	             

SUPPORTING STATEMENT

ENVIRONMENTAL PROTECTION AGENCY

REPORTING REQUIREMENTS UNDER EPA’S CLIMATE LEADERS PARTNERSHIP
(Renewal)

1.	IDENTIFICATION OF THE INFORMATION COLLECTION REQUEST

1(a)	Title and Number of the Information Collection Request

Reporting Requirements Under EPA’s Climate Leaders Partnership
(Renewal), EPA ICR No. 2100.03, OMB Control No. 2060-0532. 

1(b)	Short Characterization/Abstract

Climate Leaders is an EPA-sponsored voluntary program that encourages
companies to develop a corporate greenhouse gas (GHG) inventory and
inventory management plan and to establish a GHG emissions reduction
goal. Partners in the program benefit from participation by receiving
public recognition from EPA for achieving progress toward their GHG
emissions reduction goal. Partners also receive technical assistance in
developing their GHG inventory and inventory management plan, and in
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
Partnership Agreement that outlines responsibilities of the Climate
Leaders Partner and EPA. The Partnership Agreement begins a partnership
between the Climate Leaders Partner and EPA wherein the Partner agrees
to develop a corporate-wide GHG inventory and inventory management plan,
and to report this inventory annually to EPA using the Climate Leaders
Annual GHG Inventory Summary and Goal Tracking Form. To reduce the
burden on Partners, EPA provides checklists and examples for developing
inventory management plans, uses pre-populated electronic reporting
techniques, and 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 emissions 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 Partnership 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 and 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 emissions 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 Partnership Agreement. This
information typically includes the identification of a company liaison
and other contact information. EPA also provides technical assistance to
Partners 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 using the Climate Leaders
Annual GHG Inventory Summary and Goal Tracking Form. Partners report
their GHG inventory to EPA annually, which allows EPA to evaluate a
Partner's progress and performance and to assess overall program
results.  This GHG inventory data and supporting documentation collected
through this Partnership provides the necessary level of detail for
accurately measuring each Partner’s contribution towards reducing GHG
emissions.  

2(b)	Practical Utility/Users of the Data

EPA uses information submitted in the Partnership Agreement to set up a
database of Partner contact information, which facilitates information
dissemination to Partners. EPA uses information submitted in the
Inventory Management Plans to assure that the Partner’s GHG inventory
is of sufficient quality for recognition in the Climate Leaders program
and to provide technical assistance and example plans to other Partners
that are developing their own GHG management strategies. EPA uses
information submitted in the Climate Leaders Annual GHG Inventory
Summary and Goal Tracking Form to accurately 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

In order to maintain the reputable standing of the voluntary Climate
Leaders Partnership, and credibly discuss Partner corporations as
“leaders” in reducing emissions of GHGs, the data collected under
this ICR is very specific to each Partner’s GHG inventory and is
subject to a rigorous review process.  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 issued
a public notice in the Federal Register on May 30, 2008 (73FR 31087) No
comments were received. 

3(c)	Consultations 

EPA followed the approved method of consultations with Climate Leaders
Partners to obtain 

their views on this method of data collection and burden estimate. 
Various Climate Leaders 

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 Partners with a list of reporting requirements under
the Climate Leaders 

Partnership, and asked them to estimate the associated hourly 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 Partners provided
hourly estimates for each activity, and either provided labor rates or
indicated that the labor rates from the initial ICR were representative.
 Generally, the estimates provided by the Partners were consistent with
EPA expectations of the labor burden.  

3(d)	Effects of Less Frequent Collection		

The development of a Partnership Agreement, Inventory Management Plan
and GHG emissions reduction goal are one-time information submittals
from companies that choose to become Partners. EPA also asks Partners to
prepare and submit the Climate Leaders 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 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. Additionally, Climate
Leaders focuses its information collection at the corporate level and
does not retain records of facility specific data.  For Partners that
are concerned about data confidentiality, EPA will consider proposals to
be able to review sensitive data 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 that is collected under this ICR and that is 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 Partnership
Agreement, Inventory Management Plan, or Climate Leaders Annual GHG
Inventory Summary and Goal Tracking Form.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)	Respondents and NAICS Codes

 	Following are the North American Industrial Classification System
(NAICS) codes associated with the majority of companies currently
participating in the program.  Other types of companies may join this
voluntary program in the future.

NAICS Title	

NAICS Code

Breweries	31212

Carpet and Rug Mills	31411

Cement and Concrete Product Manufacturing	3273

Chemicals (except agriculture)	325

Clothing Stores	4481

Electric Power Generation, Transmission and Distribution	2211

Federal Government	9211

Financial Services	5221

Food Manufacturing	311

Lodging/Accommodations Services	7211

Motor Vehicle Manufacturing	3362

Office Machinery Manufacturing	333313

Oil & Gas Extraction	211

Petroleum Refineries	3241

Pharmaceutical Manufacturing	3254

Primary Metal Manufacturing	331

Semiconductor Manufacturing	3344

Waste Management	          562

Glass and Glass Product Manufacturing	         3272



4(b)	Information Requested

EPA asks all Partners to submit a simple, one-page Partnership Agreement
to indicate their intention to participate in the program. Within the
first year of joining the program, Partners also develop and submit an
Inventory Management Plan, base year inventory, and work to develop a
GHG emissions reduction goal. They also submit a brief company profile
which EPA posts on the Climate Leaders Web site to provide publicity and
recognition.

In order to measure the progress toward meeting the GHG reduction goals,
Partners complete and submit the Climate Leaders Annual GHG Inventory
Summary and Goal Tracking Form. This form documents a Partner’s GHG
emissions during the past year. Partners may also submit contact or
profile updates through e-mail or the Climate Leaders Web site, as
necessary.   SEQ CHAPTER \h \r 1 Each information collection activity is
described below. 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.

	(1)	Partnership Agreement

	EPA asks Climate Leaders Partners to develop and submit a Partnership
Agreement.

Data items.  Partners provide the following information in the
Partnership

Agreement:

The name, title, address, and telephone, e-mail address and facsimile
number of a designated company representative.

(ii)	Respondent activities.	In developing the Partnership Agreement,
Partners perform 

the following activities:

Receive and review the Partnership Agreement.

Gather address and contact information to complete the Partnership
Agreement.

Sign the Partnership Agreement and submit it to EPA.

	(2)	Inventory Management Plan

	EPA asks Climate Leaders Partners to develop and submit a
corporate-wide Inventory Management Plan to describe the Partner’s
process for completing a high-quality, corporate-wide GHG inventory.
There is not a standard template for an Inventory Management Plan,
instead each plan is tailored to the Partner’s corporate structure so
that the plan is most beneficial to the Partner corporation. Although
each plan is unique, an Inventory Management Plan checklist provides
guidance on the seven required areas included in the plan. EPA also
posts examples of Inventory Management Plans on its website from several
Partners that have completed the process.

	(i)	Data items.  The Inventory Management Plan must contain details in
seven 		different areas as listed below: 

Partner Information: 

The legal name of the company and its physical address, as well as a
contact name, title, address, telephone, e-mail address and facsimile
number of a designated inventory representative for the company.

Boundary Conditions: 

Organizational boundary descriptions, which define a basis for reporting
emissions data from partially owned or controlled assets, and a list of
facilities with location, percent ownership or percent control that are
included in the inventory. 

Operational boundary descriptions, which include a list of GHGs included
in the inventory and a description of the procedure or method used to
identify direct and indirect emission sources. For direct sources, a
list of groups of emission sources by emission category for each
facility or reporting unit; for indirect sources, a list of energy
imports or exports that are reflected in the inventory; and for optional
sources, a list of other sources that are accounted for in the
inventory.

Emissions Quantification: 

A description of the emission quantification methodologies, with
references, used for each emission source and offset project; a list of
emission factors and other constants, with references, for each emission
category; and a process for maintaining the use of current external
references.

Data Management:

A description to identify the source of data documents or processes
required to complete the emissions quantification methodology (e.g.,
monthly fuel purchase records, fuel meters, etc.) for each item of
activity data.

A description of the process for collecting and processing activity or
monitoring data from its original source to the final emission data
entered into the inventory.

A description of the normalization factor (units of product, $ revenue,
etc.) used to calculate emission intensity and associated documentation
on selecting the normalization factor.*

A description of the process flow for collecting and processing activity
or monitoring data to obtain the final normalization factor data entered
into the inventory.*

A description of the major sources of uncertainty and quality assurance
measures for the data process flow. This includes information on how
measurement system accuracy is assessed.

A description of how data collection system security is maintained.

A description of how GHG reporting and processing is integrated with
other reporting tools; and

The frequency for reporting facility data to the corporate level.

* These items are only necessary if Partner chooses to set its GHG goal
based on an intensity target.

Base Year:  

A description of the approach for adjusting base year emissions due to
structural changes in the Partner corporation (e.g., mergers,
acquisitions, divestitures, and outsourcing) or changes to the
methodology (e.g., calculations, emission factors, or error correction).

Management Tools:  

A description of the overall roles and responsibilities for corporate
GHG inventory development and maintenance, training received by
inventory development team members, and version control of inventory
management guidelines.

Auditing and Verification:

A description of the internal audit process and timing and if
applicable, a description of the external review process and timing.

A description of the senior management review process.

A description of the process for implementing and documenting corrective
actions for all internal and external reviews.

	(ii)	Respondent activities.  In completing the Inventory Management
Plan, Partners perform the following activities:

Review Inventory Guidance and Inventory Management Checklist for
requirements on developing and reporting GHG emissions and example
Inventory Management Plans; Draft and document corporate-wide Inventory
Management Plan and submit to EPA for review.

Revise Inventory Management Plan based on EPA comments and resubmit to
EPA.

Select location and prepare for on-site Inventory Management Plan
Review.

	(3)	Annual GHG Inventory Summary and Goal Tracking Form (Base Year)

	After a Partner has completed its Inventory Management Plan, EPA asks
Climate Leaders Partners to calculate and summarize corporate-wide GHG
emissions for the base year inventory.

	(i)	Data items:  Partners provide the following information to EPA:

The legal name of the company and reporting year, and the name, title,
department, address, and telephone, e-mail address and facsimile number
of an inventory contact person.

For emissions in the United States:  

Direct emissions from each source category (e.g., stationary combustion,
mobile combustion) and the name and corresponding direct emissions from
each source of chemical process or fugitive emissions.

Indirect emissions from purchased electricity, steam, and hot water. 

The name of each optional emission source with its corresponding
emissions.

Total GHG emissions from stationary and mobile sources of biomass
combustion. Note that direct emissions listed above should not include
biomass source emissions.

For facilities that choose to self-track CFC / HCFC emissions from
refrigerants, the metric tons of gas of CFCs and HCFCs.

For non-utility facilities that choose to report the portion of direct
stationary source emissions allocated to the amount of energy sold
outside organizational boundaries, the quantity of electricity (MWh) or
steam (Btu) sold and the emissions from these sold quantities.

For emissions outside the U.S., if the Partner chooses to report
non-U.S. emissions, enter base year emissions for all source categories
as entered for emissions inside the U.S.

  

(ii)	Respondent activities. In completing the base year inventory,
Partners perform the following activities:

Review the form instructions and requirements and Climate Leaders 
Inventory Guidance. 

Summarize the requested data at the corporate level.

Complete spreadsheet form and submit to EPA.

	(4)	GHG Emissions Reduction Goal Setting

	After a Partner has completed its base-year GHG inventory, EPA asks
Climate Leaders Partners to set an aggressive corporate-wide GHG
emissions reduction goal. 

	(i)	Data items. Partners provide the following information to EPA:

GHG emissions reduction goal in terms of an absolute GHG reduction or as
a decrease in GHG intensity.

Year of GHG emissions reduction goal.

For a goal in terms of GHG intensity, the units of a normalization
factor (e.g., tons of product).

For a normalized goal, the values of the normalization factor for base
year and annual year reporting.

(ii)	Respondent activities. In selecting a GHG emissions reduction goal,
Partners perform the following activities:

Select and submit goal to EPA for review.

Revise goal based on EPA input and resubmit to EPA for review.

Enter goal, goal year, and normalization factor (if necessary) in the
Annual GHG Inventory Summary and Goal Tracking Form.

	(5)	Annual GHG Inventory Summary and Goal Tracking Form (Subsequent
Year)

	In order to assist the Agency in evaluating whether Partners are on
track to meet their GHG reduction targets, EPA asks Partners to update
the base year inventory each subsequent year with the Annual GHG
Inventory Summary and Goal Tracking Form. 

	(i)	Data items. Partners provide the following information to EPA:

For all categories of base year data entered, input the annual emission
values for the current year inventory.

New source categories and corresponding emissions, as necessary.

If the inventory is re-baselined, due to an acquisition, the new base
year estimate.

Number of times the base year data has been adjusted since the first
inventory submittal year with an explanation of each adjustment.

Description of any changes in calculation methodologies or any other
significant differences from the previous year data submittal to EPA.

Year of inventory represented and the date the form was completed.

(ii)	Respondent activities. In completing subsequent years of the Annual
GHG Inventory Summary and Goal Tracking Form, Partners perform the
following activities:

Select and submit goal to EPA for review.

Revise goal based on EPA input and resubmit to EPA for review.

	(6)	Web Profile

	After a Partner has set its GHG emissions reduction goal, EPA requests
Partners submit a short company profile, which will be posted on the
Climate Leaders Web site.  

(i)	Data items. Partners provide the following information to EPA:

Partner company information including: city and state of corporate
headquarters, company Web site and company environmental Web site.

GHG emissions reduction goal.

Descriptions of company, reason for joining climate leaders, GHG
emission reductions before joining climate leaders, approach to GHG
management, and progress towards goal completion.

(ii)	Respondent activities. In preparing a Web profile form, Partners
perform the following activity:

Complete and submit Web profile form to EPA.

(7)	Additional Activities 

	During participation in the program, Partners may be requested to
notify EPA of any

change, such as a change in Climate Leaders Company Representative.

	(i)	Data items. Partners provide the following information to EPA:

Changes in information, such as the name of a new company
representative, change in address or update to the Web profile.

(ii)	Respondent activities. In updating information, Partners perform
the following activity:

Provide EPA with new information, such as the name of a new liaison or
change in address via e-mail or Climate Leaders Web site.

5.	AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)	Agency Activities

This section discusses the forms and associated Agency activities under
EPA’s Climate Leaders Partnership.

	(1)	Partnership Agreement

Review Partnership Agreement and file.

Enter Partnership Agreement contact information into database.

Participate in calls with Partners.

	(2)	Inventory Management Plan

Assist Partner in developing and documenting Inventory Management Plan.

Receive and review draft Inventory Management Plan according to required
components from the Inventory Management Plan checklist and submit
comments to Partner, as necessary.

File final version of Inventory Management Plan after corrections have
been made.

Prepare and attend on-site Inventory Management Plan Review.

Document on-site review visit.

(3)	Annual GHG Inventory Summary and Goal Tracking Form (Base Year)

Assist Partner in summarizing inventory data and completing form. 

Receive, review, and enter information from spreadsheet form into
database.

(4)	GHG Emissions Reduction Goal Setting

Assist Partner in selecting a key performance indicator.

Create a sector benchmark for comparing GHG emissions performance.

Review Partner GHG emissions reduction goal against the projected
benchmark GHG emissions improvement rate for each Partner’s sector.

Compare Partner’s current emissions intensity to sector-wide emissions
intensity.

Negotiate GHG emissions reduction goal with Partner, as necessary.

Enter Partner’s goal in database and post on Web.

(5)	Annual GHG Inventory Summary and Goal Tracking Form (Subsequent
Year)

Pre-populate spreadsheet form with data from all previous years and
contact information.

Receive, review, and enter updated information from spreadsheet form
into database.

(6)	Web Profile

Compile information from each Partner’s Web Profile and post on
Climate Leaders Web site to publicize the Partner’s commitment and
progress towards achieving GHG emissions reduction goal.

(7)	Additional Activities

Enter revised contact or profile information updates submitted by
Partners through the Climate Leaders Web site or e-mail.

5(b)	Collection Methodology and Management

  SEQ CHAPTER \h \r 1 The methods selected for this information
collection are chosen based on efficiency and minimization of burden for
respondents and EPA. The Partnership Agreements can be downloaded from
the Climate Leaders Web site and returned to EPA either by fax or mail.
EPA will review and then enter the contact information obtained from the
Partnership Agreement into a data base. Resources for developing
Inventory Management Plans, calculating a base year inventory, setting a
GHG emissions reduction goal, and completing the Annual GHG Inventory
Summary and Goal Tracking Form can be downloaded from the Climate
Leaders Web site. In addition, EPA allocates a substantial amount of
technical assistance hours for supporting each Partner as it develops an
Inventory Management Plan, calculates a base year inventory, and selects
a GHG emissions reduction goal. All of these reporting requirements,
other than the initial Partnership Agreement are submitted to EPA
electronically.

For the base year inventory, 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 Partner must enter into the base year spreadsheet.  The
Partner will submit the completed form to EPA electronically.  For
subsequent year inventories, EPA will send a pre-populated Annual GHG
Inventory Summary and Goal Tracking Forms to Partners each year
containing the information previously submitted. Partners need only
review the information for accuracy and submit any updates for the
current year inventory, thus further minimizing the burden of the
respondents and maintaining data accuracy and consistency. The Annual
GHG Inventory Summary and Goal Tracking Forms are submitted to EPA
electronically. All information received through the forms will be
reviewed by EPA for accuracy and completeness before being entered into
the database or on the Climate Leaders Web site.  

5(c)	Small Entity Flexibility

Because Climate Leaders is designed primarily for large industrial and
commercial

companies, EPA expects that less than 10 of the Climate Leaders Partners
will be small entities

(having fewer than 1,000 employees). EPA has designed its program and
reporting forms to minimize respondent burden while obtaining sufficient
and accurate information. The partnership program was designed to be
highly flexible and the hourly burden estimates for reporting
requirements under the Climate Leaders Partnership will be lessened due
to the less complex structure of GHG emissions inventories at small
entities. Additionally, Partners create their own Inventory Management
Plans and GHG emissions reduction goals, subject to the Inventory
Management Plan checklist and goal-setting criteria, and based on
individual Partner resources. As discussed above, Climate Leaders
provides technical assistance to Partners, including small entities, and
facilitates electronic submittal of information.  In conclusion, 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 Partnership Agreement,
which is completed and submitted by each Partner upon agreement to
participate in the program. Other one-time information collection
activities include the Inventory Management Plan, base year inventory
reporting via the Annual GHG Inventory Summary and Goal Tracking Form,
GHG emissions reduction goal-setting, and Partner Web Profile, which is
completed and submitted by each Partner during its first year in the
program. EPA collects information annually via the Annual GHG Inventory
Summary and Goal Tracking Form to monitor progress towards the GHG
emissions reduction goal. Finally, EPA may collect other program
information on a periodic basis or as the information is submitted;
these items include notification of changes such as company
representative, address, or Web Profile information.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)	Estimating Respondent Hour

	In order to obtain an accurate cost estimate, EPA consulted with and
obtained

burden estimates   SEQ CHAPTER \h \r 1 from three Partners (respondents)
from the Climate Leaders Partnership.

6(b)	Estimating Respondent Costs

In order to obtain an accurate cost estimate, EPA consulted with three
Partners (respondents) from the Climate Leaders Partnership on hourly
wage rates for each type of labor. EPA presented these Partners with
hourly wage rates from the previous ICR and asked them if these rates
were still appropriate, and if not, to include an estimate of a revised
hourly rate. 

(i)	Labor Costs

For purposes of this analysis, EPA estimates an average hourly
respondent labor cost

(including fringe and overhead) of $109 for legal staff, $98 for
managerial staff, $94 for

technical staff, and $47 for clerical staff. 

(ii)	Capital Costs

Capital costs usually include any produced physical 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 ICR.

(iii)	Operations 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, a $3
operations costs for submitting each Partnership Agreement via mail or
facsimile is included in the burden estimate.

6(c)	Estimating Agency Hour and Cost Burden

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
$83.16 for legal staff, $83.16 for managerial staff, $44.39 for
technical staff, and $20.20 for clerical staff. To derive these hourly
estimates, EPA used the “2008 GS Salary Table of Annual Rates by Grade
and Step,” from the Department of Personnel Management. For purposes
of this ICR, EPA assigned staff the following 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 hourly labor rate of $147.00 (including
overhead) for technical labor from EPA contractor staff. To derive these
hourly estimates, EPA examined the technical work performed by
contractors and estimated an hourly rate for GHG inventory assistance
activities based on an average of the fully loaded labor rates from the
contractor invoices on the current Climate Leaders contract.

6(d) 	Estimating the Respondent Universe and Total Hour and Cost Burden

(1)	Respondent Universe

  SEQ CHAPTER \h \r 1 Table 1 presents the number of companies expected
to participate in the program over the three-year period of this ICR. At
the beginning of 2008, EPA had 155 enrolled Partners.  For purposes of
the ICR’s burden calculations, EPA has averaged the number of new and
existing Partners over the three-year period, to conclude that there
will be, on average, 35 new Partners per year for each of the three
years of this ICR.  We anticipate that this will result in a total
enrollment 260 Partners by the end ICR year three. EPA derived these
universel estimates based on Partner growth in recent years, and Climate
Leader program goals. 

Table 1:  Number of Respondents Expected to Participate in the Climate
Leaders Partnership Over the Three-Year Period of the ICR

Type of Respondent	Year 1

(2008)	Year 2

(2009)	Year 3

(2010`)	Average

Existing (at beginning of year)	155	190	225	190

New (during year)	35	35	35	35

Existing (at end of year)	190	225	260	225



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 ICR 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)	Partnership Agreement. Corporations wanting to become Partners of
the Climate Leaders Partnership Priorities program are required to
complete and submit to EPA a Partnership Agreement. EPA estimates that,
on average, 35 new organizations per year become Partners and will
conduct this activity.				

(ii)	Inventory Management Plan (IMP).  Partners will review the
Inventory Management Plan checklist and example Inventory Management
Plans before drafting a corporate wide Inventory Management Plan. Each
Partner will draft and submit to EPA an Inventory Management Plan within
the first year of joining the Partnership. EPA will review and provide
comments to the Partner on each Inventory Management Plan, and the
Partner will make needed corrections before a final Inventory Management
Plan is approved. As part of the Inventory Management Plan review
process, Partners will prepare for and participate in a one day on-site
Inventory Management Plan review with EPA.  Based on the projected
number of new Partner organizations, EPA estimates that, on average, 35
Partners will complete a base year inventory each year.	

In lieu of developing an Inventory Management Plan and going through the
Inventory Management Plan review process and on-site visit, a Partner
may opt to have a third party verify that their Inventory Management
Plan meets the requirements of the Climate Leaders GHG inventory review.
 The third party verifier would provide a verification letter to EPA
certifying that these requirements have been met. Given the costs of a
third party review, this option is mostly reserved for Partners that are
participating in other GHG reduction programs that require a third party
review. EPA estimates that one new Partner per year over the next three
year period will choose to use a third party verifier.

(iii)	Annual GHG Inventory and Goal Tracking Form (Base Year). After
completing its Inventory Management Plan, Partners must calculate and
summarize their corporate-wide base year emissions on the Annual GHG
Inventory Summary and Goal Tracking Form. EPA has provided detailed
instructions and has allocated technical support hours to assist
Partners in completing this form. Based on the projected number of new
Partner organizations, EPA estimates that, on average, 35 new Partners
will complete a base year inventory each year.	

(iv)	GHG Emissions Reduction Goal Setting. After successfully completing
the base year inventory, Partners must work with EPA to set an
aggressive GHG emissions reduction goal. Partners must select the
timeframe to reach the goal between five and 10 years from the base year
reporting, as well as the format of the goal as either an absolute GHG
reduction or as a decrease in GHG intensity. Once this goal is approved
or negotiated with EPA, the Partner must enter this goal on its Annual
GHG Inventory and Goal Tracking Form. Based on the projected number of
new Partner organizations, EPA estimates that, on average, 35 new
Partners will establish a GHG emission reduction goal each year. 

(v)	Annual GHG Inventory and Goal Tracking Form (Subsequent Year). For
each year subsequent to the base year reporting, Partners will receive a
pre-populated Annual GHG Inventory and Goal Tracking Form from EPA.
Partners must update this form with the current year inventory reporting
and make any corrections to the contact information or revised goal or
base year information. EPA estimates that only those Partners who have
completed all the one-time will be responsible for updating the annual
GHG Inventory and Goal Tracking Form. Based on the projected number
Partners, EPA estimates that, on average, 190 Partners will make updates
to their subsequent year inventories each year.

(vi)	Web Profile. After a Partner has completed its base year inventory
and GHG emissions reduction goal, the Partner will complete a Web
Profile form to help publicize its commitment to reducing emissions of
GHGs. This Web Profile is a one-time burden and EPA expects that, on
average, 35 new Partners will submit a Web profile to EPA each year.

(vii)	Miscellaneous Activities. As needed, Partners may submit updated
contact information or updates to the Web profile. These updates would
notify EPA of a change such as a new Partner representative, address
change, or update to Web profile information. EPA estimates that
approximately 10 percent of Partners, or on average 20 Partners, will
submit this update each year.

  SEQ CHAPTER \h \r 1 6(e)	Bottom Line Hour and Cost Burden 

(1)	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 19,636 hours and $1,847,721.

(2)	Agency Tally

As is shown in Exhibit 2, the annual Agency hour and cost burden
associated with all the requirements covered in this ICR is estimated to
be 10,184 hours and $1,008,190. 

6(f)	Reasons for Change in Burden

	The previously approved ICR, ICR Number 2100.02, estimated the annual
hourly burden for respondents to be 11,955 and the annual cost for
respondents to be $878,176. This renewal estimates the annual hourly
burden for respondents to be 19,636 hours and the annual cost for
respondents to be $1,847,721. 

	This is a difference of 7,681 hours. There are several reasons for the
increase in burden. First, the program has continued to grow since its
inception; the original ICR had an average respondent base of 70
Partners over the 3-year ICR reporting period, compared to an average of
225 Partners reflected in this renewal ICR. Second, as a result of both
an adjustment in the types of corporations joining the Partnership and
program changes made to the reporting mechanisms, the size and scope of
some of the Partner inventories and their associated Inventory
Management Plans and Goal-setting processes are more complex and
detailed in order to best suit the corporation’s structure. The
Partner consultations used in the revised ICR were able to gauge input
from larger companies with more complex inventories that were not
completed during the initial ICR. As a result, the initial ICR may have
underestimated the burden. Third, as a result of discussions with
corporate Partners, a program change modified several mechanisms of
reporting including the types of inventory reporting forms and the
process for outlining an Inventory Management Plan. Although these
changes incur a higher burden up front, it is expected that these
changes make a GHG inventory and emissions reduction goal more useful to
the Partners and EPA. Climate Leaders Partners expect the modified
reporting forms to reduce burden substantially in subsequent year
inventories. 

	The annualized costs were overestimated in the original ICR and have
been adjusted in this renewal.  Since the inception of the Climate
Leaders Partnership, it was found that the capital cost of the filing
cabinet line item was not an accurate cost of the program, and it was
removed from this renewal ICR.  The only remaining annual cost is $3 for
each Partnership Agreement submitted by mail or facsimile, a total of
$105 for an estimated 35 new respondents per year.     

The burden outlined below for the information collection envisioned
under this ICR is necessary to help EPA determine that the Partners
merit recognition as corporate leaders in GHG reduction and to 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 opportunities that
result in savings to the company through, for example, enhanced energy
efficiency or revenue from other GHG emissions reduction trading
programs.

6(g)	Burden Statement

	Burden Statement:  The annual public reporting and recordkeeping burden
for this collection of information is estimated to be 87 hours per year
per respondent. 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 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 docket for this ICR under Docket ID No.
EPA-HQ-OAR-2002-0094, which is available for online viewing at
www.regulations.gov, or in person viewing at the Air and Radiation
Docket in the EPA Docket Center (EPA/DC), EPA West Building, Room 3334,
1301 Constitution Ave., NW, Washington, DC. The EPA/DC Public Reading
Room is open from 8 a.m. to 4:30 p.m., Monday through Friday, excluding
legal holidays. The telephone number for the Reading Room is
202-566-1744, and the telephone number for the Air and Radiation Docket
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
electronically. When 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.
EPA-HQ-OAR-2002-0094 and OMB Control Number 2060-0532 in any
correspondence.  

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