SUPPORTING
STATEMENT
FOR
LANDFILL
METHANE
OUTREACH
PROGRAM,

EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
1849.02
October
17,
2003
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
This
renewal
information
collection
is
entitled
"
The
Landfill
Methane
Outreach
Program",

ICR
number
1849.02.

1(
b)
Short
Characterization/
Abstract
The
Landfill
Methane
Outreach
Program
(
LMOP),
created
by
EPA
as
part
of
the
Climate
Change
Action
Plan,
is
a
voluntary
program
designed
to
encourage
and
facilitate
the
development
of
environmentally
and
economically
sound
landfill
gas
energy
(
LFGE)
projects
across
the
United
States.
LMOP
does
this
by
educating
local
governments
and
communities
about
the
benefits
of
landfill
gas
recovery
and
building
partnerships
between
state
agencies,
industry,
energy
service
providers,
local
communities,
and
other
stakeholders
interested
in
developing
this
valuable
resource
in
their
community.
To
continue
to
be
successful,
it
is
critical
that
LMOP
gather
information
from
its
partners
about
their
activities
and
how
the
program
can
improve
its
support
to
them.

Partners
are
entities
that
have
volunteered
to
participate
in
LMOP.
The
EPA
has
identified
four
categories
of
partners:

°
community
partners;

°
State
partners;

°
industry
partners
(
developers
and
non­
developers);
and
°
energy
partners.

Community
partners
are
local
agencies
or
municipalities
that
own
landfills.
State
partners
represent
State
agencies
involved
with
energy,
air
quality,
and
solid
waste
management
activities.

Industry
partners
are
further
divided
into
two
groups:
(
1)
developers
are
organizations
that
facilitate,
finance,
and
implement
LFGE
projects;
(
2)
non­
developers
are
manufacturers
and
suppliers
of
equipment
and
expertise
needed
to
collect
and
utilize
landfill
gas.
Energy
partners
include
utilities,
power
marketers,
and
the
end
users
of
energy
produced
from
landfill
gas.

There
are
three
mechanisms
for
collecting
information
from
the
partners:

°
memoranda
of
understanding
(
MOU);

°
information
forms;
and
°
periodic
information
updates.
2
The
MOU
are
completed
when
communities,
States,
and
other
organizations
become
partners.
The
MOU
are
a
one­
time
information
collection.
The
MOU
request
basic
information
(
for
example:
name,
address,
phone
number)
as
well
as
identification
of
contacts
and
experts
on
various
aspects
of
landfill
gas
recovery
and
use.
The
MOU
also
outline
the
responsibilities
of
the
partner
and
LMOP.
As
of
January
2004,
electronic
versions
of
the
MOU
will
be
available
on
the
LMOP
Web
site
that
will
allow
for
electronic
signature
and
submittal.

The
information
forms
request
more
detailed
information
and
vary
according
to
the
type
of
partner.
Under
the
previous
information
collection,
the
forms
were
completed
by
all
existing
partners
one
time.
The
forms
will
be
completed
by
new
partners
as
they
join
LMOP.
The
forms
will
be
updated
annually
by
partners
directly
involved
in
LFGE
projects.
This
includes
developers
(
a
subgroup
of
industry
partners),
energy
partners,
and
community
partners.

Periodic
information
updates
may
also
occur
to
obtain
general
information
(
company
and
contact
information)
from
partners.
Partners
may
initiate
the
update,
through
phone
calls
or
the
LMOP
Web
site,
when
they
become
aware
of
new
information
or
revisions
to
information
that
was
previously
provided
to
EPA.
The
EPA
may
also
request
updated
information
through
phone
calls
when
they
become
aware
of
outdated
or
new
information.

The
information
will
be
gathered
from
the
partners
through
forms
that
can
be
submitted
electronically
on
LMOP's
Web
site,
faxed,
or
mailed
to
the
EPA.
Information
will
be
updated
through
forms
or
telephone
calls.
The
EPA
will
use
the
information
provided
by
the
partners
to
track
the
progress
and
success
of
existing
LFGE
projects,
identify
opportunities
for
new
LFGE
projects
and
facilitate
the
implementation
of
these
projects,
and
identify
services
and
information
that
LMOP
could
provide
to
better
assist
the
partners
in
their
efforts.

The
LMOP
information
collection
in
the
first
year
is
expected
to
involve
249
existing
partners
and
an
additional
40
new
partners
per
year.
The
average
number
of
respondents
per
year
over
three
years
is
315.
The
average
annual
hours
(
rounded
to
one
decimal
place)
and
cost
per
respondents
is
estimated
to
be
4.9
hours
and
$
284.
The
total
annual
reporting
and
recordkeeping
burden
averaged
over
three
years
is
1,533
hours
and
$
89,630.

2.
NEED
FOR
AND
USE
OF
THIS
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
The
EPA
needs
to
collect
the
information
in
the
MOU
to
formally
establish
participation
in
LMOP
and
to
obtain
general
information
about
new
partners.
Additional
information
collected
3
through
information
forms
is
needed
to
allow
EPA
to
track,
facilitate,
and
encourage
the
implementation
of
LFGE
projects.
This
information
collection
will
assist
LMOP
in
decreasing
methane
emissions
from
landfills,
increasing
the
use
of
methane
as
a
renewable
energy
source,
and
reducing
emissions
due
to
the
burning
of
non­
renewable
energy
sources
such
as
coal
and
fuel
oil.

Participation
in
LMOP
is
voluntary.
As
described
in
Section
1(
b),
the
four
categories
of
participants
are:

°
community
partners.

°
State
partners;

°
industry
partners
(
developers
and
non­
developers);
and
°
energy
partners.

All
partners,
in
completing
the
MOU,
agree
to
provide
EPA
with
information
requested
in
the
forms
and
provide
contact
information
for
their
LMOP
coordinator.
Additionally,
non­
developer
industry
partners
agree
to
provide
a
description
of
their
products
and
services
and
contact
information
for
people
in
their
organization
with
expertise
in
landfill
gas
recovery
and
use.

Developer
industry
partners
and
energy
partners
agree
to
provide
information
on
LFGE
projects
with
which
they
have
been
involved.
Community
partners
agree
to
provide
information
on
the
progress
of
implementing
LFGE
projects
at
their
landfill(
s).

2(
b)
Practical
Utility/
Users
of
the
Data
The
EPA
uses
information
submitted
in
the
MOU
to
update
its
database
of
LMOP
partners.
The
database
serves
as
a
source
of
general
information
and
a
mailing
list.
The
EPA
uses
information
submitted
in
additional
forms
to
monitor
the
progress
of
LFGE
projects
and
identify
opportunities
for
new
projects.
The
EPA
also
uses
the
data
to
prepare
reports
on
LFGE
projects
and
the
progress
of
LMOP.
EPA
uses
case
studies
of
successful
LFGE
projects
to
demonstrate
to
existing
and
potential
partners
the
cost
savings
and
environmental
benefits
associated
with
capturing
and
using
landfill
gas.
General
information
on
the
partners
and
LFGE
projects
is
also
provided
on
the
LMOP
Web
site,
making
it
available
to
other
LMOP
partners
as
well
as
the
public.
4
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
For
new
partners,
the
information
to
be
collected
has
not
previously
been
collected
by
EPA
or
any
other
Federal
Agency.
Existing
partners
that
do
not
have
LFGE
projects
(
i.
e.,

industry
non­
developer
partners
and
State
partners)
will
not
be
requested
to
complete
annual
information
forms.
For
existing
partners
with
LFGE
projects,
some
of
the
information
required
may
be
available
in
the
existing
LMOP
database.
To
avoid
requesting
information
that
has
already
been
collected,
forms
sent
to
existing
partners
will
be
filled­
in
with
information
from
the
database
or
the
information
available
in
the
database
will
be
included
as
a
separate
attachment.

Recipients
of
the
forms
will
be
asked
to
review
the
information
provided.
Only
if
the
information
is
incorrect
or
out
of
date
will
the
recipients
be
required
to
provide
updated
or
additional
information.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
Paperwork
Reduction
Act
of
1995,
EPA
solicited
public
comments
on
the
ICR
through
an
announcement
in
the
Federal
Register
on
June
18,
2003
(
68
FR
36546).

Three
comments
were
received
and
addressed
by
EPA.
Two
of
the
comments
expressed
support
for
the
proposed
ICR
1849.02
and
warranted
no
further
comment
by
EPA.
The
third
comment
expressed
support
for
the
"...
urgent
need
to
collect
essential
data
about
whether
gas
management
at
landfills
with
active
gas
recovery
systems
that
utilize
the
methane
for
energy
production
are
managed
significantly
less
efficiently
than
those
with
active
collection
systems
that
do
not
include
energy
generation."
Furthermore,
the
commentary
"...
urges
EPA
to
include
a
table
in
the
questions
asked
of
LMOP
landfills
to
develop
a
data
base
to
begin
to
assess
the
magnitude
of
this
problem."
EPA
appreciates
the
concerns
raised
and
attentive
recommendations
included
in
the
comments.

The
recommended
inclusion
of
a
table
of
new
data
collection
under
this
ICR
falls
outside
the
scope
and
intent
of
EPA
LMOP's
data
collection
efforts.
In
general,
EPA
uses
information
submitted
in
the
information
collection
forms
to
monitor
the
progress
of
LFGE
projects
and
identify
opportunities
for
new
projects.
The
EPA
also
uses
the
data
to
prepare
reports
on
LFGE
projects
and
the
progress
of
LMOP.
The
recommended
table
would
track
percent
of
maximum
5
negative
pressure
for
each
well
at
a
landfill
(
typically
several
wells
to
several
hundred
wells)
on
a
daily
basis.
Collection
of
this
data
represents
excessive
burden
placed
on
LMOP
partners.

3(
c)
Consultations
No
additional
consultations
with
persons
outside
of
the
EPA
have
occurred
since
the
original
ICR
was
developed
and
approved
in
2000.
In
2000,
the
EPA
consulted
with
less
than
nine
partners
regarding
the
burden
of
this
information
collection.
LMOP
liaisons
with
the
following
partners
were
contacted:

Category
Contact
Phone
Number
Community
Partner
Jim
Mikolaitis
City
of
Tucson,
Arizona,
Department
of
Solid
Waste
Management
520­
791­
3175
Industry
Partner,
developer
Cindy
McCoy,
President
Natural
Power
company
919­
876­
6722
Energy
Partner,
utility
Kevin
Watkins,
Vice
President,
Engineering
Pacific
Northwest
Generating
Cooperative
503­
288­
1234
Energy
Partner,
end
user
Gary
Faw,
Facilities
Manager
Ajinimoto
USA,
Inc.
919­
231­
0100
State
Partner
Alexander
DePillis,
Renewable
Energy
Engineer
Wisconsin
Energy
Bureau
608­
266­
1067
The
partners
contacted
in
2000
were
provided
copies
of
the
information
collection
forms
to
be
used
and
an
initial
estimate
of
the
associated
burden,
including
estimated
labor
rates.
The
partners
were
asked
to
comment
on
the
accuracy
of
the
burden
estimates.
Generally,
the
contacts
agreed
with
the
estimates.
The
State
partner
and
community
partner
commented
that
the
labor
rates
seemed
high.
Originally,
the
same
labor
rates
were
being
used
for
both
public­
and
privatesector
employees.
The
rates
for
public
sector
employees
were
revised,
using
the
same
rates
used
for
EPA
employees,
which
are
comparable
to
rates
suggested
by
the
community
partner.
The
estimated
technical
hours
required
to
complete
an
information
form
were
reduced
based
on
the
suggestion
of
the
State
partner.
Hours
to
complete
the
MOU
were
allocated
to
technical
as
well
as
managerial
staff
at
the
suggestion
of
the
energy
partner.

3(
d)
Effects
of
Less
Frequent
Collection
The
MOU
are
submitted
once
by
organizations
that
choose
to
become
partners
of
LMOP.

For
non­
developer
industry
and
State
partners,
the
information
forms
are
also
submitted
only
6
once.
To
allow
EPA
to
remain
current
on
LFGE
projects,
partners
directly
involved
in
projects
will
be
asked
to
update
the
information
forms
annually.
Partners
may
also
update
company
and
contact
information
periodically.
The
EPA
believes
that
any
reduction
in
the
frequency
of
this
information
collection
would
impede
efforts
by
EPA
to
evaluate
results
of
the
program,
facilitate
LFGE
project
implementation,
and
respond
in
a
timely
manner
to
needs
of
the
partners.

3(
e)
General
Guidelines
This
information
collection
request
was
prepared
in
compliance
with
OMB's
and
EPA's
guidelines
for
ICR
preparation.

3(
f)
Confidentiality
Participation
in
LMOP
is
voluntary.
Participants
are
not
required
to
reveal
confidential
business
information.
Additionally,
participants
will
be
given
specific
instructions
not
to
provide
any
information
that
they
consider
confidential.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
asked
in
the
MOU,
information
forms,
or
periodic
information
updates.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondent
NAICS/
SIC
Codes
This
information
collection
will
encompass
a
wide
variety
of
respondents.
Community
partners
include
local
agencies
and
municipalities
that
own
landfills.
State
agencies
involved
in
energy,
air
pollution,
and
solid
waste
management
are
represented
through
State
partners.

Industry
partners
include
manufacturers
and
suppliers
of
equipment
and
knowledge
needed
to
capture
and
utilize
landfill
gas.
This
includes
engine
and
turbine
manufacturers,
engineering
firms,

construction
companies,
and
environmental
consultants.
Industry
partners
also
include
companies
involved
in
the
logistics
of
developing
LFGE
projects
such
as
law
firms
and
financing
companies.

Energy
partners
include
utility
companies
who
purchase
the
energy
generated
from
the
landfills,

power
marketers,
and
the
end
users
of
energy
from
the
landfill.
The
end
user
is
potentially
the
most
diverse
category.
Any
facility
located
near
a
landfill
that
utilizes
fuel
either
in
manufacturing
products
or
heating
the
facility
is
a
potential
energy
end
user.
Table
1
provides
the
North
American
Industrial
Classification
Standard
(
NAICS)
code
and
description
as
well
as
the
Standard
Industrial
Classification
(
SIC)
code
for
respondents
to
the
information
collection.
7
4(
b)
Information
Requested
(
i)
Data
Items,
Including
Recordkeeping
Requirements
Information
will
be
collected
in
MOU,
information
forms,
and
through
periodic
updates.

The
MOU
request
the
following
information
from
all
partners:

°
Name
of
the
organization;

°
Signature,
including
electronic
signature,
of
authorized
representative
with
authorized
representative's
printed
name
and
the
date
of
the
signature;

°
Information
about
the
LMOP
coordinator
including
name,
title,
address,
phone
number,
fax
number,
and
email
address;

°
Organization's
Web
site
address;
and
°
A
camera­
ready
copy
of
organization's
logo
or
seal.

Non­
developer
industry
partners
are
also
asked
to
provide
information
on
LMOP
experts
including:
name,
title,
address,
phone
number,
fax
number,
email
address,
and
area
of
expertise.

The
information
to
be
collected
through
the
information
forms
varies
according
to
the
type
of
partner.
The
information
to
be
collected
through
periodic
updates
will
mainly
be
changes
to
contact
information
for
LMOP
coordinators
and
experts.

Participation
in
LMOP
does
not
require
any
records
to
be
kept,
although
partners
will
likely
keep
file
copies
of
MOU
and
information
forms
submitted
to
EPA.

(
ii)
Respondent
Activities
The
respondent
activities
depend
on
the
aspect
of
the
information
collection
to
which
they
are
responding.
In
completing
the
MOU,
respondents
will:

°
review
the
form;

°
complete
the
form
on­
line;

°
sign
and
submit
the
form
electronically
to
EPA;
and
°
file
a
copy
of
the
form.

In
completing
the
information
forms,
respondents
will:

°
read
the
forms
and
instructions;

°
gather
information;

°
complete
the
form
on­
line;
8
°
submit
the
form
electronically
to
EPA;
and
°
file
a
copy
of
the
form.

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

°
gather
information;
and
°
provide
information
via
the
LMOP
Web
site
or
telephone
interview.

5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
Agency
activities
associated
with
this
information
collection
depend
on
the
aspect
of
the
information
collection
that
the
agency
has
received.
In
receiving
the
MOU,
the
agency
will:

°
review
the
information
provided;

°
sign
the
form;

°
return
a
copy
of
the
signed
form
to
the
partner;

°
enter
the
information
into
a
database;
and
°
file
the
form.

In
requesting
and
receiving
information
through
an
information
form,
the
agency
will:

°
prepare
and
send
out
the
form;

°
review
the
information
provided
and
follow
up
if
necessary;

°
enter
information
into
a
database;
and
°
file
the
form
received.

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

°
review
the
data;
and
°
revise
data
in
the
database
based
on
the
updates.

In
initiating
an
information
update,
the
agency
will:

°
call
or
email
partner;

°
request
updated
information;
and
°
revise
data
in
the
database
based
on
the
updates.

5(
b)
Collection
Methodology
and
Management
The
methods
selected
for
this
information
collection
are
chosen
based
on
efficiency
and
minimization
of
burden
for
respondents
and
EPA.
The
MOU
can
be
downloaded
from
the
LMOP
Web
site
and
returned
to
EPA
either
by
fax
or
mail,
or
submitted
electronically.
General
partner
9
information
will
be
posted
on
the
LMOP
Web
site
where
it
can
be
reviewed
for
accuracy
by
the
partners
and
revised
if
necessary.
Information
forms
will
be
available
for
partners
electronically
on
LMOP's
Web
site.
In
addition,
information
forms
will
be
mailed
to
partners
who
do
not
have
access
to
the
Web
site
or
partners
who
would
rather
fill
out
a
hard
copy
of
the
form.
Prior
to
being
sent
to
the
partner
or
put
on
the
Web
site,
the
information
forms
will
be
filled­
in
with
information
EPA
currently
has
regarding
the
partner
or
the
information
will
be
included
as
a
separate
attachment.
This
will
allow
the
partner
to
review
the
information
for
accuracy
as
well
as
minimizing
the
burden
of
the
respondents.
All
information
received
through
the
forms
(
electronically
or
via
hard
copy)
will
be
reviewed
by
EPA
before
being
entered
into
the
database.

5(
c)
Small
Entity
Flexibility
The
EPA
expects
that
some
LMOP
partners
are
small
entities.
EPA
has
designed
its
approach
for
this
information
collection
to
minimize
burden
for
all
respondents
while
obtaining
sufficient
and
accurate
information.
Since
the
previous
ICR,
we
have
simplified
the
MOU
and
information
forms
to
solicit
only
the
most
critical
information
and
have
added
the
option
for
electronic
submittal.
Additionally,
participation
in
LMOP
is
voluntary.
Any
small
entity
that
finds
the
information
collection
overly
burdensome
is
not
required
to
participate.

5(
d)
Collection
Schedule
The
EPA
will
collect
general
information
in
the
MOU,
which
are
completed
and
submitted
by
each
partner
upon
their
agreement
to
participate
in
the
program.
The
EPA
will
collect
additional
information
through
information
forms.
These
forms
will
be
completed
annually
for
partners
directly
involved
in
LFGE
projects
(
i.
e.,
industry
developer
partners,
energy
partners,
and
community
partners)
and
once
for
other
partners.
Information
may
also
be
updated
periodically
at
the
request
of
EPA
or
the
partner.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
In
order
to
obtain
accurate
hourly
burden
and
cost
estimates,
EPA
consulted
with
fewer
than
nine
partners
regarding
burden
and
cost
assumptions
in
2000.
For
this
renewal
ICR,
the
hourly
burden
estimates
for
industry
developer
partners,
energy
partners,
and
community
partners
were
decreased
because
the
information
forms
were
simplified.
Cost
estimates
were
increased
to
account
for
an
increase
in
wages
and
the
number
of
partners.
Attachment
A
presents
the
10
estimated
annual
respondent
burden
and
costs
for
information
collection
activities
associated
with
LMOP
for
each
year
of
the
collection.
Table
3
presents
a
summary
of
the
respondent
burden.

6(
b)
Estimating
Respondent
Costs
(
i)
Estimating
Labor
Costs
For
private­
sector
respondents
(
industry
and
energy
partners),
the
EPA
used
a
national
average
hourly
labor
rate
(
hourly
rate
plus
110%
overhead)
of
$
96.22
for
legal
staff,
$
93.09
for
managerial
staff,
$
64.13
for
technical
staff,
and
$
39.65
for
clerical
staff.
Managerial,
technical,

and
clerical
labor
rates
(
for
white
collar
occupations)
were
obtained
from
the
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
10.
Private
Industry,
by
Occupational
and
Industry
Group,"
for
June
2003.
Legal
labor
rates
for
2001
were
obtained
from
the
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
1.
National
employment
and
wage
data
from
the
Occupational
Employment
Statistics
survey
by
occupation,
2001."
A
June
2003
labor
rate
for
legal
staff
was
estimated
by
applying
a
consumer
price
index
growth
rate
(
from
Bureau
of
Labor
Statistics,
"
Consumer
Price
Index
­
All
Urban
Consumers")
to
the
2001
legal
labor
rate.
The
EPA
used
a
national
average
hourly
labor
rate
(
hourly
rate
plus
110%

overhead)
of
$
96.22
for
legal
staff.
Attachment
A
contains
further
details
about
estimating
labor
costs
for
respondents.

For
public­
sector
respondents
(
community
and
State
partners),
EPA
used
the
same
labor
rates
used
for
EPA
personnel
(
see
Section
6(
c)).
These
rates
are
comparable
to
rates
provided
by
a
community
partner
and
using
them
for
all
public­
sector
employees
provides
consistency.
Labor
rates
for
management
staff
of
public­
sector
respondents
were
used
to
represent
labor
rates
for
legal
staff
of
public­
sector
respondents.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
Because
this
information
collection
requires
respondents
only
to
report
information
that
is
already
available
to
them,
there
are
no
capital
costs.
The
EPA
does
not
expect
that
the
operations
and
maintenance
(
O&
M)
costs
of
this
program
will
be
significant.
The
only
O&
M
costs
expected
are
for
postage
required
to
mail
in
the
MOU
and
forms.
A
postage
cost
of
$
3.00
is
attributed
to
all
activities
involving
mailing
materials
to
account
for
the
use
of
trackable
mail.
The
average
annual
O&
M
cost
over
three
years
is
$
744.

6(
c)
Estimating
Agency
Burden
and
Costs
11
Attachment
B
presents
the
estimated
Agency
burden
hours
and
costs
for
the
information
collection
activities
associated
with
LMOP.
Table
4
presents
a
summary
of
the
agency
burden.

EPA
estimates
an
average
hourly
labor
cost
(
labor
plus
60%
for
overhead)
of
$
65.28
for
managerial
staff,
$
44.75
for
technical
staff,
and
$
17.97
for
clerical
staff.
To
derive
these
estimates,
EPA
used
the
"
Salary
Table
2003
­
GS"
from
the
Department
of
Personnel
Management.
For
purposes
of
this
ICR,
EPA
assigned
staff
the
following
government
service
levels:

°
Managerial
Staff
­
GS­
15,
Step
1
°
Technical
Staff
­
GS­
12,
Step
5
°
Clerical
Staff
­
GS­
5,
Step
1
Attachment
B
presents
further
details
about
estimating
agency
labor
costs.

6(
d)
Estimating
the
Respondent
Universe
Currently,
there
are
approximately
342
LMOP
partners.
However,
information
will
be
collected
from
only
249
of
these
respondents
initially,
because
existing
non­
developer
industry
and
State
partners
are
not
required
to
complete
annual
information
forms.
The
EPA
anticipates
that
an
average
of
40
new
partners
will
join
the
program
annually.
The
existing
number
of
respondents
for
each
year
is
based
on
all
existing
project
developer,
energy,
and
community
partners,
but
only
half
of
the
non­
developer
industry
and
State
partners.
Each
of
the
40
new
partners
(
all
types)
per
year
are
required
to
complete
the
annual
information
forms.
However,
in
subsequent
years
only
half
of
those
now­
existing
non­
developer
industry
and
State
partners
are
counted
in
the
respondent
universe,
as
only
half
are
assumed
to
voluntarily
update
their
contact
information
on
the
LMOP
Web
site.

The
average
annual
number
of
total
respondents
over
three
years
is
315.
The
number
of
respondents
in
each
of
the
three
years
of
this
information
collection
and
the
average
over
the
3­
year
period
are
shown
in
Table
2.

6(
e)
Bottom
Line
Burden
Hours
and
Costs
Tables3
and
4
show
the
total
annual
burden
and
cost
to
respondents
and
the
government,

respectively,
for
the
information
collection
activities
associated
with
LMOP.
Over
the
three
year
period
covered
by
this
ICR,
EPA
estimates
the
burden
of
the
program
to
be
4,598
hours
and
$
268,891
for
respondents,
and
2,934
hours
and
$
128,808
for
EPA.
The
total
annual
burden,

averaged
over
the
three­
year
period,
is
1,533
hours
and
$
89,630
for
respondents
and
978
hours
12
and
$
42,936
for
EPA.
The
bottom
line
burden
for
respondents
will
be
the
least
in
year
1
and
will
gradually
increase
in
years
2
and
3.
This
is
because
there
are
more
partners
responding
in
years
2
and
3.
The
burden
per
respondent
is
similar
in
all
3
years.
In
years
1,
2,
and
3,
new
partners
will
complete
MOU
and
information
forms.
In
years
1,
2,
and
3,
existing
partners
will
be
updating
information
only
as
needed.
Additionally,
for
those
partners
directly
involved
in
LFGE
projects,

EPA
will
provide
the
information
previously
submitted
and
only
ask
for
updates
and
new
project
information.
New
partners
will
have
to
provide
new
information
through
MOU
and
forms.
The
total
burden
and
cost
for
respondents
in
year
1
is
estimated
to
be
1,424
hours
and
$
83,275
and
the
average
is
4.9
hours
(
rounded
to
on
decimal
place)
and
$
288
per
respondent.
In
year
2,
the
total
burden
and
cost
is
estimated
to
be
1,534
hours
and
$
89,689,
and
the
average
is
4.9
hours
and
$
285
per
respondent.
In
year
3,
the
total
burden
and
cost
is
estimated
to
be
1,640
hours
and
$
95,927,
and
the
average
is
4.8
hours
and
$
280
per
respondent.
Overall,
the
average
respondent
burden
is
4.9
hours
per
year
(
rounded
to
one
decimal
place)
and
$
284
per
year.
Total
and
average
respondent
burden
and
cost
are
summarized
in
Table
3.

Similarly,
the
Agency
burden
is
the
least
in
year
1
and
will
gradually
increase
in
years
2
and
3.
In
year
1,
the
agency
burden
and
cost
is
estimated
to
be
912
hours
and
$
40,019.
In
year
2,

the
burden
is
978
hours
and
$
42,936.
In
year
3,
the
agency
burden
is
1,044
hours
and
$
45,853.

Agency
burden
and
cost
are
summarized
in
Table
4.

6(
f)
Reasons
for
Change
in
Burden
Under
this
renewal
ICR,
the
total
respondent
burden
over
the
three
year
period
is
4,598
hours,
or
an
average
of
1,533
per
year.
The
2000
ICR
total
burden
was
4,452
hours
or
an
average
of
1,484
per
year.
The
total
hourly
burden
increased
because
of
an
increase
in
the
number
of
partners,
even
though
the
industry
developer,
energy,
and
community
partner
information
forms
were
simplified.
The
total
cost
estimate
over
the
three
year
period
for
this
renewal
ICR
is
$
268,891,
as
compared
to
$
249,925
in
the
2000
ICR.
The
total
cost
estimate
increase
is
due
to
an
increase
in
the
number
of
partners
and
increases
in
wages.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
3.5
hours
per
response.
The
burden
estimate
includes
time
to
review,

complete,
sign,
and
submit
the
MOU.
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
13
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.

Overall,
the
average
respondent
burden
is
4.9
hours
per
year
and
$
284
per
year.
Over
the
three
year
period
covered
by
this
ICR,
EPA
estimates
the
burden
of
the
program
to
be
4,598
hours
and
$
268,891
for
respondents,
and
2,934
hours
and
$
128,808
for
EPA.

The
average
per
facility
reporting
burden
for
activities
associated
with
completing
the
MOU
is
estimated
to
be
1.8
hours.
The
burden
estimate
includes
time
to
review,
complete,
sign,

and
submit
the
MOU.

The
average
per
facility
reporting
burden
for
activities
associated
with
completing
the
information
forms
is
estimated
to
be
4.8
hours.
The
burden
ranges
from
2.25
hours
for
State
partners
to
18.5
hours
for
new
industry
partners
who
are
developers.
The
burden
estimate
includes
time
to
read
the
form
and
instructions,
gather
the
requested
information,
complete
the
form,
and
submit
the
form
to
EPA.
The
burden
for
each
type
of
partner
is
shown
in
Attachment
A
and
the
total
burden
is
summarized
in
Table
3.

The
average
per
facility
reporting
burden
for
activities
associated
with
periodic
information
updates
is
estimated
to
be
2.2
hours.
The
burden
estimate
includes
time
to
gather
the
requested
information
and
provide
the
information
to
EPA.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provided
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2003­
0078,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
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
14
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
and
Radiation
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
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
2003­
0078)
and
OMB
control
number
(
2060­
0446)
in
any
correspondence.
15
Table
1.
Respondents
to
Information
Collection
Partner
Type
NAICS
Code
NAICS
Description
SIC
Code
Community
and
State
Partners
924
Public
Administration,
Administration
of
Environmental
Quality
Programs
92411
Public
Administration,
Administration
of
Air
and
Water
Resource
and
Solid
Waste
Management
Programs
9511
92613
Public
Administration,
Regulation
and
Administration
of
Communications,
Electric,
Gas,
and
Other
Utilities
9631
Industry
Partners
333611
Turbine
and
turbine
generator
manufacturing
3511
333618
Other
Engine
Equipment
Manufacturing
3519
541330
Engineering
Services
8711
541620
Environmental
Consulting
Services
8999
234930
Industrial
Nonbuilding
Structure
Construction
1629
562212
Administrative
and
Support
and
Waste
Management
and
Remediation
Services,
Solid
Waste
Landfill
4953
541110
Offices
of
Lawyers
8111
522110
Commercial
Banking
6021,
6022,
6029
523910
Financial
Investments
and
Related
Activities,
Miscellaneous
Intermediation
6153,
6211,
6799
Energy
Partners
direct
usersa
611310
Colleges,
Universities
and
Professional
Schools
8221
325412
Pharmaceutical
Preparation
Manufacturing
2834
327121
Brick
and
Structural
Clay
Tile
Manufacturing
3251
327310
Cement
Manufacturing
3241
334210
Telephone
Apparatus
Manufacturing
3661
33422
Radio
and
Television
Broadcasting
and
Wireless
Communications
Equipment
Manufacturing
3663
336111
Automobile
Manufacturing
3711
325411
Medicinal
and
Botanical
Manufacturing
2833
331511
Iron
Foundries
3321
power
marketers
and
utilities
221121
Electric
Bulk
Power
Transmission
and
Control
4911,
4931,
4939
221122
Electric
Power
Distribution
221119
Other
Electric
Power
Generation
a
There
is
a
wide
variety
of
entities
that
could
become
direct
energy
users.
Any
facility
near
a
landfill
that
uses
fuel
is
a
potential
direct
user.
For
this
reason,
only
the
NAICS
codes
and
descriptions
of
the
current
direct
energy
users
are
included
in
Table
1.
16
Table
2.
Number
of
Respondents
Year
1
Year
2
Year
3
Averageb
Partner
Type
Existing
New
Existing
New
Existing
New
Existing
New
Industry
Developers
48
3
51
3
54
3
51
3
Non­
Developers
77
26
90
26
103
26
90
26
Energy
52
5
57
5
62
5
57
5
State
17
1
17
1
18
1
17
1
Community
55
5
60
5
65
5
60
5
TOTALa
249
40
275
40
302
40
275
40
a
Existing
non­
developer
industry
and
State
partners
are
not
expected
to
provide
information
for
new
projects
or
revise
information
for
existing
projects
(
only
new
non­
developer
industry
and
State
partners
are
required
to
fill
out
partner
profile
forms).
It
is
assumed
that
in
subsequent
years,
half
of
the
existing
non­
developer
industry
and
State
partners
will
voluntarily
update
their
contact
information
on
the
LMOP
Web
site.
Therefore,
the
total
number
of
respondents
in
the
existing
columns
for
years
2
and
3
are
not
the
previous
year's
existing
total
plus
40
new
partners,
but
rather,
include
only
half
of
the
non­
developer
industry
and
State
partners
from
the
previous
year.
See
tables
and
footnotes
in
Attachment
A
for
further
details.
b
Average
over
the
3­
year
period.
The
annual
average
number
of
respondents
is
275
existing
partners
and
40
new
partners,
or
315
total
respondents.
17
Table
3.
Summary
of
Respondent
Burdena
Year
1
Year
2
Year
3
Total
Averageb
Number
of
Respondents
Existing
249
275
302
­
275
New
40
40
40
­
40
Total
289
315
342
­
315
Hours
Industry
Project
Developers
434
458
480
1,372
457
Industry
Partners
(
Non­
Developers)
342
375
407
1,124
375
Energy
Partners
308
336
361
1,005
335
State
Partners
17
17
17
51
17
Community
Partners
323
348
375
1,046
349
Total
Hours
1,424
1,534
1,640
4,598
1,533
Average
hours
per
Respondent
4.9
4.9
4.8
­­
4.9
Cost
Industry
Project
Developers
$
27,357
$
28,907
$
30,297
$
86,561
$
28,854
Industry
Partners
(
Non­
Developers)
$
22,117
$
24,201
$
26,285
$
72,603
$
24,201
Energy
Partners
$
19,460
$
21,189
$
22,757
$
63,
406
$
21,135
State
Partners
$
720
$
720
$
753
$
2,193
$
731
Community
Partners
$
13,621
$
14,672
$
15,835
$
44,128
$
14,709
Total
Cost
$
83,275
$
89,689
$
95,927
$
268,891
$
89,630
Average
cost
per
Respondent
$
288
$
285
$
280
­­
$
284
a
The
hours
and
costs
for
each
type
of
partner
for
each
year
are
taken
from
the
detailed
tables
in
Attachment
A.
The
hours
and
costs
for
the
five
types
of
partners
are
summed
to
give
the
total
hours
and
costs
for
each
year.
The
average
hours
per
respondent
is
calculated
by
dividing
the
total
hours
by
the
number
of
respondents
and
rounding
to
one
decimal
place.
The
average
cost
per
respondent
is
calculated
by
dividing
the
total
cost
by
the
number
of
respondents
and
rounding
to
the
nearest
dollar.
b
Average
over
the
3­
year
period.

Table
4.
Summary
of
Agency
Burdena
Year
1
Year
2
Year
3
Totalb
Hours
912
978
1,044
2,934
Cost
$
40,019
$
42,936
$
45,853
$
128,808
a
The
hours
and
costs
are
taken
from
the
detailed
tables
in
Attachment
B.
b
The
overall
average
annual
agency
burden
over
the
3
year
period
is
978
hours
and
$
42,936
per
year.
Attachment
A
Estimate
of
Respondent
Burden
A­
1
Table
A­
1a.
Estimated
Respondent
Burden
And
Cost
For
Year
1
 
Industry
Project
Developers
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
96.22/

Hour
Mgr.

$
93.09/

Hour
Tech.

$
64.13/

Hour
Cler.

$
39.65/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.50
0.25
0.25
0.00
1.00
$
87
$
0
3
3
$
262
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
39
$
0
3
2
$
118
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
3
2
$
68
SUBTOTAL
6
$
449
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.50
0.00
0.50
$
32
$
0
51
26
$
1,635
Gather
information
­
new
developers4
0.00
0.00
7.00
0.00
7.00
$
449
$
0
3
21
$
1,347
Gather
information
­
existing
developers5
0.00
0.00
3.00
0.00
3.00
$
192
$
0
48
144
$
9,235
Complete
the
form
­
new
developers4
0.00
1.50
5.25
3.75
10.50
$
625
$
0
3
32
$
1,875
Complete
the
form
­
existing
developers5
0.00
0.50
1.50
0.50
2.50
$
163
$
0
48
120
$
7,803
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
51
26
$
1,164
SUBTOTAL
368
$
23,060
Information
Update6
Gather
Information
0.00
0.00
1.50
0.00
1.50
$
96
$
0
24
36
$
2,309
Provide
information
via
LMOP
Web
site
0.00
0.00
1.00
0.00
1.00
$
64
$
0
12
12
$
770
Provide
information
via
telephone
interview
0.00
0.00
1.00
0.00
1.00
$
64
$
0
12
12
$
770
SUBTOTAL
60
$
3,848
TOTAL
434
$
27,357
1
Source
for
managerial,
technical,
and
clerical
labor
rates:
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
10.
Private
Industry,
by
Occupational
and
Industry
Group,"
June
2003,

http://
www.
bls.
gov/
news.
release/
ecec.
t10.
htm.
Sources
for
legal
labor
rates:
1)
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
1.
National
employment
and
wage
data
from
the
Occupational
Employment
Statistics
survey
by
occupation,
2001."
http://
www.
bls.
gov/
news.
release/
ocwage.
t01.
htm.
2)
Bureau
of
Labor
Statistics,
"
Consumer
Price
Index­
All
Urban
Consumers."
http://
www.
bls.
gov/
data/
home.
htm.

A
June
2003
legal
labor
rate
was
estimated
by
applying
a
consumer
price
index
growth
rate
(
ratio
of
the
June
2003
consumer
price
index
to
the
2001
annual
average
consumer
price
index,
or
183.7/
177.1=
1.037)
to
the
2001
legal
labor
rate
in
Table
1.
All
labor
rates
incorporate
a
110%
factor
to
account
for
overhead
profit.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
1,
it
is
expected
that
3
new
industry
project
developers
will
join
LMOP.

3
In
year
1,
all
new
partners
must
submit
a
completed
information
form.
Additionally,
all
existing
project
developers
must
review
project
information
they
have
previously
provided
and
submit
any
corrections
and
complete
a
form
for
any
new
projects.
In
year
1,
there
are
an
estimated
3
new
industry
project
developers
and
48
existing
developers,
for
a
total
of
51
developers
that
will
complete
an
information
form.

4
The
information
form
must
be
filled
out
for
each
project.
The
hour
estimates
represent
an
average
burden
for
developers.
It
is
based
on
2
new
smaller
developers
with
1
project
and
1
new
larger
developer
with
an
average
of
17
projects.
Time
to
gather
information
is
2
hours
for
a
small
developer
and
17
hours
for
a
large
developer,
averaging
7
hours
per
developer.
Time
to
complete
the
forms
is
3
hours
for
a
small
developer
and
25.5
hours
for
a
large
developer,
averaging
10.5
hours
per
developer.

5
Project
developers
must
submit
updated
information
forms
annually.
In
year
1,
it
is
estimated
that
there
are
48
existing
project
developers.
Because
the
developers
have
already
filled
out
the
form
in
a
previous
year,
and
they
will
only
be
asked
to
review
information
on
existing
projects
and
provide
information
on
new
projects,
the
burden
will
be
significantly
less
than
that
for
new
developers.

6
It
is
assumed
that
in
year
1,
half
of
all
existing
project
developers
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
1,
there
are
an
estimated
48
existing
project
developer
partners.
It
is
assumed
24
will
provide
an
information
update,
12
through
the
web,
12
by
telephone.
A­
2
Table
A­
1b.
Estimated
Respondent
Burden
And
Cost
For
Year
1
 
Industry
Partners
(
Non­
Developers)

INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
96.22/

Hour
Mgr.

$
93.09/

Hour
Tech.

$
64.13/

Hour
Cler.

$
39.65/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.50
0.25
0.25
0.00
1.00
$
87
$
0
26
26
$
2,273
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
39
$
0
26
13
$
1,022
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
26
13
$
593
SUBTOTAL
52
$
3,888
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.50
0.00
0.50
$
32
$
0
26
13
$
834
Gather
information
0.00
0.00
1.00
0.00
1.00
$
64
$
0
26
26
$
1,667
Complete
the
form
0.00
0.25
1.00
0.50
1.75
$
107
$
0
26
46
$
2,788
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
26
13
$
593
SUBTOTAL
98
$
5,883
Information
Update4
Gather
Information
0.00
0.00
1.50
0.00
1.50
$
96
$
0
77
116
$
7,407
Provide
information
via
LMOP
Web
site
0.00
0.00
1.00
0.00
1.00
$
64
$
0
39
39
$
2,501
Provide
information
via
telephone
interview
0.00
0.00
1.00
0.00
1.00
$
64
$
0
38
38
$
2,437
SUBTOTAL
193
$
12,346
TOTAL
342
$
22,117
1
Source
for
managerial,
technical,
and
clerical
labor
rates:
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
10.
Private
Industry,
by
Occupational
and
Industry
Group,"
June
2003,

http://
www.
bls.
gov/
news.
release/
ecec.
t10.
htm.
Sources
for
legal
labor
rates:
1)
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
1.
National
employment
and
wage
data
from
the
Occupational
Employment
Statistics
survey
by
occupation,
2001."
http://
www.
bls.
gov/
news.
release/
ocwage.
t01.
htm.
2)
Bureau
of
Labor
Statistics,
"
Consumer
Price
Index­
All
Urban
Consumers."
http://
www.
bls.
gov/
data/
home.
htm.

A
June
2003
legal
labor
rate
was
estimated
by
applying
a
consumer
price
index
growth
rate
(
ratio
of
the
June
2003
consumer
price
index
to
the
2001
annual
average
consumer
price
index,
or
183.7/
177.1=
1.037)
to
the
2001
legal
labor
rate
in
Table
1.
All
labor
rates
incorporate
a
110%
factor
to
account
for
overhead
profit.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
1,
it
is
expected
that
26
new
industry
partners
(
non­
developers)
will
join
LMOP.

3
Non­
developer
industry
partners
are
not
expected
to
provide
information
for
new
projects
or
revise
information
on
existing
projects
as
they
are
not
directly
involved
in
LFGE
projects.
As
a
result,
in
year
1,
only
the
26
new
industry
partners
(
non­
developers)
will
be
required
to
submit
an
information
form.

4
It
is
assumed
that
in
year
1,
half
of
all
existing
non­
developers
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
1,
there
are
an
estimated
154
existing
non­
developer
industry
partners.
It
is
assumed
77
will
provide
an
information
update,
39
through
the
web,

38
by
telephone.
A­
3
Table
A­
1c.
Estimated
Respondent
Burden
And
Cost
For
Year
1
 
Energy
Partners
(
direct
users,
power
marketers,
utilities)

INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
96.22/

Hour
Mgr.

$
93.09/

Hour
Tech.

$
64.13/

Hour
Cler.

$
39.65/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.50
0.25
0.25
0.00
1.00
$
87
$
0
5
5
$
437
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
39
$
0
5
3
$
197
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
5
3
$
114
SUBTOTAL
10
$
748
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.50
0.00
0.50
$
32
$
0
57
29
$
1,828
Gather
information
­
new
partners
0.00
0.00
1.50
0.00
1.50
$
96
$
0
5
8
$
481
Gather
information
­
existing
partners
0.00
0.00
1.00
0.00
1.00
$
64
$
0
52
52
$
3,335
Complete
the
form
­
new
partners
0.00
0.50
1.50
0.50
2.50
$
163
$
0
5
13
$
813
Complete
the
form
­
existing
partners
0.00
0.50
1.00
0.50
2.00
$
131
$
0
52
104
$
6,786
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
57
29
$
1,301
SUBTOTAL
233
$
14,544
Information
Update4
Gather
Information
0.00
0.00
1.50
0.00
1.50
$
96
$
0
26
39
$
2,501
Provide
information
via
LMOP
Web
site
0.00
0.00
1.00
0.00
1.00
$
64
$
0
13
13
$
834
Provide
information
via
telephone
interview
0.00
0.00
1.00
0.00
1.00
$
64
$
0
13
13
$
834
SUBTOTAL
65
$
4,169
TOTAL
308
$
19,460
1
Source
for
managerial,
technical,
and
clerical
labor
rates:
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
10.
Private
Industry,
by
Occupational
and
Industry
Group,"
June
2003,

http://
www.
bls.
gov/
news.
release/
ecec.
t10.
htm.
Sources
for
legal
labor
rates:
1)
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
1.
National
employment
and
wage
data
from
the
Occupational
Employment
Statistics
survey
by
occupation,
2001."
http://
www.
bls.
gov/
news.
release/
ocwage.
t01.
htm.
2)
Bureau
of
Labor
Statistics,
"
Consumer
Price
Index­
All
Urban
Consumers."
http://
www.
bls.
gov/
data/
home.
htm.

A
June
2003
legal
labor
rate
was
estimated
by
applying
a
consumer
price
index
growth
rate
(
ratio
of
the
June
2003
consumer
price
index
to
the
2001
annual
average
consumer
price
index,
or
183.7/
177.1=
1.037)
to
the
2001
legal
labor
rate
in
Table
1.
All
labor
rates
incorporate
a
110%
factor
to
account
for
overhead
profit.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
1,
it
is
expected
that
5
new
energy
partners
will
join
LMOP.

3
In
year
1,
all
new
partners
must
submit
a
completed
information
form.
Additionally,
all
existing
energy
partners
must
review
project
information
they
have
previously
provided
and
submit
any
corrections
and
complete
a
form
for
any
new
projects.
In
year
1,
there
are
an
estimated
5
new
energy
partners
and
52
existing
energy
partners,
for
a
total
of
57
energy
partners
that
will
complete
an
information
form.

4
It
is
assumed
that
in
year
1,
half
of
all
existing
energy
partners
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
1,
there
are
an
estimated
52
existing
energy
partners.
It
is
assumed
26
will
provide
an
information
update,
13
through
the
web,
13
by
telephone.
A­
4
Table
A­
1d.
Estimated
Respondent
Burden
And
Cost
For
Year
1
 
State
Partners
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
65.28/

Hour
Mgr.

$
65.28/

Hour
Tech.

$
44.75/

Hour
Cler.

$
17.97/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.00
0.25
0.25
0.00
0.50
$
28
$
0
1
1
$
28
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
28
$
0
1
1
$
28
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
9
$
3
1
1
$
12
SUBTOTAL
2
$
67
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.25
0.00
0.25
$
11
$
0
1
0.3
$
11
Gather
information
0.00
0.00
0.50
0.00
0.50
$
22
$
0
1
1
$
22
Complete
the
form
0.00
0.25
0.25
0.50
1.00
$
36
$
0
1
1
$
36
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
9
$
3
1
1
$
12
SUBTOTAL
2
$
82
Information
Update4
Gather
Information
0.00
0.00
0.50
0.00
0.50
$
22
$
0
17
9
$
380
Provide
information
via
LMOP
Web
site
0.00
0.00
0.25
0.00
0.25
$
11
$
0
8
2
$
90
Provide
information
via
telephone
interview
0.00
0.00
0.25
0.00
0.25
$
11
$
0
9
2
$
101
SUBTOTAL
13
$
571
TOTAL
17
$
720
1
Labor
rates
for
EPA
personnel
were
used
for
all
public­
sector
personnel,
including
employees
of
State
agencies.
Source
for
EPA
labor
rates:
Department
of
Personnel
Management,
"
Salary
Table
2003
­
GS,"

http://
www.
opm.
gov/
oca/
03tables/
pdf/
gs_
h.
pdf.
For
the
managerial
and
legal
labor
rates,
level
GS­
15,
step
1
was
used,
for
the
technical
labor
rate,
level
GS­
12,
step
5
was
used,
for
the
clerical
labor
rate,
level
GS­
5,
step
1
was
used.
All
agency
labor
rates
include
a
multiplier
of
1.6
to
account
for
overhead
and
fringe
benefit
costs.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
1,
it
is
expected
that
1
new
State
partner
will
join
LMOP.

3
State
partners
are
not
expected
to
provide
information
for
new
projects
or
revise
information
on
existing
projects
as
they
are
not
directly
involved
in
LFGE
projects.
As
a
result,
in
year
1,
only
the
1
new
State
partner
will
be
required
to
submit
an
information
form.

4
It
is
assumed
that
in
year
1,
half
of
all
existing
State
partners
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
1,
there
are
an
estimated
33
existing
State
partners.
It
is
assumed
17
will
provide
an
information
update,
8
through
the
web,
9
by
telephone.
A­
5
Table
A­
1e.
Estimated
Respondent
Burden
And
Cost
For
Year
1
 
Community
Partners
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
65.28/

Hour
Mgr.

$
65.28/

Hour
Tech.

$
44.75/

Hour
Cler.

$
17.97/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.00
0.25
0.25
0.00
0.50
$
28
$
0
5
3
$
138
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
28
$
0
5
3
$
138
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
9
$
3
5
3
$
60
SUBTOTAL
8
$
335
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.50
0.00
0.50
$
22
$
0
60
30
$
1,343
Gather
information
­
new
partners
0.00
0.00
1.50
0.00
1.50
$
67
$
0
5
8
$
336
Gather
information
­
existing
partners
0.00
0.00
1.00
0.00
1.00
$
45
$
0
55
55
$
2,461
Complete
the
form
­
new
partners
0.00
0.50
1.50
0.50
2.50
$
109
$
0
5
13
$
544
Complete
the
form
­
existing
partners
0.00
0.50
1.00
0.50
2.00
$
86
$
0
55
110
$
4,751
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
9
$
3
60
30
$
719
SUBTOTAL
245
$
10,153
Information
Update4
Gather
Information
0.00
0.00
1.50
0.00
1.50
$
67
$
0
28
42
$
1,880
Provide
information
via
LMOP
Web
site
0.00
0.00
1.00
0.00
1.00
$
45
$
0
14
14
$
627
Provide
information
via
telephone
interview
0.00
0.00
1.00
0.00
1.00
$
45
$
0
14
14
$
627
SUBTOTAL
70
$
3,133
TOTAL
323
$
13,621
1
Labor
rates
for
EPA
personnel
were
used
for
all
public­
sector
personnel,
including
employees
of
local
communities.
Source
for
EPA
labor
rates:
Department
of
Personnel
Management,
"
Salary
Table
2003
­
GS,"

http://
www.
opm.
gov/
oca/
03tables/
pdf/
gs_
h.
pdf.
For
the
managerial
and
legal
labor
rates,
level
GS­
15,
step
1
was
used,
for
the
technical
labor
rate,
level
GS­
12,
step
5
was
used,
for
the
clerical
labor
rate,
level
GS­
5,
step
1
was
used.
All
agency
labor
rates
include
a
multiplier
of
1.6
to
account
for
overhead
and
fringe
benefit
costs.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
1,
it
is
expected
that
5
new
partners
will
join
LMOP.

3
In
year
1,
all
new
partners
must
submit
a
completed
information
form.
Additionally,
all
existing
partners
must
review
project
information
they
have
previously
provided
and
submit
any
corrections
and
complete
a
form
for
any
new
projects.
In
year
1,
there
are
an
estimated
5
new
partners
and
55
existing
partners,
for
a
total
of
60
partners
that
will
complete
an
information
form.

4
It
is
assumed
that
in
year
1,
half
of
all
existing
partners
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
1,
there
are
an
estimated
55
existing
partners.
It
is
assumed
28
will
provide
an
information
update,
14
through
the
web,
14
by
telephone.
A­
6
Table
A­
2a.
Estimated
Respondent
Burden
And
Cost
For
Year
2
 
Industry
Project
Developers
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
96.22/

Hour
Mgr.

$
93.09/

Hour
Tech.

$
64.13/

Hour
Cler.

$
39.65/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.50
0.25
0.25
0.00
1.00
$
87
$
0
3
3
$
262
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
39
$
0
3
2
$
118
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
3
2
$
68
SUBTOTAL
6
$
449
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.50
0.00
0.50
$
32
$
0
54
27
$
1,732
Gather
information
­
new
developers4
0.00
0.00
7.00
0.00
7.00
$
449
$
0
3
21
$
1,347
Gather
information
­
existing
developers5
0.00
0.00
3.00
0.00
3.00
$
192
$
0
51
153
$
9,813
Complete
the
form
­
new
developers4
0.00
1.50
5.25
3.75
10.50
$
625
$
0
3
32
$
1,875
Complete
the
form
­
existing
developers5
0.00
0.50
1.50
0.50
2.50
$
163
$
0
51
128
$
8,291
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
54
27
$
1,232
SUBTOTAL
387
$
24,290
Information
Update6
Gather
Information
0.00
0.00
1.50
0.00
1.50
$
96
$
0
26
39
$
2,501
Provide
information
via
LMOP
Web
site
0.00
0.00
1.00
0.00
1.00
$
64
$
0
13
13
$
834
Provide
information
via
telephone
interview
0.00
0.00
1.00
0.00
1.00
$
64
$
0
13
13
$
834
SUBTOTAL
65
$
4,169
TOTAL
458
$
28,907
1
Source
for
managerial,
technical,
and
clerical
labor
rates:
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
10.
Private
Industry,
by
Occupational
and
Industry
Group,"
June
2003,

http://
www.
bls.
gov/
news.
release/
ecec.
t10.
htm.
Sources
for
legal
labor
rates:
1)
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
1.
National
employment
and
wage
data
from
the
Occupational
Employment
Statistics
survey
by
occupation,
2001."
http://
www.
bls.
gov/
news.
release/
ocwage.
t01.
htm.
2)
Bureau
of
Labor
Statistics,
"
Consumer
Price
Index­
All
Urban
Consumers."
http://
www.
bls.
gov/
data/
home.
htm.

A
June
2003
legal
labor
rate
was
estimated
by
applying
a
consumer
price
index
growth
rate
(
ratio
of
the
June
2003
consumer
price
index
to
the
2001
annual
average
consumer
price
index,
or
183.7/
177.1=
1.037)
to
the
2001
legal
labor
rate
in
Table
1.
All
labor
rates
incorporate
a
110%
factor
to
account
for
overhead
profit.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
2,
it
is
expected
that
3
new
industry
project
developers
will
join
LMOP.

3
In
year
2,
all
new
partners
must
submit
a
completed
information
form.
Additionally,
all
existing
project
developers
must
review
project
information
they
have
previously
provided
and
submit
any
corrections
and
complete
a
form
for
any
new
projects.
In
year
2,
there
are
an
estimated
3
new
industry
project
developers
and
51
existing
developers,
for
a
total
of
54
developers
that
will
complete
an
information
form.

4
The
information
form
must
be
filled
out
for
each
project.
The
hour
estimates
represent
an
average
burden
for
developers.
It
is
based
on
2
new
smaller
developers
with
1
project
and
1
new
larger
developer
with
an
average
of
17
projects.
Time
to
gather
information
is
2
hours
for
a
small
developer
and
17
hours
for
a
large
developer,
averaging
7
hours
per
developer.
Time
to
complete
the
forms
is
3
hours
for
a
small
developer
and
25.5
hours
for
a
large
developer,
averaging
10.5
hours
per
developer.

5
Project
developers
must
submit
updated
information
forms
annually.
In
year
2,
it
is
estimated
that
there
are
51
existing
project
developers.
Because
the
developers
have
already
filled
out
the
form
in
a
previous
year,
and
they
will
only
be
asked
to
review
information
on
existing
projects
and
provide
information
on
new
projects,
the
burden
will
be
significantly
less
than
that
for
new
developers.

6
It
is
assumed
that
in
year
2,
half
of
all
existing
project
developers
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
2,
there
are
an
estimated
51
existing
project
developer
partners.
It
is
assumed
26
will
provide
an
information
update,
13
through
the
web,

13
by
telephone.
A­
7
Table
A­
2b.
Estimated
Respondent
Burden
And
Cost
For
Year
2
 
Industry
Partners
(
Non­
Developers)

INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
96.22/

Hour
Mgr.

$
93.09/

Hour
Tech.

$
64.13/

Hour
Cler.

$
39.65/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.50
0.25
0.25
0.00
1.00
$
87
$
0
26
26
$
2,273
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
39
$
0
26
13
$
1,022
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
26
13
$
593
SUBTOTAL
52
$
3,888
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.50
0.00
0.50
$
32
$
0
26
13
$
834
Gather
information
0.00
0.00
1.00
0.00
1.00
$
64
$
0
26
26
$
1,667
Complete
the
form
0.00
0.25
1.00
0.50
1.75
$
107
$
0
26
46
$
2,788
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
26
13
$
593
SUBTOTAL
98
$
5,883
Information
Update4
Gather
Information
0.00
0.00
1.50
0.00
1.50
$
96
$
0
90
135
$
8,658
Provide
information
via
LMOP
Web
site
0.00
0.00
1.00
0.00
1.00
$
64
$
0
45
45
$
2,886
Provide
information
via
telephone
interview
0.00
0.00
1.00
0.00
1.00
$
64
$
0
45
45
$
2,886
SUBTOTAL
225
$
14,430
TOTAL
375
$
24,201
1
Source
for
managerial,
technical,
and
clerical
labor
rates:
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
10.
Private
Industry,
by
Occupational
and
Industry
Group,"
June
2003,

http://
www.
bls.
gov/
news.
release/
ecec.
t10.
htm.
Sources
for
legal
labor
rates:
1)
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
1.
National
employment
and
wage
data
from
the
Occupational
Employment
Statistics
survey
by
occupation,
2001."
http://
www.
bls.
gov/
news.
release/
ocwage.
t01.
htm.
2)
Bureau
of
Labor
Statistics,
"
Consumer
Price
Index­
All
Urban
Consumers."
http://
www.
bls.
gov/
data/
home.
htm.

A
June
2003
legal
labor
rate
was
estimated
by
applying
a
consumer
price
index
growth
rate
(
ratio
of
the
June
2003
consumer
price
index
to
the
2001
annual
average
consumer
price
index,
or
183.7/
177.1=
1.037)
to
the
2001
legal
labor
rate
in
Table
1.
All
labor
rates
incorporate
a
110%
factor
to
account
for
overhead
profit.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
2,
it
is
expected
that
26
new
industry
partners
(
non­
developers)
will
join
LMOP.

3
Non­
developer
industry
partners
are
not
expected
to
provide
information
for
new
projects
or
revise
information
on
existing
projects
as
they
are
not
directly
involved
in
LFGE
projects.
As
a
result,
in
year
2,
only
the
26
new
industry
partners
(
non­
developers)
will
be
required
to
submit
an
information
form.

4
It
is
assumed
that
in
year
2,
half
of
all
existing
non­
developers
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
2,
there
are
an
estimated
180
existing
non­
developer
industry
partners.
It
is
assumed
90
will
provide
an
information
update,
45
through
the
web,

45
by
telephone.
A­
8
Table
A­
2c.
Estimated
Respondent
Burden
And
Cost
For
Year
2
 
Energy
Partners
(
direct
users,
power
marketers,
utilities)

INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
96.22/

Hour
Mgr.

$
93.09/

Hour
Tech.

$
64.13/

Hour
Cler.

$
39.65/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.50
0.25
0.25
0.00
1.00
$
87
$
0
5
5
$
437
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
39
$
0
5
3
$
197
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
5
3
$
114
SUBTOTAL
10
$
748
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.50
0.00
0.50
$
32
$
0
62
31
$
1,988
Gather
information
­
new
partners
0.00
0.00
1.50
0.00
1.50
$
96
$
0
5
8
$
481
Gather
information
­
existing
partners
0.00
0.00
1.00
0.00
1.00
$
64
$
0
57
57
$
3,656
Complete
the
form
­
new
partners
0.00
0.50
1.50
0.50
2.50
$
163
$
0
5
13
$
813
Complete
the
form
­
existing
partners
0.00
0.50
1.00
0.50
2.00
$
131
$
0
57
114
$
7,439
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
62
31
$
1,415
SUBTOTAL
253
$
15,791
Information
Update4
Gather
Information
0.00
0.00
1.50
0.00
1.50
$
96
$
0
29
44
$
2,790
Provide
information
via
LMOP
Web
site
0.00
0.00
1.00
0.00
1.00
$
64
$
0
15
15
$
962
Provide
information
via
telephone
interview
0.00
0.00
1.00
0.00
1.00
$
64
$
0
14
14
$
898
SUBTOTAL
73
$
4,650
TOTAL
336
$
21,189
1
Source
for
managerial,
technical,
and
clerical
labor
rates:
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
10.
Private
Industry,
by
Occupational
and
Industry
Group,"
June
2003,

http://
www.
bls.
gov/
news.
release/
ecec.
t10.
htm.
Sources
for
legal
labor
rates:
1)
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
1.
National
employment
and
wage
data
from
the
Occupational
Employment
Statistics
survey
by
occupation,
2001."
http://
www.
bls.
gov/
news.
release/
ocwage.
t01.
htm.
2)
Bureau
of
Labor
Statistics,
"
Consumer
Price
Index­
All
Urban
Consumers."
http://
www.
bls.
gov/
data/
home.
htm.

A
June
2003
legal
labor
rate
was
estimated
by
applying
a
consumer
price
index
growth
rate
(
ratio
of
the
June
2003
consumer
price
index
to
the
2001
annual
average
consumer
price
index,
or
183.7/
177.1=
1.037)
to
the
2001
legal
labor
rate
in
Table
1.
All
labor
rates
incorporate
a
110%
factor
to
account
for
overhead
profit.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
2,
it
is
expected
that
5
new
energy
partners
will
join
LMOP.

3
In
year
2,
all
new
partners
must
submit
a
completed
information
form.
Additionally,
all
existing
energy
partners
must
review
project
information
they
have
previously
provided
and
submit
any
corrections
and
complete
a
form
for
any
new
projects.
In
year
2,
there
are
an
estimated
5
new
energy
partners
and
57
existing
energy
partners,
for
a
total
of
62
energy
partners
that
will
complete
an
information
form.

4
It
is
assumed
that
in
year
2,
half
of
all
existing
energy
partners
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
2,
there
are
an
estimated
57
existing
energy
partners.
It
is
assumed
29
will
provide
an
information
update,
15
through
the
web,
14
by
telephone.
A­
9
Table
A­
2d.
Estimated
Respondent
Burden
And
Cost
For
Year
2
­
State
Partners
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
65.28/

Hour
Mgr.

$
65.28/

Hour
Tech.

$
44.75/

Hour
Cler.

$
17.97/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.00
0.25
0.25
0.00
0.50
$
28
$
0
1
1
$
27
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
28
$
0
1
1
$
27
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
9
$
3
1
1
$
12
SUBTOTAL
2
$
67
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.25
0.00
0.25
$
11
$
0
1
0.3
$
11
Gather
information
0.00
0.00
0.50
0.00
0.50
$
22
$
0
1
1
$
22
Complete
the
form
0.00
0.25
0.25
0.50
1.00
$
36
$
0
1
1
$
36
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
9
$
3
1
1
$
12
SUBTOTAL
2
$
82
Information
Update4
Gather
Information
0.00
0.00
0.50
0.00
0.50
$
22
$
0
17
9
$
380
Provide
information
via
LMOP
Web
site
0.00
0.00
0.25
0.00
0.25
$
11
$
0
8
2
$
90
Provide
information
via
telephone
interview
0.00
0.00
0.25
0.00
0.25
$
11
$
0
9
2
$
101
SUBTOTAL
13
$
571
TOTAL
17
$
720
1
Labor
rates
for
EPA
personnel
were
used
for
all
public­
sector
personnel,
including
employees
of
State
agencies.
Source
for
EPA
labor
rates:
Department
of
Personnel
Management,
"
Salary
Table
2003
­
GS,"

http://
www.
opm.
gov/
oca/
03tables/
pdf/
gs_
h.
pdf.
For
the
managerial
and
legal
labor
rates,
level
GS­
15,
step
1
was
used,
for
the
technical
labor
rate,
level
GS­
12,
step
5
was
used,
for
the
clerical
labor
rate,
level
GS­
5,
step
1
was
used.
All
agency
labor
rates
include
a
multiplier
of
1.6
to
account
for
overhead
and
fringe
benefit
costs.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
2,
it
is
expected
that
1
new
State
partner
will
join
LMOP.

3
State
partners
are
not
expected
to
provide
information
for
new
projects
or
revise
information
on
existing
projects
as
they
are
not
directly
involved
in
LFGE
projects.
As
a
result,
in
year
2,
only
the
1
new
State
partner
will
be
required
to
submit
an
information
form.

4
It
is
assumed
that
in
year
2,
half
of
all
existing
State
partners
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
2,
there
are
an
estimated
34
existing
State
partners.
It
is
assumed
17
will
provide
an
information
update,
8
through
the
web,
9
by
telephone.
A­
10
Table
A­
2e.
Estimated
Respondent
Burden
And
Cost
For
Year
2
 
Community
Partners
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
65.28/

Hour
Mgr.

$
65.28/

Hour
Tech.

$
44.75/

Hour
Cler.

$
17.97/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.00
0.25
0.25
0.00
0.50
$
28
$
0
5
3
$
138
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
28
$
0
5
3
$
138
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
9
$
3
5
3
$
60
SUBTOTAL
8
$
335
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.50
0.00
0.50
$
22
$
0
65
33
$
1,454
Gather
information
­
new
partners
0.00
0.00
1.50
0.00
1.50
$
67
$
0
5
8
$
336
Gather
information
­
existing
partners
0.00
0.00
1.00
0.00
1.00
$
45
$
0
60
60
$
2,685
Complete
the
form
­
new
partners
0.00
0.50
1.50
0.50
2.50
$
109
$
0
5
13
$
544
Complete
the
form
­
existing
partners
0.00
0.50
1.00
0.50
2.00
$
86
$
0
60
120
$
5,183
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
9
$
3
65
33
$
779
SUBTOTAL
265
$
10,980
Information
Update4
Gather
Information
0.00
0.00
1.50
0.00
1.50
$
67
$
0
30
45
$
2,014
Provide
information
via
LMOP
Web
site
0.00
0.00
1.00
0.00
1.00
$
45
$
0
15
15
$
671
Provide
information
via
telephone
interview
0.00
0.00
1.00
0.00
1.00
$
45
$
0
15
15
$
671
SUBTOTAL
75
$
3,356
TOTAL
348
$
14,672
1
Labor
rates
for
EPA
personnel
were
used
for
all
public­
sector
personnel,
including
employees
of
local
communities.
Source
for
EPA
labor
rates:
Department
of
Personnel
Management,
"
Salary
Table
2003
­
GS,"

http://
www.
opm.
gov/
oca/
03tables/
pdf/
gs_
h.
pdf.
For
the
managerial
and
legal
labor
rates,
level
GS­
15,
step
1
was
used,
for
the
technical
labor
rate,
level
GS­
12,
step
5
was
used,
for
the
clerical
labor
rate,
level
GS­
5,
step
1
was
used.
All
agency
labor
rates
include
a
multiplier
of
1.6
to
account
for
overhead
and
fringe
benefit
costs.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
2,
it
is
expected
that
5
new
partners
will
join
LMOP.

3
In
year
2,
all
new
partners
must
submit
a
completed
information
form.
Additionally,
all
existing
partners
must
review
project
information
they
have
previously
provided
and
submit
any
corrections
and
complete
a
form
for
any
new
projects.
In
year
2,
there
are
an
estimated
5
new
partners
and
60
existing
partners,
for
a
total
of
65
partners
that
will
complete
an
information
form.

4
It
is
assumed
that
in
year
2,
half
of
all
existing
partners
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
2,
there
are
an
estimated
60
existing
partners.
It
is
assumed
30
will
provide
an
information
update,
15
through
the
web,
15
by
telephone.
A­
11
Table
A­
3a.
Estimated
Respondent
Burden
And
Cost
For
Year
3
 
Industry
Project
Developers
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
96.22/

Hour
Mgr.

$
93.09/

Hour
Tech.

$
64.13/

Hour
Cler.

$
39.65/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.50
0.25
0.25
0.00
1.00
$
87
$
0
3
3
$
262
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
39
$
0
3
2
$
118
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
3
2
$
68
SUBTOTAL
6
$
449
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.50
0.00
0.50
$
32
$
0
57
29
$
1,828
Gather
information
­
new
developers4
0.00
0.00
7.00
0.00
7.00
$
449
$
0
3
21
$
1,347
Gather
information
­
existing
developers5
0.00
0.00
3.00
0.00
3.00
$
192
$
0
54
162
$
10,390
Complete
the
form
­
new
developers4
0.00
1.50
5.25
3.75
10.50
$
625
$
0
3
32
$
1,875
Complete
the
form
­
existing
developers5
0.00
0.50
1.50
0.50
2.50
$
163
$
0
54
135
$
8,779
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
57
29
$
1,301
SUBTOTAL
407
$
25,519
Information
Update6
Gather
Information
0.00
0.00
1.50
0.00
1.50
$
96
$
0
27
41
$
2,597
Provide
information
via
LMOP
Web
site
0.00
0.00
1.00
0.00
1.00
$
64
$
0
14
14
$
898
Provide
information
via
telephone
interview
0.00
0.00
1.00
0.00
1.00
$
64
$
0
13
13
$
834
SUBTOTAL
68
$
4,329
TOTAL
480
$
30,297
1
Source
for
managerial,
technical,
and
clerical
labor
rates:
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
10.
Private
Industry,
by
Occupational
and
Industry
Group,"
June
2003,

http://
www.
bls.
gov/
news.
release/
ecec.
t10.
htm.
Sources
for
legal
labor
rates:
1)
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
1.
National
employment
and
wage
data
from
the
Occupational
Employment
Statistics
survey
by
occupation,
2001."
http://
www.
bls.
gov/
news.
release/
ocwage.
t01.
htm.
2)
Bureau
of
Labor
Statistics,
"
Consumer
Price
Index­
All
Urban
Consumers."
http://
www.
bls.
gov/
data/
home.
htm.

A
June
2003
legal
labor
rate
was
estimated
by
applying
a
consumer
price
index
growth
rate
(
ratio
of
the
June
2003
consumer
price
index
to
the
2001
annual
average
consumer
price
index,
or
183.7/
177.1=
1.037)
to
the
2001
legal
labor
rate
in
Table
1.
All
labor
rates
incorporate
a
110%
factor
to
account
for
overhead
profit.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
3,
it
is
expected
that
3
new
industry
project
developers
will
join
LMOP.

3
In
year
3,
all
new
partners
must
submit
a
completed
information
form.
Additionally,
all
existing
project
developers
must
review
project
information
they
have
previously
provided
and
submit
any
corrections
and
complete
a
form
for
any
new
projects.
In
year
3,
there
are
an
estimated
3
new
industry
project
developers
and
54
existing
developers,
for
a
total
of
57
developers
that
will
complete
an
information
form.

4
The
information
form
must
be
filled
out
for
each
project.
The
hour
estimates
represent
an
average
burden
for
developers.
It
is
based
on
2
new
smaller
developers
with
1
project
and
1
new
larger
developer
with
an
average
of
17
projects.
Time
to
gather
information
is
2
hours
for
a
small
developer
and
17
hours
for
a
large
developer,
averaging
7
hours
per
developer.
Time
to
complete
the
forms
is
3
hours
for
a
small
developer
and
25.5
hours
for
a
large
developer,
averaging
10.5
hours
per
developer.

5
Project
developers
must
submit
updated
information
forms
annually.
In
year
3,
it
is
estimated
that
there
are
54
existing
project
developers.
Because
the
developers
have
already
filled
out
the
form
in
a
previous
year,
and
they
will
only
be
asked
to
review
information
on
existing
projects
and
provide
information
on
new
projects,
the
burden
will
be
significantly
less
than
that
for
new
developers.

6
It
is
assumed
that
in
year
3,
half
of
all
existing
project
developers
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
3,
there
are
an
estimated
54
existing
project
developer
partners.
It
is
assumed
27
will
provide
an
information
update,
14
through
the
web,

13
by
telephone.
A­
12
Table
A­
3b.
Estimated
Respondent
Burden
And
Cost
For
Year
3
 
Industry
Partners
(
Non­
Developers)

INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
96.22/

Hour
Mgr.

$
93.09/

Hour
Tech.

$
64.13/

Hour
Cler.

$
39.65/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.50
0.25
0.25
0.00
1.00
$
87
$
0
26
26
$
2,273
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
39
$
0
26
13
$
1,022
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
26
13
$
593
SUBTOTAL
52
$
3,888
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.50
0.00
0.50
$
32
$
0
26
13
$
834
Gather
information
0.00
0.00
1.00
0.00
1.00
$
64
$
0
26
26
$
1,667
Complete
the
form
0.00
0.25
1.00
0.50
1.75
$
107
$
0
26
46
$
2,788
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
26
13
$
593
SUBTOTAL
98
$
5,883
Information
Update4
Gather
Information
0.00
0.00
1.50
0.00
1.50
$
96
$
0
103
155
$
9,909
Provide
information
via
LMOP
Web
site
0.00
0.00
1.00
0.00
1.00
$
64
$
0
51
51
$
3,271
Provide
information
via
telephone
interview
0.00
0.00
1.00
0.00
1.00
$
64
$
0
52
52
$
3,335
SUBTOTAL
258
$
16,515
TOTAL
407
$
26,285
1
Source
for
managerial,
technical,
and
clerical
labor
rates:
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
10.
Private
Industry,
by
Occupational
and
Industry
Group,"
June
2003,

http://
www.
bls.
gov/
news.
release/
ecec.
t10.
htm.
Sources
for
legal
labor
rates:
1)
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
1.
National
employment
and
wage
data
from
the
Occupational
Employment
Statistics
survey
by
occupation,
2001."
http://
www.
bls.
gov/
news.
release/
ocwage.
t01.
htm.
2)
Bureau
of
Labor
Statistics,
"
Consumer
Price
Index­
All
Urban
Consumers."
http://
www.
bls.
gov/
data/
home.
htm.

A
June
2003
legal
labor
rate
was
estimated
by
applying
a
consumer
price
index
growth
rate
(
ratio
of
the
June
2003
consumer
price
index
to
the
2001
annual
average
consumer
price
index,
or
183.7/
177.1=
1.037)
to
the
2001
legal
labor
rate
in
Table
1.
All
labor
rates
incorporate
a
110%
factor
to
account
for
overhead
profit.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
3,
it
is
expected
that
26
new
industry
partners
(
non­
developers)
will
join
LMOP.

3
Non­
developer
industry
partners
are
not
expected
to
provide
information
for
new
projects
or
revise
information
on
existing
projects
as
they
are
not
directly
involved
in
LFGE
projects.
As
a
result,
in
year
3,
only
the
26
new
industry
partners
(
non­
developers)
will
be
required
to
submit
an
information
form.

4
It
is
assumed
that
in
year
3,
half
of
all
existing
non­
developers
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
3,
there
are
an
estimated
206
existing
non­
developer
industry
partners.
It
is
assumed
103
will
provide
an
information
update,
51
through
the
web,

52
by
telephone.
A­
13
Table
A­
3c.
Estimated
Respondent
Burden
And
Cost
For
Year
3
 
Energy
Partners
(
direct
users,
power
marketers,
utilities)

INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
96.22/

Hour
Mgr.

$
93.09/

Hour
Tech.

$
64.13/

Hour
Cler.

$
39.65/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.50
0.25
0.25
0.00
1.00
$
87
$
0
5
5
$
437
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
39
$
0
5
3
$
197
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
5
3
$
114
SUBTOTAL
10
$
748
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.50
0.00
0.50
$
32
$
0
67
34
$
2,148
Gather
information
­
new
partners
0.00
0.00
1.50
0.00
1.50
$
96
$
0
5
8
$
481
Gather
information
­
existing
partners
0.00
0.00
1.00
0.00
1.00
$
64
$
0
62
62
$
3,976
Complete
the
form
­
new
partners
0.00
0.50
1.50
0.50
2.50
$
163
$
0
5
13
$
813
Complete
the
form
­
existing
partners
0.00
0.50
1.00
0.50
2.00
$
131
$
0
62
124
$
8,091
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
20
$
3
67
34
$
1,529
SUBTOTAL
273
$
17,039
Information
Update4
Gather
Information
0.00
0.00
1.50
0.00
1.50
$
96
$
0
31
47
$
2,982
Provide
information
via
LMOP
Web
site
0.00
0.00
1.00
0.00
1.00
$
64
$
0
16
16
$
1,026
Provide
information
via
telephone
interview
0.00
0.00
1.00
0.00
1.00
$
64
$
0
15
15
$
962
SUBTOTAL
78
$
4,970
TOTAL
361
$
22,757
1
Source
for
managerial,
technical,
and
clerical
labor
rates:
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
10.
Private
Industry,
by
Occupational
and
Industry
Group,"
June
2003,

http://
www.
bls.
gov/
news.
release/
ecec.
t10.
htm.
Sources
for
legal
labor
rates:
1)
Bureau
of
Labor
Statistics,
United
States
Department
of
Labor
News,
"
Table
1.
National
employment
and
wage
data
from
the
Occupational
Employment
Statistics
survey
by
occupation,
2001."
http://
www.
bls.
gov/
news.
release/
ocwage.
t01.
htm.
2)
Bureau
of
Labor
Statistics,
"
Consumer
Price
Index­
All
Urban
Consumers."
http://
www.
bls.
gov/
data/
home.
htm.

A
June
2003
legal
labor
rate
was
estimated
by
applying
a
consumer
price
index
growth
rate
(
ratio
of
the
June
2003
consumer
price
index
to
the
2001
annual
average
consumer
price
index,
or
183.7/
177.1=
1.037)
to
the
2001
legal
labor
rate
in
Table
1.
All
labor
rates
incorporate
a
110%
factor
to
account
for
overhead
profit.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
3,
it
is
expected
that
5
new
energy
partners
will
join
LMOP.

3
In
year
3,
all
new
partners
must
submit
a
completed
information
form.
Additionally,
all
existing
energy
partners
must
review
project
information
they
have
previously
provided
and
submit
any
corrections
and
complete
a
form
for
any
new
projects.
In
year
3,
there
are
an
estimated
5
new
energy
partners
and
62
existing
energy
partners,
for
a
total
of
67
energy
partners
that
will
complete
an
information
form.

4
It
is
assumed
that
in
year
3,
half
of
all
existing
energy
partners
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
3,
there
are
an
estimated
62
existing
energy
partners.
It
is
assumed
31
will
provide
an
information
update,
16
through
the
web,
15
by
telephone.
A­
14
Table
A­
3d.
Estimated
Respondent
Burden
And
Cost
For
Year
3
 
State
Partners
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
65.28/

Hour
Mgr.

$
65.28/

Hour
Tech.

$
44.75/

Hour
Cler.

$
17.97/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.00
0.25
0.25
0.00
0.50
$
28
$
0
1
1
$
28
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
28
$
0
1
1
$
28
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
9
$
3
1
1
$
12
SUBTOTAL
2
$
67
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.25
0.00
0.25
$
11
$
0
1
0.3
$
11
Gather
information
0.00
0.00
0.50
0.00
0.50
$
22
$
0
1
1
$
22
Complete
the
form
0.00
0.25
0.25
0.50
1.00
$
36
$
0
1
1
$
36
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
9
$
3
1
1
$
12
SUBTOTAL
2
$
82
Information
Update4
Gather
Information
0.00
0.00
0.50
0.00
0.50
$
22
$
0
18
9
$
403
Provide
information
via
LMOP
Web
site
0.00
0.00
0.25
0.00
0.25
$
11
$
0
9
2
$
101
Provide
information
via
telephone
interview
0.00
0.00
0.25
0.00
0.25
$
11
$
0
9
2
$
101
SUBTOTAL
14
$
604
TOTAL
17
$
753
1
Labor
rates
for
EPA
personnel
were
used
for
all
public­
sector
personnel,
including
employees
of
State
agencies.
Source
for
EPA
labor
rates:
Department
of
Personnel
Management,
"
Salary
Table
2003
­
GS,"

http://
www.
opm.
gov/
oca/
03tables/
pdf/
gs_
h.
pdf.
For
the
managerial
and
legal
labor
rates,
level
GS­
15,
step
1
was
used,
for
the
technical
labor
rate,
level
GS­
12,
step
5
was
used,
for
the
clerical
labor
rate,
level
GS­
5,
step
1
was
used.
All
agency
labor
rates
include
a
multiplier
of
1.6
to
account
for
overhead
and
fringe
benefit
costs.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
3,
it
is
expected
that
1
new
State
partner
will
join
LMOP.

3
State
partners
are
not
expected
to
provide
information
for
new
projects
or
revise
information
on
existing
projects
as
they
are
not
directly
involved
in
LFGE
projects.
As
a
result,
in
year
3,
only
the
1
new
State
partner
will
be
required
to
submit
an
information
form.

4
It
is
assumed
that
in
year
3,
half
of
all
existing
State
partners
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
3,
there
are
an
estimated
35
existing
State
partners.
It
is
assumed
18
will
provide
an
information
update,
9
through
the
web,
9
by
telephone.
A­
15
Table
A­
3e.
Estimated
Respondent
Burden
And
Cost
For
Year
3
 
Community
Partners
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Leg.

$
65.28/

Hour
Mgr.

$
65.28/

Hour
Tech.

$
44.75/

Hour
Cler.

$
17.97/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
MOU
0.00
0.25
0.25
0.00
0.50
$
28
$
0
5
3
$
138
Complete
MOU
0.00
0.25
0.25
0.00
0.50
$
28
$
0
5
3
$
138
Submit
MOU
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
9
$
3
5
3
$
60
SUBTOTAL
8
$
335
Information
Forms3
Review
form
and
instructions
0.00
0.00
0.50
0.00
0.50
$
22
$
0
70
35
$
1,566
Gather
information
­
new
partners
0.00
0.00
1.50
0.00
1.50
$
67
$
0
5
8
$
336
Gather
information
­
existing
partners
0.00
0.00
1.00
0.00
1.00
$
45
$
0
65
65
$
2,909
Complete
the
form
­
new
partners
0.00
0.50
1.50
0.50
2.50
$
109
$
0
5
13
$
544
Complete
the
form
­
existing
partners
0.00
0.50
1.00
0.50
2.00
$
86
$
0
65
130
$
5,614
Submit
form
to
EPA
and
file
copy
0.00
0.00
0.00
0.50
0.50
$
9
$
3
70
35
$
839
SUBTOTAL
285
$
11,808
Information
Update4
Gather
Information
0.00
0.00
1.50
0.00
1.50
$
67
$
0
33
50
$
2,215
Provide
information
via
LMOP
Web
site
0.00
0.00
1.00
0.00
1.00
$
45
$
0
16
16
$
716
Provide
information
via
telephone
interview
0.00
0.00
1.00
0.00
1.00
$
45
$
0
17
17
$
761
SUBTOTAL
83
$
3,692
TOTAL
375
$
15,835
1
Labor
rates
for
EPA
personnel
were
used
for
all
public­
sector
personnel,
including
employees
of
local
communities.
Source
for
EPA
labor
rates:
Department
of
Personnel
Management,
"
Salary
Table
2003
­
GS,"

http://
www.
opm.
gov/
oca/
03tables/
pdf/
gs_
h.
pdf.
For
the
managerial
and
legal
labor
rates,
level
GS­
15,
step
1
was
used,
for
the
technical
labor
rate,
level
GS­
12,
step
5
was
used,
for
the
clerical
labor
rate,
level
GS­
5,
step
1
was
used.
All
agency
labor
rates
include
a
multiplier
of
1.6
to
account
for
overhead
and
fringe
benefit
costs.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
3,
it
is
expected
that
5
new
partners
will
join
LMOP.

3
In
year
3,
all
new
partners
must
submit
a
completed
information
form.
Additionally,
all
existing
partners
must
review
project
information
they
have
previously
provided
and
submit
any
corrections
and
complete
a
form
for
any
new
projects.
In
year
3,
there
are
an
estimated
5
new
partners
and
65
existing
partners,
for
a
total
of
70
partners
that
will
complete
an
information
form.

4
It
is
assumed
that
in
year
3,
half
of
all
existing
partners
will
submit
an
information
update.
It
is
assumed
that
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
3,
there
are
an
estimated
65
existing
partners.
It
is
assumed
33
will
provide
an
information
update,
16
through
the
web,
17
by
telephone.
Attachment
B
Estimate
of
Agency
Burden
B­
1
Table
B­
1.
Estimated
Agency
Burden
And
Cost
For
Year
1
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Mgr.

$
65.28/

Hour
Tech.

$
44.75/

Hour
Cler.

$
17.97/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
and
sign
MOU
0.25
0.50
0.00
0.75
$
39
$
0
40
30
$
1,548
File
MOU
and
return
signed
copy
to
the
partner
0.00
0.00
0.50
0.50
$
9
$
0
40
20
$
359
Enter
MOU
information
into
a
database
0.00
0.50
0.00
0.50
$
22
$
0
40
20
$
895
SUBTOTAL
70
$
2,802
Information
Forms3
Prepare
and
send
information
forms
to
new
partners
0.00
0.25
0.00
0.25
$
11
$
3
40
10
$
568
Prepare
and
send
information
forms
to
existing
partners
0.00
1.00
0.25
1.25
$
49
$
3
155
194
$
8,098
Review
information
form
and
follow
up,
if
necessary
0.00
2.00
0.00
2.00
$
90
$
0
195
390
$
17,453
Enter
information
into
database
and
file
copy
of
the
form
0.00
0.50
0.00
0.50
$
22
$
0
195
98
$
4,363
SUBTOTAL
691
$
30,482
Receive
Information
Update4
Review
information
received
via
LMOP
Web
site
0.00
0.25
0.00
0.25
$
11
$
0
86
22
$
962
Revise
data
in
the
database
0.00
0.50
0.00
0.50
$
22
$
0
86
43
$
1,924
SUBTOTAL
65
$
2,887
Initiate
Information
Update4
Call
or
email
partner
and
request
updated
information
0.00
0.50
0.00
0.50
$
22
$
0
86
43
$
1,924
Revise
data
in
database
0.00
0.50
0.00
0.50
$
22
$
0
86
43
$
1,924
SUBTOTAL
86
$
3,849
TOTAL
912
$
40,019
1
Source
for
Agency
labor
rates:
Department
of
Personnel
Management,
"
Salary
Table
2003
­
GS,"
http://
www.
opm.
gov/
oca/
03tables/
pdf/
gs_
h.
pdf.
For
the
managerial
labor
rate,
level
GS­
15,
step
1
was
used,
for
the
technical
labor
rate,
level
GS­
12,
step
5
was
used,
for
the
clerical
labor
rate,
level
GS­
5,
step
1
was
used.
All
agency
labor
rates
include
a
multiplier
of
1.6
to
account
for
overhead
and
fringe
benefit
costs.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
1,
it
is
expected
that
40
new
partners
will
join
LMOP.

3
In
year
1,
EPA
will
compile
project
information
for
existing
partners
to
review
and
revise
if
necessary.
Existing
partners
will
also
provide
information
on
new
projects.
EPA
will
prepare
and
send
forms
for
new
partners
along
with
the
signed
MOU,
which
will
require
less
time
and
effort.
In
year
1,
it
is
estimated
that
there
will
be
40
new
partners
and
155
existing
partners
directly
involved
in
LFGE
projects
(
48
project
developers,
52
energy
partners,
and
55
community
partners).
EPA
will
review
the
information
provided
from
existing
partners
as
well
as
information
from
new
partners
(
40
additional
respondents)
and
enter
the
information
into
the
LMOP
database.

4
It
is
assumed
that
in
year
1,
half
of
all
existing
partners
will
submit
an
information
update.
It
is
assumed
that
approximately
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
1,
there
are
an
estimated
342
existing
partners.
It
is
assumed
172
will
provide
an
information
update,
86
through
the
web,
86
by
telephone.
B­
2
Table
B­
2.
Estimated
Agency
Burden
And
Cost
For
Year
2
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Mgr.

$
65.28/

Hour
Tech.

$
44.75/

Hour
Cler.

$
17.97/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
and
sign
MOU
0.25
0.50
0.00
0.75
$
39
$
0
40
30
$
1,548
File
MOU
and
return
signed
copy
to
the
partner
0.00
0.00
0.50
0.50
$
9
$
0
40
20
$
359
Enter
MOU
information
into
a
database
0.00
0.50
0.00
0.50
$
22
$
0
40
20
$
895
SUBTOTAL
70
$
2,802
Information
Forms3
Prepare
and
send
information
forms
to
new
partners
0.00
0.25
0.00
0.25
$
11
$
3
40
10
$
568
Prepare
and
send
information
forms
to
existing
partners
0.00
1.00
0.25
1.25
$
49
$
3
168
210
$
8,777
Review
information
form
and
follow
up,
if
necessary
0.00
2.00
0.00
2.00
$
90
$
0
208
416
$
18,617
Enter
information
into
database
and
file
copy
of
the
form
0.00
0.50
0.00
0.50
$
22
$
0
208
104
$
4,654
SUBTOTAL
740
$
32,616
Receive
Information
Update4
Review
information
received
via
LMOP
Web
site
0.00
0.25
0.00
0.25
$
11
$
0
96
24
$
1,074
Revise
data
in
the
database
0.00
0.50
0.00
0.50
$
22
$
0
96
48
$
2,148
SUBTOTAL
72
$
3,222
Initiate
Information
Update4
Call
or
email
partner
and
request
updated
information
0.00
0.50
0.00
0.50
$
22
$
0
96
48
$
2,148
Revise
data
in
database
0.00
0.50
0.00
0.50
$
22
$
0
96
48
$
2,148
SUBTOTAL
96
$
4,296
TOTAL
978
$
42,936
1
Source
for
Agency
labor
rates:
Department
of
Personnel
Management,
"
Salary
Table
2003
­
GS,"
http://
www.
opm.
gov/
oca/
03tables/
pdf/
gs_
h.
pdf.
For
the
managerial
labor
rate,
level
GS­
15,
step
1
was
used,
for
the
technical
labor
rate,
level
GS­
12,
step
5
was
used,
for
the
clerical
labor
rate,
level
GS­
5,
step
1
was
used.
All
agency
labor
rates
include
a
multiplier
of
1.6
to
account
for
overhead
and
fringe
benefit
costs.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
2,
it
is
expected
that
40
new
partners
will
join
LMOP.

3
In
year
2,
EPA
will
compile
project
information
for
existing
partners
to
review
and
revise
if
necessary.
Existing
partners
will
also
provide
information
on
new
projects.
EPA
will
prepare
and
send
forms
for
new
partners
along
with
the
signed
MOU,
which
will
require
less
time
and
effort.
In
year
2,
it
is
estimated
that
there
will
be
40
new
partners
and
168
existing
partners
directly
involved
in
LFGE
projects
(
51
project
developers,
57
energy
partners,
and
60
community
partners).
EPA
will
review
the
information
provided
from
existing
partners
as
well
as
information
from
new
partners
(
40
additional
respondents)
and
enter
the
information
into
the
LMOP
database.

4
It
is
assumed
that
in
year
2,
half
of
all
existing
partners
will
submit
an
information
update.
It
is
assumed
that
approximately
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
2,
there
are
an
estimated
382
existing
partners.
It
is
assumed
192
will
provide
an
information
update,
96
through
the
web,
96
by
telephone.
B­
3
Table
B­
3.
Estimated
Agency
Burden
And
Cost
For
Year
3
INFORMATION
COLLECTION
ACTIVITY
Hours
and
Costs
Per
Respondent/
Activity1
Total
Hours
and
Costs
Mgr.

$
65.28/

Hour
Tech.

$
44.75/

Hour
Cler.

$
17.97/

Hour
Respon.

Hours/
Activity
Labor
Cost/
Activity
O
&
M
Cost
Number
of
Respondents
Total
Hours/

Year
Total
Cost/

Year
Memoranda
of
Understanding2
Review
and
sign
MOU
0.25
0.50
0.00
0.75
$
39
$
0
40
30
$
1,548
File
MOU
and
return
signed
copy
to
the
partner
0.00
0.00
0.50
0.50
$
9
$
0
40
20
$
359
Enter
MOU
information
into
a
database
0.00
0.50
0.00
0.50
$
22
$
0
40
20
$
895
SUBTOTAL
70
$
2,802
Information
Forms3
Prepare
and
send
information
forms
to
new
partners
0.00
0.25
0.00
0.25
$
11
$
3
40
10
$
568
Prepare
and
send
information
forms
to
existing
partners
0.00
1.00
0.25
1.25
$
49
$
3
181
226
$
9,456
Review
information
form
and
follow
up,
if
necessary
0.00
2.00
0.00
2.00
$
90
$
0
221
442
$
19,780
Enter
information
into
database
and
file
copy
of
the
form
0.00
0.50
0.00
0.50
$
22
$
0
221
111
$
4,945
SUBTOTAL
789
$
34,749
Receive
Information
Update4
Review
information
received
via
LMOP
Web
site
0.00
0.25
0.00
0.25
$
11
$
0
106
27
$
1,186
Revise
data
in
the
database
0.00
0.50
0.00
0.50
$
22
$
0
106
53
$
2,372
SUBTOTAL
80
$
3,558
Initiate
Information
Update4
Call
or
email
partner
and
request
updated
information
0.00
0.50
0.00
0.50
$
22
$
0
106
53
$
2,372
Revise
data
in
database
0.00
0.50
0.00
0.50
$
22
$
0
106
53
$
2,372
SUBTOTAL
106
$
4,744
TOTAL
1,044
$
45,853
1
Source
for
Agency
labor
rates:
Department
of
Personnel
Management,
"
Salary
Table
2003
­
GS,"
http://
www.
opm.
gov/
oca/
03tables/
pdf/
gs_
h.
pdf.
For
the
managerial
labor
rate,
level
GS­
15,
step
1
was
used,
for
the
technical
labor
rate,
level
GS­
12,
step
5
was
used,
for
the
clerical
labor
rate,
level
GS­
5,
step
1
was
used.
All
agency
labor
rates
include
a
multiplier
of
1.6
to
account
for
overhead
and
fringe
benefit
costs.

2
All
partners
must
submit
MOU
when
they
join
LMOP.
In
year
3,
it
is
expected
that
40
new
partners
will
join
LMOP.

3
In
year
3,
EPA
will
compile
project
information
for
existing
partners
to
review
and
revise
if
necessary.
Existing
partners
will
also
provide
information
on
new
projects.
EPA
will
prepare
and
send
forms
for
new
partners
along
with
the
signed
MOU,
which
will
require
less
time
and
effort.
In
year
3,
it
is
estimated
that
there
will
be
40
new
partners
and
181
existing
partners
directly
involved
in
LFGE
projects
(
54
project
developers,
62
energy
partners,
and
65
community
partners).
EPA
will
review
the
information
provided
from
existing
partners
as
well
as
information
from
new
partners
(
40
additional
respondents)
and
enter
the
information
into
the
LMOP
database.

4
It
is
assumed
that
in
year
3,
half
of
all
existing
partners
will
submit
an
information
update.
It
is
assumed
that
approximately
half
of
those
that
update
their
information
will
provide
information
through
the
LMOP
Web
site
and
the
other
half
will
provide
information
through
a
telephone
interview.
In
year
3,
there
are
an
estimated
422
existing
partners.
It
is
assumed
212
will
provide
an
information
update,
106
through
the
web,
106
by
telephone.
