is
not
accepted
into
Performance
Track,
and
is
notified
in
writing.

EPA
generally
responds
to
applicants
within
90
days
after
the
close
of
the
"
open
season"
period.
Facilities
are
notified
in
writing
whether
they
qualify
or
do
not
qualify.
Facilities
that
are
not
accepted
for
the
program
may
reapply
at
future
open
seasons.

The
following
is
a
list
of
itemized
Agency
activities
in
Performance
Track:

1.
Receive
applications
from
interested
facilities
2.
Perform
comprehensive
compliance
screen
3.
Evaluate
applications
4.
Notify
applicant
of
selection
or
rejection
5.
Perform
annual
compliance
screen
for
participating
companies
6.
Review
compliance
audit
work
plan
and
report
7.
Review
EMS
audit
work
plan
and
implementation
plan
8.
Evaluate
participant
facility
continuous
improvement
achievements
annually
according
to
annual
reports.

5(
b)
Collection
Methodology
and
Management
EPA
designed
and
launched
the
Performance
Track
website,
which
provides
a
program
description
and
comprehensive
information,
including
application
materials,
documents
to
assist
facilities
with
the
application,
and
names
and
addresses
of
key
Agency
contacts.
Applicants
must
submit
four
copies
of
the
application
to
EPA.
The
application
is
evaluated
for
completeness.
EPA
also
conducts
a
compliance
screen
of
the
applicant
using
the
Agency's
Screening
Guidance
for
Partnership
Programs.
EPA
also
conducts
limited
site
visits
to
evaluate
the
program
and
identify
opportunities
to
improve
program
operation
and
guidance.

Required
documents
and
reports
submitted
during
the
period
of
participation
are
sent
to
an
EPA
Performance
Track
contact.
APRs
are
posted
on
the
Performance
Track
website.
The
Performance
Track
Program
utilizes
electronic
submissions
for
APRs,
and
is
working
to
develop
capabilities
to
process
electronic
applications.
15
5(
c)
Small
Entity
Flexibility
EPA
realizes
that
applicants
to
the
Performance
Track
Program
vary
in
size.
The
burden
to
small
facilities
has
been
recognized
during
the
development
of
the
program,
its
application
and
reporting
requirements,
and
this
information
collection.
The
need
to
keep
the
program
requirements
flexible
enough
to
stimulate
interest
in
participation
by
small
facilities
was
considered
during
the
planning
of
the
program.
Thus,
small
business
must
select
commitments
in
two
(
as
opposed
to
four)
criteria,
and
demonstrate
one
(
rather
than
two)
past
environmental
achievements.

5(
d)
Collection
Schedule
The
following
Table
summarizes
the
program's
collection
schedule.

Table
5.1:
Collection
Schedule
Activity
Schedule
EPA
solicits
applications
Open
Season
(
3
months,
twice
annually)
EPA
reviews
applications,
performs
compliance
screen
During
open
season
and
up
to
90
days
from
close
of
open
season
EPA
selects
Performance
Track
members;
notifies
applicants
of
selection
status
Up
to
90
days
from
close
of
open
season
Members
prepare
and
submit
annual
performance
report
Annually
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
This
section
presents
EPA's
estimates
of
the
respondent's
burden
hours
and
cost
to
complete
the
activities
associated
with
this
information
collection.
EPA
considers
respondents
to
be
only
member
facilities
of
the
Perforamnce
Track
Program.
EPA
and
States
are
not
respondents
for
this
ICR,
they
are
the
recipients
and
reviewers
of
the
data
collected.
In
using
this
analysis,
it
should
be
noted
again
that
all
responses
to
this
information
collection
are
voluntary
and
the
submissions
of
annual
reports
are
required
for
only
those
facilities
that
are
accepted
into
the
program.
There
are
expected
benefits
to
those
who
choose
to
participate
in
the
program.
EPA
does
not
expect
a
response
from
any
facility
where
the
burdens
associated
with
preparing
the
response
outweigh
the
expected
benefits
to
the
facility.

EPA
estimates
burden
hours
by
projecting
program
membership
levels
against
a
May
2003
baseline.
The
May
2003
baseline
is
calculated
by
adding
an
estimated
19
new
members
anticipated
from
Round
6
applications
(
currently
under
review)
to
the
304
current
Performance
Track
members
to
arrive
at
a
total
of
323
Performance
Track
member
facilities.
Membership
for
ensuing
years
is
projected
using
Performance
Track's
target
annual
growth
rate
of
25%,
less
the
program's
historical
attrition
rate
of
17
facilities
annually.
Over
the
history
of
the
program,
losing
17
facilities
translates
to
a
12%
attrition
rate
annually.
EPA
projects
the
number
of
new
1
Based
on
the
2003
General
Schedule
Pay
Chart,
and
adding
benefits
and
overhead
costs
pursuant
to
the
Office
of
Management
and
Budget's
Estimating
Paperwork
Burden
guidance,
EPA
estimates
an
average
adjusted
hourly
labor
cost
of
$
44.67
for
technical
staff
responsible
for
EPA
activities
in
the
National
Environmental
Performance
Track.

16
applications
by
first
determining
the
number
of
successful
applicants
necessary
to
meet
program
growth
targets,
then
using
the
program's
historical
acceptance
rate
to
project
the
number
of
applications
necessary
to
fill
the
target
number
of
new
spots.
Although
there
may
be
some
attrition
associated
with
re­
application,
EPA
assumes
for
purposes
of
estimating
burden
that
all
member
facilities
eligible
to
re­
apply
for
Performance
Track
membership
will
do
so
within
the
required
timeframes.
The
following
Table
summarizes
the
program's
projected
membership
and
application
levels.

Table
6.1:
Projected
Membership
and
Application
Levels
Current
Membership
(
May
2003)
Projected
Membership
(
June
2003)
July
1,
2003
­
June
30,
2004
July
1,
2004
­
June
30,
2005
July
1,
2005
­
June
30,
2006
Membership1
304
323
404
505
631
Membership
Goal
Adjusted
for
Annual
Attrition2
n/
a
n/
a
452
566
707
New
Applications
Needed
to
Meet
Membership
Goal
n/
a
25
173
215
269
Re­
applications
(
Round
#)
n/
a
n/
a
216
(
Rounds
1
and
2)
51
(
Rounds
3
and
4)
56
(
Rounds
5
and
6)

1
Assumes
an
annual
growth
rate
goal
of
25%
for
each
year
beginning
on
July
1,
2003
2
To
account
for
the
historical
attrition
rate
of
12%
of
facilities
annually,
EPA
added
12%
to
the
Membership
Goal,
and
calculated
the
number
of
applications
necessary
to
meet
the
attrition­
adjusted
goal.

EPA
estimates
that
the
application
will
take
approximately
40
hours
to
complete.
Postacceptance
activities
include
demonstration
of
compliance,
EMS
documentation
and
reporting,
demonstration
of
continuous
improvement,
annual
reporting,
and
public
outreach.
EPA
estimates
that
these
activities
combined
will
require
187.75
hours
per
facility.
In
total,
the
annual
burden
hours
for
each
facility
is
267.75
(
see
Table
6.2
for
detail).

This
ICR
uses
estimations
equivalent
to
those
of
the
original
ICR
to
approximate
the
number
of
hours
needed
to
complete
the
application
and
other
required
activities
for
Performance
Track.
For
the
original
ICR,
EPA
asked
seven
facilities
in
the
Star
Track
pilot
program
to
submit
an
approximation
of
the
number
of
hours
it
took
to
complete
similar
activities.
In
addition
to
the
StarTrack
pilot
project,
EPA
estimated
the
hourly
labor
rates
of
managerial,
legal,
technical,
and
administrative
professionals
according
to
the
Bureau
of
Labor
Statistics'
National
Occupational
Employment
and
Wage
and
Employer
Costs
for
Employee
Compensation
datasets.
The
hourly
labor
rate
estimate
for
EPA
activity
was
obtained
from
the
U.
S.
Office
of
Personnel
Management
2003
General
Schedule
Pay
Chart1
Table
6.2
(
below)
details
the
annual
respondent
burden
for
each
of
the
three
years
covered
by
this
ICR.
17
6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
EPA
estimates
total
annualized
respondent
costs
for
the
number
of
expected
participants
to
be
phase
in
the
program.
For
an
individual
facility,
the
application
phase
could
cost
$
2129.00
(
we
assume
equivalent
costs
for
re­
applications
by
current
members)
and
program
participation
could
cost
$
11,400.00.
Preparing
and
submitting
the
application
is
a
one­
time
event;
member
re­
applications
occur
once
every
three
years;
and
program
participation
activities
occur
annually.

Table
6.2
uses
the
following
equation
to
obtain
labor
costs:
(
Clerical
Hours
x
$
32.55/
hour)
+
(
Technical
Hours
x
$
58.80/
hour)
+
(
Managerial
Hours
x
$
74.87/
hour)
+
(
Legal
Hours
x
$
91.92/
hour)
=
Labor
Cost/
Year/
Respondent.

It
should
be
noted
that
Table
6.2
does
not
include
those
activities
considered
to
be
customary
business
practices
(
CBP).
As
stated,
cost
estimates
were
derived
from
the
Bureau
of
Labor
Statistics
Data,
and
reflect
benefits
and
overhead
costs.
18
Table
6.2:
Detailed
Annualized
Respondent
Burden
and
Cost,
July
1,
2003
­
June
30,
2006
Respondent
Burden,
July
1,
2003
­
June
30,
2004
Information
Collection
Activity
Legal
($
91.92/

Hour)
Mgr.

($
74.87/

Hour)
Tech.

($
58.80/

Hour)
Clerical
($
32.55/

Hour)
Resp.
Hours/

Year
Labor
Cost/

Year
#
Resp.
Total
Hours/

Year
Total
Cost/

Year
Applications
New
Applications
4
4
16
16
40.00
$
2,129
173
6920
$
368,275
Member
Re­
applications
4
4
16
16
40.00
$
2,129
216
8640
$
459,812
Program
Participation
Compliance
Compliance
Audit
Workplan
0
0.25
16
0.25
16.50
$
968
404
6666
$
390,933
Compliance
Audit
Report
4
2
47
0.25
53.25
$
3,289
404
21513
$
1,328,820
Submit
Compliance
Certification
4
4
0
0
8.00
$
667
404
3232
$
269,533
Compliance
Subtotal
77.75
$
4,924
404
31411
$
1,989,285
Document
EMS
Audit
Workplan
0
0.25
8
0.25
8.50
$
497
404
3434
$
200,891
Complete
Audit
0
0
13
0
13.00
$
764
404
5252
$
308,818
Implementation
Plan
0.5
0.5
18
0
19.00
$
1,142
404
7676
$
461,285
EMS
Subtotal
40.5
$
2,403
404
16362
$
970,994
Performance
Report
(
APR)

Reporting
on
Goals
in
APR
0
5
32
0.5
37.50
$
2,272
404
15150
$
917,979
Public
Outreach
and
Reporting
Outreach
0
4
8
4
16.00
$
900
404
6464
$
363,632
Reporting
0
4
8
4
16.00
$
900
404
6464
$
363,632
Public
Outreach
Subtotal
32
$
1,800
404
12928
$
727,265
Program
Participation
Subtotal
8.5
20
150
9.25
187.75
$
11,400
75851
$
4,605,522
Total
2003­
2004
16.5
28
182
41.25
267.75
$
15,657
91411
$
5,433,610
Respondent
Burden,
July
1,
2004
­
June
30,
2005
Information
Collection
Activity
Legal
($
91.92/

Hour)
Mgr.

($
74.87/

Hour)
Tech.

($
58.80/

Hour)
Clerical
($
32.55/

Hour)
Resp.
Hours/

Year
Labor
Cost/

Year
#
Resp.
Total
Hours/

Year
Total
Cost/

Year
Applications
New
Applications
4
4
16
16
40
$
2,129
215
8600
$
457,683
Member
Re­
applications
4
4
16
16
40
$
2,129
51
2040
$
108,567
Program
Participation
Compliance
Compliance
Audit
Workplan
0
0.25
16
0.25
16.5
$
968
505
8332.5
$
488,666
Compliance
Audit
Report
4
2
47
0.25
53.25
$
3,289
505
26891.25
$
1,661,025
Submit
Compliance
Certification
4
4
0
0
8
$
667
505
4040
$
336,916
Compliance
Subtotal
77.75
$
4,924
505
39263.75
$
2,486,606
19
Table
6.2:
Detailed
Annualized
Respondent
Burden
and
Cost,
July
1,
2003
­
June
30,
2006
(
continued)

Respondent
Burden,
July
1,
2004
­
June
30,
2005
(
continued)

Information
Collection
Activity
Legal
($
91.92/

Hour)
Mgr.

($
74.87/

Hour)
Tech.

($
58.80/

Hour)
Clerical
($
32.55/

Hour)
Resp.
Hours/

Year
Labor
Cost/

Year
#
Resp.
Total
Hours/

Year
Total
Cost/

Year
Document
EMS
Audit
Workplan
0
0.25
8
0.25
8.5
$
497
505
4292.5
$
251,114
Complete
Audit
0
0
13
0
13
$
764
505
6565
$
386,022
Implementation
Plan
0.5
0.5
18
0
19
$
1,142
505
9595
$
576,606
EMS
Subtotal
40.5
$
2,403
505
20452.5
$
1,213,742
Performance
Report
(
APR)

Reporting
on
Goals
in
APR
0
5
32
0.5
37.5
$
2,272
505
18937.5
$
1,147,474
Public
Outreach
and
Reporting
Outreach
0
4
8
4
16
$
900
505
8080
$
454,540
Reporting
0
4
8
4
16
$
900
505
8080
$
454,540
Public
Outreach
Subtotal
32
$
1,800
505
16160
$
909,081
Program
Participation
Subtotal
8.5
20
150
9.25
187.75
$
11,400
94813.75
$
5,756,903
Total
2004­
2005
16.5
28
182
41.25
267.75
$
15,657
105453.75
$
6,323,153
Respondent
Burden,
July
1,
2005
­
June
30,
2006
Information
Collection
Activity
Legal
($
91.92/

Hour)
Mgr.

($
74.87/

Hour)
Tech.

($
58.80/

Hour)
Clerical
($
32.55/

Hour)
Resp.
Hours/

Year
Labor
Cost/

Year
#
Resp.
Total
Hours/

Year
Total
Cost/

Year
Applications
New
Applications
4
4
16
16
40
$
2,129
269
10760
$
572,636
Member
Re­
applications
4
4
16
16
40
$
2,129
56
2240
$
119,211
Program
Participation
Compliance
Compliance
Audit
Workplan
0
0.25
16
0.25
16.5
$
968
631
10411.5
$
610,590
Compliance
Audit
Report
4
2
47
0.25
53.25
$
3,289
631
33600.75
$
2,075,458
Submit
Compliance
Certification
4
4
0
0
8
$
667
631
5048
$
420,978
Compliance
Subtotal
77.75
$
4,924
631
49060.25
$
3,107,027
Document
EMS
Audit
Workplan
0
0.25
8
0.25
8.5
$
497
631
5363.5
$
313,768
Complete
Audit
0
0
13
0
13
$
764
631
8203
$
482,336
Implementation
Plan
0.5
0.5
18
0
19
$
1,142
631
11989
$
720,473
EMS
Subtotal
40.5
$
2,403
631
25555.5
$
1,516,577
Performance
Report
(
APR)

Reporting
on
Goals
in
APR
0
5
32
0.5
37.5
$
2,272
631
23662.5
$
1,433,774
Public
Outreach
and
Reporting
Outreach
0
4
8
4
16
$
900
631
10096
$
567,950
Reporting
0
4
8
4
16
$
900
631
10096
$
567,950
Public
Outreach
Subtotal
32
$
1,800
631
20192
$
1,135,901
Program
Participation
Subtotal
8.5
20
150
9.25
187.75
$
11,400
118470.25
$
7,193,279
Total
2005­
2006
16.5
28
182
41.25
267.75
$
15,657
131470.25
$
7,885,126
20
(
ii)
Estimating
Capital
and
Operations
Maintenance
Costs.

Most
of
the
facilities
applying
to
the
Performance
Track
maintain
environmental
compliance
data
as
a
customary
business
practice.
EPA
does
not
expect
any
start­
up
or
capital
costs
to
affect
applicants
or
participants
in
Performance
Track
beyond
those
labor
costs
outlined
in
the
worksheets
in
this
section.

6(
c)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Based
on
the
Agency's
goal
of
a
25%
growth
rate
for
the
program,
EPA
estimates
that
new
Performance
Track
applications
will
range
from
173
to
269
during
the
period
covered
by
this
ICR.
Member
re­
applications
will
range
from
216
in
the
first
year
to
56
in
the
third
year
of
the
ICR
based
on
the
number
of
existing
members
that
need
to
re­
apply.
The
Agency
also
estimates
that
between
81
and
126
applicants
will
be
selected
for
participation
each
year
during
the
course
of
this
ICR.
EPA
requires
reports
listed
in
section
4(
b)(
i)
of
this
ICR
be
submitted
each
year
by
those
facilities
wishing
to
maintain
their
status
in
the
National
Environmental
Performance
Track
Program.
In
Tables
6.2
through
6.4
the
following
equations
are
applied
using
this
estimated
universe
of
respondents
to
obtain
total
hourly
burden
and
total
cost
estimates:

Hours/
Respondent
x
Total
Number
of
Respondents=
Total
Hours/
Year
Cost/
Respondent
x
Total
Number
of
Respondents
=
Total
Cost/
Year
6(
d)
Estimating
State
Burden
and
Costs
Table
6.3
provides
a
Summary
of
State
Burden
for
State
Regulatory
Agencies
(
Table
6.4
provides
a
yearly
breakout).
It
is
estimated
that
participating
regulatory
agencies
will
spend
6
hours
per
facility
during
the
application
review
phase,
and
2
hours
per
respondent
reviewing
environmental
performance
reports.
This
ICR
modifies
the
hours
estimate
for
the
Site
visit
to
12
hours,
comprising
pre­
visit
coordination,
travel,
site
visit,
and
a
post­
visit
report.
EPA
estimates
that
State
Agency
representatives
will
attend
75%
of
all
Site
visits.
Again,
we
assume
equivalent
costs
for
re­
applications
by
current
members.
This
translates
to
a
cost
to
the
state
of
$
289.08
per
applicant
during
the
application
and
re­
application
phases,
and
$
674.52
per
participant
during
a
typical
program
year.
Table
6.3
uses
the
following
equation
to
obtain
labor
costs:
(
Technical
Hours
x
$
48.18/
hour
)=
Labor
Cost/
Year/
Respondent.
21
Table
6.3:
Summary
of
Annualized
State
Burden,
July
1,
2003
­
June
30,
2006
Total
Hours
Total
Labor
Cost
Applications
Environmental
Compliance
Screen
1314
$
63,309
Evaluation
of
Application
2628
$
126,617
Member
Re­
applications1
1938
$
93,373
Application
Subtotal
5880
$
283,298
Annualized
Application
Subtotal
1960
$
94,433
Program
Participation
Review
APR
3080
$
148,394
Site
Visit
(
if
necessary)
2772
$
133,555
Program
Participation
Subtotal
5852
$
281,949
Annualized
Program
Participation
Subtotal
1951
$
93,983
Summary
Total
State
Burden,
2003­
2006
11732
$
565,248
Annualized
Total
State
Burden
3911
$
188,416
1
Although
re­
application
to
the
Performance
Track
Program
may
take
less
time
for
existing
members
than
the
original
application,
EPA
is
estimating
equivalent
burden
hours
and
costs
for
re­
application
for
purposes
of
this
ICR.
22
Table
6.4:
Detailed
Annualized
State
Burden,
July
1,
2003
­
June
30,
2006
State
Burden,
July
1,
2003
­
June
30,
2004
Tech.

($
48.18/
Hour)
Respondent
Hours/
Year
Labor
Cost/
Year
#
Respondents
Total
Hours/
Year
Total
Cost/
Year
Applications
Environmental
Compliance
Screen
2
2
$
96.36
173
346
$
16,670
Evaluation
of
Application
4
4
$
192.72
173
692
$
33,341
Member
Re­
applications1
6
6
$
289.08
216
1296
$
62,441
Application
Subtotal
12
12
$
578.16
2334
$
112,452
Program
Activities
Site
Visit
(
if
necessary)
2
12
12
$
578.16
61
727
$
35,036
Review
Annual
Performance
Report
2
2
$
96.36
404
808
$
38,929
Program
Activities
Subtotal
14
14
$
674.52
1535
$
73,966
Total
26
26
$
1,252.68
3869
$
186,418
State
Burden,
July
1,
2004
­
June
30,
2005
Tech.

($
48.18/
Hour)
Respondent
Hours/
Year
Labor
Cost/
Year
#
Respondents
Total
Hours/
Year
Total
Cost/
Year
Applications
Environmental
Compliance
Screen
2
2
$
96.36
215
430
$
20,717
Evaluation
of
Application
4
4
$
192.72
215
860
$
41,435
Member
Re­
applications
6
6
$
289.08
51
306
$
14,743
Application
Subtotal
12
12
$
578.16
1596
$
76,895
Program
Activities
Site
Visit
(
if
necessary)
12
12
$
578.16
76
909
$
43,796
Review
Annual
Performance
Report
2
2
$
96.36
505
1010
$
48,662
Program
Activities
Subtotal
14
14
$
674.52
1919
$
92,457
Table
6.4:
Detailed
Annualized
State
Burden,
July
1,
2003
­
June
30,
2006
23
Total
26
26
$
1,252.68
3515
$
169,353
State
Burden,
July
1,
2005
­
June
30,
2006
Tech.

($
48.18/
Hour)
Respondent
Hours/
Year
Labor
Cost/
Year
#
Respondents
Total
Hours/
Year
Total
Cost/
Year
Applications
Environmental
Compliance
Screen
2
2
$
96.36
269
538
$
25,921
Evaluation
of
Application
4
4
$
192.72
269
1076
$
51,842
Member
Re­
applications
6
6
$
289.08
56
336
$
16,188
Application
Subtotal
12
12
$
578.16
1950
$
93,951
Program
Activities
Site
Visit
(
if
necessary)
12
12
$
578.16
95
1136
$
54,723
Review
Annual
Performance
Report
2
2
$
96.36
631
1262
$
60,803
Program
Activities
Subtotal
14
14
$
674.52
2398
$
115,526
Total
26
26
$
1,252.68
4348
$
209,477
1
Although
re­
application
to
the
Performance
Track
program
may
take
less
time
for
existing
members
than
the
original
application,
EPA
is
estimating
equivalent
burden
hours
and
costs
for
re­
application
purposes
for
this
ICR.

2
This
ICR
modifies
the
hours
estimate
for
the
Site
visit
to
12
hours,
comprising
pre­
visit
coordination,
travel,
site
visit,
and
a
post­
visit
report.
EPA
estimates
that
State
Agency
representatives
will
attend
75%
of
all
Site
visits.
See
Appendix
C
for
the
program's
Site
Visit
Protocol.
2
Based
on
the
2003
General
Schedule
Pay
Chart,
and
adding
benefits
and
overhead
costs
pursuant
to
the
Office
of
Management
and
Budget's
Estimating
Paperwork
Burden
guidance,
EPA
estimates
an
average
adjusted
hourly
labor
cost
of
$
44.67
for
technical
staff
responsible
for
EPA
activities
in
the
National
Environmental
Performance
Track.

24
6(
e)
Estimating
Agency
Burden
and
Cost
Table
6.5
provides
a
Summary
of
Agency
Burden
and
Cost
to
EPA
staff
during
the
application
phase
and
the
program
(
Table
6.6
provides
a
yearly
breakout).
The
burden
included
in
the
tables
is
based
primarily
on
EPA's
experience
with
developing,
gathering
information,
and
providing
oversight
and
coordination
for
the
StarTrack
Program.
The
adjusted
hourly
labor
rate
was
developed
using
the
U.
S.
Office
of
Personnel
Management's
2003
General
Schedule
Pay
Chart.
2
EPA
estimates
it
will
expend
12
hours
per
facility
during
the
application
and
re­
application
phases,
and
11
hours
reviewing
participants'
annual
environmental
performance
reports.
This
ICR
modifies
the
hours
estimate
for
the
Site
visit
to
40
hours,
comprising
pre­
visit
coordination,
travel,
site
visit,
and
a
post­
visit
report.
EPA
estimates
that
it
will
conduct
site
visits
at
20%
of
all
Performance
Track
facilities
on
an
annual
basis.
The
cost
to
the
agency
is
$
536.04
per
applicant
during
the
application
and
re­
application
phases,
and
$
2,278.17
per
participant
during
a
typical
program
year.

Table
6.5:
Summary
of
Annualized
Agency
Burden,
July
1,
2003
­
June
30,
2006
Total
Hours
Total
Labor
Cost
Applications
Environmental
Compliance
Screen
1971
$
88,045
Evaluation
of
Application
5256
$
234,786
Notify
Applicant
of
Selection
Status
657
$
29,348
Member
Re­
applications1
3876
$
173,141
Application
Subtotal
11760
$
525,319
Annualized
Application
Subtotal
3920
$
175,106
Program
Participation
Review
APR
16940
$
756,710
Site
Visit
(
if
necessary)
12320
$
550,334
Program
Participation
Subtotal
29260
$
1,307,044
Annualized
Program
Participation
Subtotal
9753
$
435,681
Summary
Total
Agency
Burden,
2003­
2006
41020
$
1,832,363
Annualized
Total
Agency
Burden
13673
$
610,788
1Although
re­
application
to
the
Performance
Track
Program
may
take
less
time
for
existing
members
than
the
original
application,
EPA
is
estimating
equivalent
burden
hours
and
costs
for
re­
application
for
purposes
of
this
ICR.
25
Table
6.6:
Detailed
Annualized
Agency
Burden,
July
1,
2003
­
June
30,
2006
Agency
Burden,
July
1,
2003
­
June
30,
2004
Tech.

($
44.67/
Hour)
Respondent
Hours/
Year
Labor
Cost/
Year
#
Respondents
Total
Hours/
Year
Total
Cost/
Year
Applications
Environmental
Compliance
Screen
3
3
$
134.01
173
519
$
23,184
Evaluation
of
Application
8
8
$
357.36
173
1384
$
61,823
Notify
Applicant
of
Selection
Status
1
1
$
44.67
173
173
$
7,728
Member
Re­
applications1
12
12
$
536.04
216
2592
$
115,785
Application
Subtotal
24
24
$
1,072.08
4668
$
208,520
Program
Activities
Site
Visit
(
if
necessary)
2
40
40
$
1,786.80
81
3232
$
144,373
Review
Annual
Performance
Report
11
11
$
491.37
404
4444
$
198,513
Program
Activities
Subtotal
51
51
$
2,278.17
7676
$
342,887
Total
75
75
$
3,350.25
12344
$
551,406
Agency
Burden,
July
1,
2004
­
June
30,
2005
Tech.

($
44.67/
Hour)
Respondent
Hours/
Year
Labor
Cost/
Year
#
Respondents
Total
Hours/
Year
Total
Cost/
Year
Applications
Environmental
Compliance
Screen
3
3
$
134.01
215
645
$
28,812
Evaluation
of
Application
8
8
$
357.36
215
1720
$
76,832
Notify
Applicant
of
Selection
Status
1
1
$
44.67
215
215
$
9,604
Member
Re­
applications
12
12
$
536.04
51
612
$
27,338
Application
Subtotal
24
24
$
1,072.08
3192
$
142,587
Program
Activities
Site
Visit
(
if
necessary)
40
40
$
1,786.80
101
4040
$
180,467
Review
Annual
Performance
Report
11
11
$
491.37
505
5555
$
248,142
Program
Activities
Subtotal
51
51
$
2,278.17
9595
$
428,609
Total
75
75
$
3,350.25
12787
$
571,195
Table
6.6:
Detailed
Annualized
Agency
Burden,
July
1,
2003
­
June
30,
2006
26
Agency
Burden,
July
1,
2005
­
June
30,
2006
Tech.

($
44.67/
Hour)
Respondent
Hours/
Year
Labor
Cost/
Year
#
Respondents
Total
Hours/
Year
Total
Cost/
Year
Applications
Environmental
Compliance
Screen
3
3
$
134.01
269
807
$
36,049
Evaluation
of
Application
8
8
$
357.36
269
2152
$
96,130
Notify
Applicant
of
Selection
Status
1
1
$
44.67
269
269
$
12,016
Member
Re­
applications
12
12
$
536.04
56
672
$
30,018
Application
Subtotal
24
24
$
1,072.08
3900
$
174,213
Program
Activities
Site
Visit
(
if
necessary)
40
40
$
1,786.80
126
5048
$
225,494
Review
Annual
Performance
Report
11
11
$
491.37
631
6941
$
310,054
Program
Activities
Subtotal
51
51
$
2,278.17
11989
$
535,549
Total
75
75
$
3,350.25
15889
$
709,762
1Although
re­
application
to
the
Performance
Track
Program
may
take
less
time
for
existing
members
than
the
original
application,
EPA
is
estimating
equivalent
burden
hours
and
costs
for
re­
application
purposes
for
this
ICR.

2This
ICR
modifies
the
hours
estimate
for
the
Site
visit
to
40
hours,
comprising
pre­
visit
coordination,
travel,
site
visit,
and
a
post­
visit
report.
EPA
estimates
that
it
will
conduct
site
visits
at
20%
of
all
Performance
Track
facilities
on
an
annual
basis.
See
Appendix
C
for
the
program's
Site
Visit
Protocol.
27
6(
f)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally,
(
ii)
State
Tally,
(
iii)
Agency
Tally
Bottom
line
burden
hours
and
costs
for
respondents,
states
and
the
Agency
are
summarized
in
Table
6.7.

Table
6.7:
Bottom
Line
Burden
Hours
and
Costs
Total
Burden
Hours
Total
Costs
Respondents
109,445
$
6,547,296
States
3,911
$
188,416
Agency
13,673
$
610,788
Aggregate
Respondents
and
States
113,356
$
6,735,712
(
iv)
Variations
in
the
Annual
Bottom
Line
EPA
does
not
anticipate
significant
variation
(
greater
than
25
percent)
in
the
annual
respondent
reporting
burden
over
the
course
of
the
requested
ICR
period.
The
activities
required
for
the
Environmental
Performance
Track
will
be
the
same
for
each
respondent
during
each
year
of
participation.
In
addition,
those
who
are
not
accepted
and
reapply
will
experience
the
burden
of
application
more
than
once.
Re­
applications
may
require
resources
equivalent
to
initial
applications.

6(
g)
Reasons
for
Change
in
Burden
The
current
OMB
inventory
is
50,450
hours;
over
the
duration
of
this
ICR,
EPA
anticipates
incremental
growth
to
109,445
hours,
accounting
for
an
increase
in
burden
of
58,995
hours.

6(
h)
Burden
Statement
Based
on
the
Agency's
goal
of
a
25%
growth
rate
for
the
program,
EPA
estimates
that
28
new
Performance
Track
applications
will
range
from
173
to
269
during
the
period
covered
by
this
ICR.
Member
re­
applications
will
range
from
216
in
the
first
year
to
56
in
the
third
year
of
the
ICR
based
on
the
number
of
existing
members
that
need
to
re­
apply.
It
is
estimated
that
participating
facilities
will
spend
up
to
40
hours
preparing
the
application,
and
that
existing
members
will
spend
40
hours
preparing
re­
applications.
This
burden
hour
estimate
translates
to
a
cost
of
$
2129
per
facility
and
total
annualized
respondent
costs
of
phase
in
the
program.
The
Agency
also
estimates
that
between
81
and
126
applicants
will
be
selected
for
participation
each
year
during
the
course
of
this
ICR,
and
may
need
to
spend
187.75
hours
during
a
typical
year
of
participation
($
11,400.00
per
facility).
The
burden
hour
estimate
of
the
total
collection
translates
to
a
total
annualized
cost
of
$
6,547,296
(
a
total
three­
year
cost
of
$
19,641,888).

State
regulatory
agencies
may
need
to
spend
up
to
6
hours
annually
reviewing
each
Performance
Track
application
(
equivalent
costs
estimated
for
each
member
re­
application).
This
results
in
an
application
burden
cost
of
$
289.08
per
facility
and
an
annualized
application
subtotal
of
$
94,433.
EPA
also
estimates
that
the
state
may
need
to
spend
approximately
14
hours
per
facility
during
a
typical
year
of
participation.
This
results
in
a
participation
cost
estimate
of
$
674.52
per
facility
and
a
total
annualized
participation
cost
of
$
93,983.
The
burden
hour
estimate
of
the
entire
collection
equals
a
total
annualized
cost
to
states
of
$
188,416
(
a
total
threeyear
cost
of
$
565,248).

EPA
may
need
to
spend
up
to
12
hours
annually
reviewing
each
Performance
Track
application
(
equivalent
costs
estimated
for
each
member
re­
application).
This
results
in
an
application
burden
cost
of
$
536.04
per
facility
and
an
annualized
application
subtotal
of
$
175,106.
EPA
also
estimates
that
it
may
need
to
spend
approximately
51
hours
per
facility
during
a
typical
year
of
participation.
This
results
in
a
participation
cost
estimate
of
$
2,278.17
per
facility
and
a
total
annualized
participation
cost
of
$
435,681.
The
burden
hour
estimate
of
the
entire
collection
equals
a
total
annualized
cost
to
EPA
of
$
610,788
(
a
total
three­
year
cost
of
$
1,832,363).

Aggregated
across
EPA,
States,
and
respondents,
this
information
collection
totals
$
7,346,500
in
annualized
costs
(
a
total
three­
year
cost
of
$
22,039,500).

Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjusting
the
existing
ways
to
comply
with
any
preciously
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.
29
To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OA­
2003­
0001,
which
is
available
for
public
viewing
at
the
Office
of
Environmental
Information
Docket
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Ave.,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Office
of
Environmental
Information
Docket
is
(
202)
566­
1752.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
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
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
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.
(
OA­
2003­
0001)
and
OMB
control
number
(
2010­
0032)
in
any
correspondence.
30
APPENDIX
A
Application
to
National
Environmental
Performance
Track
31
APPENDIX
B
Annual
Performance
Report
32
Appendix
C
Site
Visit
Protocol
