SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
2100.01
"
REPORTING
REQUIREMENTS
UNDER
EPA'S
CLIMATE
LEADERS
PROGRAM"

February
27,
2003
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
..........................................
1
1(
a)
TITLE
AND
NUMBER
OF
THE
INFORMATION
COLLECTION
........................
1
1(
b)
SHORT
CHARACTERIZATION
/
ABSTRACT
..................................................
1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
............................................................
1
2(
a)
NEED
/
AUTHORITY
FOR
THE
COLLECTION
................................................
1
2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA
..................................................
2
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
......
2
3(
a)
NONDUPLICATION
..........................................................................................
2
3(
b)
PUBLIC
NOTICE
REQUIRED
PRIOR
TO
ICR
SUBMISSION
TO
OMB
............
2
3(
c)
CONSULTATIONS
...........................................................................................
2
3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION
.............................................
2
3(
e)
GENERAL
GUIDELINES
..................................................................................
3
3(
f)
CONFIDENTIALITY
..........................................................................................
3
3(
g)
SENSITIVE
QUESTIONS
.................................................................................
3
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
.................................
3
4(
a)
RESPONDENTS
NAICS
CODES
.....................................................................
3
4(
b)
INFORMATION
REQUESTED
..........................................................................
3
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
...........................................
5
5(
a)
AGENCY
ACTIVITIES
......................................................................................
5
5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT
...................................
6
5(
c)
SMALL
ENTITY
FLEXIBILITY
...........................................................................
6
5(
d)
COLLECTION
SCHEDULE
...............................................................................
7
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
...............................
7
6(
a)
ESTIMATING
RESPONDENT
BURDEN
..........................................................
7
6(
b)
ESTIMATING
RESPONDENT
COSTS
.............................................................
7
6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST
................................................
7
6(
d)
ESTIMATING
THE
RESPONSIBLE
UNIVERSE
AND
TOTAL
BURDEN
AND
COSTS
.....................................................................
10
6(
e)
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
............................................
10
6(
f)
REASONS
FOR
CHANGE
IN
BURDEN
.........................................................
11
6(
g)
BURDEN
STATEMENT
..................................................................................
11
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
This
ICR
is
entitled
"
Reporting
Requirements
Under
EPA's
Climate
Leaders
Program,"
EPA
ICR
Number
2100.01.

1(
b)
Characterization
of
the
Information
Collection
Climate
Leaders
is
an
EPA­
sponsored
voluntary
program
that
encourages
companies
to
develop
a
corporate
GHG
inventory
and
to
establish
greenhouse
gas
(
GHG)
reduction
goals.
Partners
in
the
program
benefit
from
participation
by
receiving
public
recognition
from
EPA
for
achieving
progress
toward
their
GHG
reduction
goals.
Partners
also
receive
assistance
in
the
form
of
identification
of
new
cost­
effective
GHG
reduction
opportunities.
The
program
is
run
through
EPA's
Climate
Protection
Partnerships
Division
(
CPPD)
in
the
Office
of
Air
&
Radiation.

Participation
in
the
program
begins
with
the
submittal
to
EPA
of
a
Letter
of
Intent
(
LOI)
that
outlines
responsibilities
of
the
Climate
Leaders
Partner
and
EPA.
The
LOI
begins
a
partnership
between
the
Climate
Leaders
Partner
and
EPA
wherein
the
Partner
agrees
to
develop
a
corporate
GHG
inventory
and
to
report
this
inventory
annually
to
EPA
using
Climate
Leaders
Reporting
Forms.
To
reduce
the
burden
on
Partners,
EPA
provides
technical
support
during
each
step
of
the
corporate
GHG
inventory
and
reporting
process.
Upon
completion
of
their
inventory,
Partners
then
agree
to
set
GHG
reduction
goals.
Partners
are
encouraged
to
publicize
their
involvement
in
the
program,
and
EPA
provides
additional
opportunities
for
public
recognition
to
Partners
who
meet
or
exceed
their
goals.
The
LOI
agreement
can
be
terminated
by
the
Climate
Leaders
Partner
or
EPA
with
no
notice
or
penalties.

This
ICR
provides
a
comprehensive
description
of
the
information
collections
under
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
by
2012.
Part
of
that
strategy
challenges
companies
to
set
GHG
reduction
goals
by
working
with
EPA
through
the
Climate
Leaders
program.

To
formally
establish
participation
in
the
Climate
Leaders
program,
EPA
collects
general
company
information
in
the
LOI.
This
information
typically
includes
the
identification
of
a
company
Liaison
and
other
contact
information.
2
EPA
also
provides
technical
assistance
to
Partners
to
help
them
develop
companyspecific
GHG
inventories
using
standardized
Climate
Leaders
Reporting
Forms.
Partners
report
their
GHG
inventory
to
EPA
annually,
and
this
information
allows
EPA
to
evaluate
a
Partner's
progress
and
performance,
and
to
assess
overall
program
results.

2(
b)
Practical
Utility/
Users
of
the
Data
EPA
uses
information
submitted
in
the
LOI
to
set
up
a
database
of
Partner
contact
information,
which
facilitates
information
dissemination
to
Partners.
EPA
uses
information
submitted
in
the
GHG
inventory
Reporting
Forms
to
monitor
the
progress
of
Partners
in
reducing
GHG
emissions,
in
order
to
provide
them
with
credible
public
recognition
when
they
meet
or
exceed
their
goal.
EPA
also
uses
this
information
to
provide
technical
assistance.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
information
to
be
obtained
under
this
ICR
has
not
been
collected
by
EPA
or
any
other
Federal
agency,
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
solicited
public
comments
on
the
ICR
through
an
announcement
in
the
Federal
Register
(
67
FR
117,
June
18,
2002).
The
comment
period
closed
on
August
19,
2002.
Two
companies
provided
comments.
Both
companies
requested
that
EPA
provide
flexibility
in
reporting
and
that
EPA
work
to
harmonize
with
other
GHG
reporting
schemes.
Since
the
first
Federal
Register
notice,
EPA
held
a
meeting
in
October
2002
with
Climate
Leaders
Partners
and
is
working
to
provide
additional
flexibility
in
the
Reporting
Forms.
EPA
also
continues
to
harmonize
with
State,
Federal,
and
international
GHG
reporting
schemes
in
order
to
minimize
reporting
burdens
on
companies
that
participate
in
more
than
one
reporting
scheme.

3(
c)
Consultations
EPA
consulted
with
six
Climate
Leaders
Partners
to
obtain
their
views
on
this
method
of
data
collection
and
obtained
their
input
on
the
burden
estimate.
Organizations
consulted
included:

°
Miller
Brewing
Company,
Quinton
Hancock,
tel.
414­
931­
3570
°
PSEG,
Mark
Brownstein,
tel.
973­
430­
7196
°
BP
p.
l.
c.
Corporation,
Denise
Michaelson,
tel.
213­
486­
0709
°
General
Motors
Corporation,
Kristen
Zimmerman,
tel.
313­
665­
9164
°
Norm
Thompson
Outfitters,
Derek
Smith,
email
dsmith@
nortom.
com
°
National
Renewable
Energy
Laboratory,
Dan
Bilello,
email
dan_
bilello@
nrel.
gov
3
3(
d)
Effects
of
Less
Frequent
Collection
The
development
of
an
LOI
is
a
one­
time
information
submittal
from
companies
that
choose
to
become
Partners.
EPA
also
asks
Partners
to
prepare
and
submit
an
annual
GHG
inventory
via
Climate
Leaders
Reporting
Forms.
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
public
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
Climate
Leaders
is
voluntary.
For
Partners
that
are
concerned
about
data
confidentiality,
EPA
will
consider
proposals
whereby
these
Partners
can
keep
data
confidential
by
designating
a
third
party
to
house
their
Reporting
Forms.
EPA
will
be
able
to
review
that
data
annually
by
making
an
on­
site
visit
to
ensure
credibility.
Another
alternative
that
EPA
offers
Partners
is
to
have
a
third
party
conduct
a
credible
GHG
inventory
audit,
and
provide
that
audit
to
EPA
for
review.
EPA
will
not
make
company­
or
agency­
specific
information
collected
under
this
ICR
and
claimed
as
confidential
business
information
("
CBI")
available
to
the
general
public
without
a
Partner's
permission,
except
in
accordance
with
EPA's
CBI
regulations
at
40
CFR,
Part
2,
subpart
B.
If
a
Partner
asserts
a
claim
of
confidentiality
covering
all
or
part
of
the
information
collections
covered
in
this
ICR,
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
LOI
or
the
Reporting
Forms.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondents/
NAICS
Codes
The
following
is
a
list
of
North
American
Industry
Classification
System
(
NAICS)
codes
and
associated
industries
that
may
be
affected
by
information
collections
covered
in
this
ICR:

Industry
Sector
NAICS
Code
Chemicals
(
except
agriculture)
422690
Primary
Metal
Manufacturing
331
Breweries
313120
4
Industry
Sector
NAICS
Code
Cement
and
Concrete
Product
Manufacturing
3273
Carpet
and
Rug
Mills
314110
Oil
&
Gas
Extraction
211
Petroleum
Refineries
324110
Motor
Vehicle
Manufacturing
3362
Electric
Power
Generation,
Transmission
and
Distribution
2211
Clothing
Stores
4481
4(
b)
Information
Requested
EPA
asks
all
Partners
to
develop
and
submit
a
simple,
one­
page
Letter
of
Intent
to
indicate
their
intention
to
participate
in
the
program.
Partners
also
submit
Climate
Leaders
Reporting
Forms
on
an
annual
basis.
The
Reporting
Forms
document
a
Partner's
GHG
emissions
in
the
past
year.
EPA
uses
this
data,
combined
with
the
company's
goal,
baseline
emissions,
and
previous
inventories
to
track
Partners'
progress
toward
their
GHG
reduction
goals.

Letter
of
Intent
EPA
asks
Climate
Leaders
Partners
to
develop
and
submit
an
LOI.

(
i)
Data
items:

Partners
provide
the
following
information
in
the
LOI:

°
The
name,
title,
address,
and
telephone,
email
address
and
facsimile
number
of
a
Liaison;
and
°
The
name,
address,
and
telephone
number
of
the
Partner's
CEO,
President,
or
Chairman,
if
applicable.

(
ii)
Respondent
activities:

In
developing
the
LOI,
Partners
perform
the
following
activities:

°
Receive
and
review
the
LOI;

°
Gather
address
and
contact
information
to
complete
the
LOI;
and
°
Sign
the
LOI
and
submit
it
to
EPA.
5
GHG
Inventory
Protocol
Reporting
Forms
In
order
to
assist
the
Agency
in
evaluating
whether
Partners
are
on
track
to
meet
their
GHG
reduction
targets,
EPA
asks
Partners
to
complete
and
submit
Climate
Leaders
GHG
inventory
protocol
Reporting
Forms
annually.
Partners
that
are
on
track
to
meet
their
targets
are
given
high­
level
public
recognition
to
champion
their
achievements.

(
i)
Data
items:

The
Partner
submits
the
following
information
in
the
Reporting
Forms:

°
Entity­
wide
energy
use
data
and/
or
emissions
data
from
the
company's
operations.

(
ii)
Respondent
activities:

Partners
conduct
the
following
activities
in
preparing
the
Reporting
Forms:

°
Review
the
data
requirements
and
previous
inventories;

°
Gather
the
requested
data
and
other
information
for
the
report;

°
Complete
and
compile
the
individual
forms;
and
°
Sign
and
submit
the
forms
to
EPA.

Note:
EPA
provides
a
variety
of
forms
of
technical
assistance
to
help
Partners
complete
their
Reporting
Forms,
including
on­
site
visits
to
collect
and
calculate
data,
assistance
filling
out
the
forms,
and
assistance
using
electronic
tools
such
as
spreadsheets.

Additional
Activities
During
participation
in
the
program,
Partners
may
be
requested
to
notify
EPA
of
any
change,
such
as
a
change
in
Climate
Leaders
Liaison.

(
i)
Data
items:

°
Changes
in
information,
such
as
the
name
of
a
new
liaison
or
change
in
address.

(
ii)
Respondent
activities:

°
Provide
EPA
with
new
information,
such
as
the
name
of
a
new
liaison
or
change
in
address.
6
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
EPA
performs
various
activities
after
a
Partner
submits
the
LOI
and
Reporting
Forms.

Letter
of
Intent
EPA
performs
the
following
activities
following
the
submittal
of
an
LOI:

°
Participate
in
calls
with
Partners;

°
Review
the
LOI
to
ensure
completeness
and
accuracy,
and
follow
up,
if
necessary;
and
°
Enter
LOI
information
into
a
contact
tracking
data
base.

Reporting
Forms
EPA
performs
the
following
activities
after
the
submittal
of
a
Partner's
GHG
inventory
protocol
Reporting
Forms:

°
Review
the
forms
to
ensure
completeness
and
accuracy,
and
conduct
follow­
up,
if
necessary;

°
Work
with
Partners
to
publicize
their
progress
towards
their
GHG
goal;
and
°
Enter
information
into
database.

Additional
Activities
EPA
may
also
perform
the
following
additional
activities:

°
Enter
any
changes
in
Partner's
information,
such
as
the
name
of
a
new
Liaison,
into
a
database.
7
5(
b)
Collection
Methodology
and
Management
In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
uses
a
stateof
the­
art
telephone
system,
personal
computers,
and
applicable
data
base
and
modeling
software.
EPA
will
ensure
the
accuracy
and
completeness
of
collected
information
by
reviewing
each
submittal.
EPA
will
enter
the
contact
information
obtained
from
the
LOI
into
a
data
base,
and
will
use
the
Climate
Leaders
Inventory
Protocol
Reporting
Forms
to
monitor
the
progress
of
Partners
in
reducing
GHGs
in
order
to
ensure
credibility
when
providing
Partners
with
public
recognition
for
meeting
their
GHG
reduction
goals.

5(
c)
Small
Entity
Flexibility
Because
Climate
Leaders
is
designed
primarily
for
large
industrial
and
commercial
companies,
EPA
expects
that
less
than
5
of
the
Climate
Leaders
Partners
will
be
small
entities
(
having
fewer
than
1,000
employees).
EPA
has
designed
its
program
to
minimize
respondent
burden
while
obtaining
sufficient
and
accurate
information.
In
addition,
the
burden
associated
with
Climate
Leaders
is
inherently
reduced
since
the
agreement
to
participate
is
voluntary.

5(
d)
Collection
Schedule
EPA
collects
initial
contact
information
via
the
LOI,
which
is
completed
and
submitted
by
each
Partner
upon
agreement
to
participate
in
the
program.
EPA
collects
information
annually
via
the
Climate
Leaders
Inventory
Protocol
Reporting
Forms
to
monitor
progress.
Finally,
EPA
may
collect
other
program
information
on
a
periodic
basis
or
as
the
information
is
submitted;
these
items
include
notification
of
changes
in
Liaison
and
notification
of
changes
in
a
Partner's
operations.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
EPA
consulted
with
fewer
than
nine
members
of
the
respondent
universe
to
estimate
the
burden
associated
with
participation
in
Climate
Leaders.
EPA
then
reviewed
comments
received
during
the
comment
period.
Exhibit
1
presents
the
estimated
annual
respondent
burden
for
information
collection
activities
associated
with
Climate
Leaders.

6(
b)
Estimating
Respondent
Costs
Labor
Costs
For
purposes
of
this
analysis,
EPA
estimates
an
average
hourly
respondent
labor
cost
(
including
fringe
and
overhead)
of
$
178
for
legal
staff,
$
106
for
managerial
staff,
$
80
for
technical
staff,
and
$
41
for
clerical
staff.
These
rates
are
based
on
data
gathered
through
consultations
with
Climate
Leaders
Partners.
8
1
Based
on
current
market
prices
(
January
2003).
Capital
Costs
Capital
costs
usually
include
any
produced
physical
good
needed
to
provide
the
needed
information,
such
as
machinery,
computers,
and
other
equipment.
EPA
anticipates
that
Partners
will
compile
data
via
existing
spreadsheet
software
programs;.
Therefore,
new
data
management
systems
will
not
be
needed.
However,
EPA
anticipates
that
there
will
be
some
capital
costs
related
to
the
purchase
of
file
cabinets
for
retaining
GHG
inventory
data
in
file
cabinets.
EPA
took
the
following
steps
to
estimate
the
cost
of
the
file
cabinets:


Estimate
the
number
of
file
cabinets
per
Partner
needed
for
the
information
repository.
Given
that
the
standard­
size,
five­
drawer,
lateral
file
cabinet
is
expected
to
hold
approximately
16,000
pages
of
material,
EPA
estimates
that
each
Partner
would
need
to
purchase
only
one
file
cabinet
to
retain
copies
of
the
applications
and
other
documentation
within
the
time
period
of
this
ICR.
The
approximate
cost
of
purchasing
a
file
cabinet
is
estimated
at
$
580.1

Calculate
the
annualized
cost.
EPA
used
the
following
formula
to
calculate
the
annual
cost
for
acquiring
a
file
cabinet:

Annualized
Net
Present
Value
=
$
580
x
[
1/(

1/(
1+
k)
t)]

where:
k
=
discount
rate
of
7
percent;
and
t
=
length
of
longest
Partner
GHG
goal
(
10
years).

EPA
estimates
that
each
Partner
will
pay
an
annual
cost
of
$
83
for
its
file
cabinet.
This
capital
cost
is
shown
in
Exhibit
1.

Operation
and
Maintenance
Costs
Operation
and
maintenance
(
O&
M)
costs
are
those
costs
associated
with
an
information
collection
incurred
continually
over
the
life
of
the
ICR.
They
are
defined
by
the
PRA
as
"
the
recurring
dollar
amount
of
costs
associated
with
O&
M
or
purchasing
services."
EPA
does
not
anticipate
that
Partners
will
incur
O&
M
costs
in
carrying
out
the
information
collections
covered
in
this
ICR.

6(
c)
Estimating
Agency
Burden
and
Cost
Exhibit
2
presents
the
estimated
Agency
burden
hours
and
costs
for
the
information
collection
activities
associated
with
this
ICR.
EPA
estimates
an
average
hourly
labor
cost
(
labor
plus
overhead)
of
$
70.82
for
legal
staff,
$
66.22
for
managerial
staff,
$
48.55
for
technical
staff,
and
$
21.73
for
clerical
staff.
To
derive
these
hourly
estimates,
EPA
first
obtained
salary
figures
for
the
following
government
service
levels
in
the
2002
Federal
Pay
Schedule:

°
Legal
Staff
GS­
15,
Step
1;
9
2
Note
that
the
number
of
new
Partners
is
expected
to
decline
over
the
three
years
because
there
are
a
limited
number
of
large
companies
in
the
industrial
sector
that
can
be
expected
to
make
GHG
reduction
targets.
°
Managerial
Staff
GS­
14,
Step
4;
°
Technical
Staff
GS­
12,
Step
5;
and
°
Clerical
Staff
GS­
6,
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.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Currently,
there
are
37
Partners
in
the
Climate
Leaders
program.
As
seen
in
the
table
below,
EPA
anticipates
that,
over
the
three­
year
period
of
this
ICR,
45
additional
companies
(
i.
e.,
20
+
15+
10
=
45)
will
join
the
Program.
2
This
results
in
a
total
of
82
Partners
in
the
Program
at
the
end
of
the
three
years.

Respondent
Universe
2003
2004
2005
Average
Existing
Partners
at
the
beginning
of
the
year
37
57
72
55
New
Partners
during
the
year
20
15
10
15
Partners
submitting
inventories
at
the
end
of
the
year
37
57
72
55
In
the
following
paragraphs,
EPA
describes
the
data
and
assumptions
used
in
estimating
annual
hour
and
cost
burden
to
Partners
under
the
Climate
Leaders
program.

Letter
of
Intent
Each
company
seeking
to
become
a
Partner
signs
and
submits
an
LOI
to
EPA
to
participate
in
the
program.
EPA
estimates
that,
on
average,
15
new
Partners
will
submit
an
LOI
each
year
during
the
three­
year
period
covered
in
this
ICR.

GHG
Reporting
Forms
All
Partners
are
asked
to
complete
and
submit
an
annual
GHG
inventory
via
the
Climate
Leaders
Reporting
Forms
only
after
one
year
of
participation
in
the
program.
Due
to
this
one­
year
time
lag,
EPA
estimates
that,
on
average,
55
Partners
will
submit
GHG
Reporting
Forms
each
year
during
the
three­
year
period
covered
in
this
ICR.
10
Additional
Activities
EPA
expects
that
some
additional
information
submittals
may
be
requested
of
some
Partners.
EPA's
experience
with
other
voluntary
programs
indicates
that
approximately
10
percent
of
all
Partners
experience
a
change,
such
as
in
their
company
Liaison,
each
year.
Thus,
EPA
estimates
that,
each
year,
seven
Partners
(
i.
e.,
average
of
70
Partners
in
the
Program
over
the
three
years
x
0.10
=
7)
will
notify
EPA
of
a
change.
11
EXHIBIT
1
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Number
of
Total
$
178/
$
106/
$
80/
$
41/
Hours/
Cost/
Startup
O
&
M
Respondts
Total
Cost/

INFORMATION
COLLECTION
ACTIVITY
Hour
Hour
Hour
Hour
Year
Year
Cost
Cost
Hours/
Year
Year
Receive
and
review
the
LOI
0.5
3.0
1.5
0.0
5.0
$
527
$
0
$
0
70
350
$
36,890
Gather
address
and
contact
information
to
complete
LOI
0.0
0.0
0.5
0.0
0.5
$
21
$
0
$
0
70
35
$
1,470
Sign
and
submit
LOI
to
EPA
0.5
1.0
1.0
0.0
2.5
$
275
$
0
$
0
70
175
$
19,250
SUBTOTAL
1.0
4.0
3.0
0.0
8.0
$
823
$
0
$
0
70
560
$
57,610
Review
the
data
requirements
and
previous
inventories
1.0
2.0
10.0
0.0
13.0
$
1,190
$
0
$
0
55
715
$
65,450
Gather
the
requested
data
and
other
information
for
the
report
0.0
0.0
40.0
0.0
40.0
$
3,200
$
0
$
0
55
2,200
$
176,000
Complete
and
compile
the
individual
forms
0.0
0.0
20.0
0.0
20.0
$
1,600
$
0
$
0
55
1,100
$
88,000
Sign
and
submit
the
forms
to
EPA
0.0
5.0
0.0
2.0
7.0
$
612
$
0
$
0
55
385
$
33,660
SUBTOTAL
1.0
7.0
70.0
2.0
80.0
$
6,602
$
0
$
0
55
4,400
$
363,110
Provide
EPA
with
new
information
0.00
0.00
2.00
0.00
2.00
$
160
$
0
$
0
7
14
$
1,120
Purchase
file
cabinets
0.00
0.00
0.00
2.00
2.00
$
82
$
83
$
0
70
140
$
11,550
TOTAL
varies
varies
varies
varies
varies
varies
varies
$
0
varies
5,114
$
433,390
Letter
of
Intent
GHG
Inventory
Protocol
Reporting
Forms
Additional
Activities
File
Cabinets
12
EXHIBIT
2
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
Hours
and
Costs
Per
Respondent
Per
Activity
Total
Hours
and
Costs
Number
of
Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Respondts
Total
Total
$
63.31/
$
59.20/
$
43.41/
$
19.42/
Hours/
Cost/
Startup
O
&
M
Hours/
Cost/

INFORMATION
COLLECTION
ACTIVITY
Hour
Hour
Hour
Hour
Year
Year
Cost
Cost
Year
Year
Participate
in
calls
with
Partners
2.00
8.00
6.00
0.00
16.00
$
861
$
0
$
0
70
1,120
$
60,270
Review
the
LOI
and
follow
up,
if
necessary
0.00
2.00
4.00
0.00
6.00
$
292
$
0
$
0
70
420
$
20,440
Enter
LOI
contact
information
into
database
0.00
0.00
0.00
4.00
4.00
$
78
$
0
$
0
70
280
$
5,460
SUBTOTAL
2.00
10.00
10.00
4.00
26.00
$
1,231
$
0
$
0
70
1,820
$
86,170
Review
forms
and
conduct
follow
up,
if
necessary
0.00
6.00
20.00
0.00
26.00
$
1,223
$
0
$
0
55
1,430
$
67,265
Work
with
Partners
to
publicize
their
GHG
goal
1.00
6.00
8.00
0.00
15.00
$
766
$
0
$
0
55
825
$
42,130
Enter
information
into
database
0.00
0.00
2.00
0.00
2.00
$
87
$
0
$
0
55
110
$
4,785
SUBTOTAL
1.00
12.00
30.00
0.00
43.00
$
2,076
$
0
$
0
55
2,365
$
114,180
Enter
any
changes
into
database
0.00
0.00
0.00
2.00
2.00
$
39
$
0
$
0
7
14
$
273
TOTAL
varies
varies
varies
varies
varies
varies
$
0
$
0
varies
4,199
$
200,623
Additional
Activities
Letter
of
Intent
GHG
Inventory
Protocol
Reporting
Forms
13
6(
e)
Bottom
Line
Burden
Hours
and
Costs
Respondent
Tally
Exhibit
1
shows
the
total
annual
hour
and
cost
burden
to
respondents.
As
shown
in
the
exhibit,
EPA
estimates
the
annual
respondent
burden
to
be
5,114
hours
and
$
433,390.
The
bottom
line
burden
to
respondents
over
three
years
is
estimated
to
be
15,342
hours
and
$
1,300,170.

Agency
Tally
Exhibit
2
shows
the
total
annual
hour
and
cost
burden
to
the
Agency.
As
shown
in
this
exhibit,
EPA
estimates
the
annual
Agency
burden
to
be
4,199
hours
and
$
200,623.
The
bottom
line
burden
to
the
Agency
over
three
years
in
estimated
to
be
12,597
hours
and
$
601,869.

6(
f)
Reasons
for
Change
in
Burden
The
burden
outlined
below
for
the
information
collection
envisioned
under
this
ICR
is
necessary
to
help
the
Agency's
determine
whether
Climate
Leaders
is
achieving
its
goals
under
the
Administration's
Climate
Strategy.
The
activities
undertaken
by
Partners
in
Climate
Leaders
are
anticipated
to
offset
some
of
this
burden
as
Partners
identify
new
emission
reduction
opportunties
that
result
in
savings
to
the
company
through,
for
example,
enhanced
energy
efficiency.

6(
g)
Burden
Statement
The
estimated
average
reporting
burden
for
each
Climate
Leaders
Partner
to
complete
and
submit
an
LOI
is
8
hours.
The
burden
estimate
includes
time
to
receive,
review,
sign,
and
submit
the
LOI.

The
estimated
average
reporting
burden
to
prepare
and
submit
Climate
Leaders
inventory
protocol
Reporting
Forms
for
each
Climate
Leaders
Partner
is
estimated
to
be
80
hours.
The
burden
estimate
includes
time
to
review
the
requirements,
gather
the
requested
data
and
other
information,
complete
the
Reporting
Forms,
and
submit
the
report
to
EPA.

The
annual
public
reporting
and
recordkeeping
burden
f
or
this
collection
of
information
is
estimated
to
average
88
hours
per
response.
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;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
14
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
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.
OAR­
2002­
0094,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center,
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
Air
Docket
is
(
202)
566­
1742.
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.
(
OAR­
2002­
0094).
