SUPPORTING STATEMENT FOR

LANDFILL METHANE OUTREACH PROGRAM,

EPA INFORMATION COLLECTION REQUEST NUMBER 1849.03

November 12, 20081.	IDENTIFICATION OF THE INFORMATION COLLECTION

Title of the Information Collection

This renewal information collection is entitled “Reporting Under EPA's
Landfill Methane Outreach Program”, ICR number 1849.03.

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 (LFG) energy projects across the United
States in order to reduce methane emissions from landfills. LMOP does
this by educating local governments and communities about the benefits
of LFG recovery and use; building partnerships between state agencies,
industry, energy service providers, local communities, and other
stakeholders interested in developing this valuable resource in their
community; and providing tools to evaluate LFG energy (LFGE) potential. 

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. Additionally, in order for LMOP to improve the data
quality in one of its critical program tools, the LMOP Landfill and
Landfill Gas Energy Project database, LMOP must gather basic physical
and operational data from municipal solid waste (MSW) landfills without
LFGE projects. Improving the data quality in this tool will enable LMOP
to identify landfills that are good candidates for LFGE projects,
improve estimates of methane emissions from landfills, and help LMOP and
its Partners prioritize LFGE project development assistance activities.

Partners are entities that have volunteered to participate in LMOP. LMOP
classifies these Partners into one of five categories: Community
Partners, State Partners, Industry Partners, Energy Partners, and
Endorsers. There are three mechanisms for collecting information from
the Partners:

electronic memoranda of understanding (MOU);

pre-populated Excel spreadsheets; and

electronic periodic information updates.

In addition to collecting data from its Partners, LMOP has identified
approximately 1,000 landfills owned or operated by other organizations
that are considered to have LFGE potential. LMOP plans to initiate a
one-time effort to update basic landfill physical and operational data
for these landfills using a pre-populated Excel spreadsheet. 

The LMOP information collection is expected to involve an average of 832
existing Partners and an additional 114 new Partners per year.
Additionally there is a planned one-time information collection for
1,000 other landfill owners and operators. The average annual burden
(rounded to one decimal place) and cost per respondent are estimated to
be 4.6 hours and $270. The total annual reporting and recordkeeping
burden averaged over three years is 5,885 hours and $344,827.

This ICR provides a comprehensive description of the information
collections under LMOP. Sections 1 through 5 of this ICR describe the
specific information collections (e.g., from the standpoint of need,
use, and respondent activities). In Section 6, EPA estimates the annual
hour and cost burden to respondents and the Agency under these
collections.

2. NEED FOR AND USE OF THIS COLLECTION

2(a) Need/Authority for the Collection

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 from certain types of
Partners through spreadsheets 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
resource, and reducing emissions due to the burning of non-renewable
energy resources such as coal and fuel oil.

Participation in LMOP is voluntary. The five categories of participants
are:

Community Partners;

State Partners;

Industry Partners (developers and non-developers); 

Energy Partners; and

Endorsers.

All participants, in completing the MOU, agree to provide EPA with
information requested in the MOU and provide contact information for
their LMOP coordinator. Industry Developer 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). 

Additionally, EPA needs to improve the data quality in one of its
critical program tools, the publicly available LMOP Landfill and
Landfill Gas Energy Project database. This is the only known national
database of LFGE projects and landfills with potential. Basic physical
and operational data for approximately 1,000 (MSW) landfills are either
sparsely populated or outdated. Since the inception of LMOP in 1994
there has never been a systematic national outreach to update landfill
data. This outreach to landfills within the LMOP Landfill and Landfill
Gas Energy Project database tool will serve several functions:

improve the accuracy of LMOP’s responses to inquiries about landfills
and LFG energy, in particular to help project developers and the general
public identify future opportunities for developing LFGE projects;

assist LMOP in identifying landfills that are good candidates for LFGE
projects, prioritizing resources on the next generation of landfills
suitable for LFGE project development, and reaching program goals; and 

provide communities with information they need to assess LFGE potential
at their landfills, communicate the benefits of LFG energy, and begin
developing LFGE projects.

2(b) Practical Utility/Users of the Data

EPA uses information submitted in the MOU to update its database of LMOP
Partners. The database serves as a source of general information and an
electronic mailing list. EPA uses information in spreadsheet attachments
submitted by Industry Developer Partners and Community Partners to
monitor the progress of LFGE projects and identify opportunities for new
projects. 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 LFG. General
information about the Partners, operational and under construction LFGE
projects, and landfills that may have potential for developing LFGE
projects is also provided on the LMOP Web site, making it available to
other LMOP Partners as well as the public. During EPA fiscal year 2007,
LMOP processed over 100 data requests from the public that required
accessing data in the LMOP Landfill and Landfill Gas Energy Project
database. 

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

Nonduplication

For new Partners, the information to be collected has not previously
been collected by EPA or any other Federal Agency. For existing Partners
with LFGE projects, and outreach to other landfill owner and operator
organizations without a LFGE project, some of the information required
may be available in the existing LMOP database. To avoid requesting
information that has already been collected, spreadsheets sent to
existing Partners and other landfill owners and operators will be
pre-populated with information from the database. Recipients of the
spreadsheets will be asked to review the information provided. Only if
the information is incorrect or out of date will the recipients be
requested to provide updated or additional information.

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 3, 2008 (73 FR 31681). The Agency did not receive any
comments on this ICR renewal. 

3(c) 	Consultations

In 2000, EPA consulted with fewer than nine Partners regarding the
burden of this information collection. The following Partners were
contacted to obtain burden estimates of LMOP activities. Since 2000, all
of the information collection procedures for LMOP have transitioned to a
more efficient, electronic, and when possible, pre-populated format.
Thus, the burden and time associated with completing the MOU, updating
landfill and LFGE project data, and submitting periodic updates are
assumed to be less than were estimated by Partners in 2000. 

Table   SEQ Table \* ARABIC  1 : List of Partner Consultations Made in
2000

Partner Type	Contact Person, Company	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
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



In 2007, LMOP also contacted fewer than nine Partners on the preferred
format for making updates to their LFGE projects and landfills in the
future. LMOP provided a choice of using the existing online data update
forms used in ICR 1849.02, or an e-mail with a pre-populated spreadsheet
attachment for all of their projects/landfills. All Partners were either
indifferent between these two options or preferred the new spreadsheet
information collection method to the old online form.

Table 2: List of Partner Consultations Made in 2007

Partner Type	Contact Person, Company	Phone Number

Industry Partner, developer	Jerry Leone, Casella Waste	607-435-9996

Industry Partner, developer	Dawn Semple, Granger Energy	517-371-9722

Industry Partner, developer	David Mauney, CPL Systems	337-269-4699 x1167

Industry Partner, developer	John Bean, G2 Energy 	281-222-1037

Community Partner	Megan Miller, Hillsborough County, FL 	813-276-2956

Community Partner	Vance Kemler, City of Denton, TX	940-349-8044



In 2008, LMOP also contacted fewer than nine Partners regarding the
burden of this information collection, considering the new methodology
of collecting landfill and LFGE project data with pre-populated
spreadsheets sent via e-mail. The Partners contacted agreed that the
estimated burden by Partner type is what they would expect for this
effort or the amount they expect is less than the estimate. 

Table 3: List of Partner Consultations Made in 2008

Partner Type	Contact Person, Company	Phone Number

Industry Partner, developer	Jerry Leone, Casella Waste	607-435-9996

Industry Partner, developer	David Mauney, CPL Systems	337-278-7899

Community Partner	Megan Miller, Hillsborough County, FL	813-276-2956



3(d)  Effects of Less Frequent Collection

The MOU are submitted once by organizations that choose to become
Partners of LMOP. To allow EPA to remain current on LFGE projects,
Industry Developer and Community Partners directly involved in projects
will be asked to update the landfill and LFGE project data spreadsheets
annually. All Partners may also update company and contact information
periodically. For others that own or operate landfills without a LFGE
project, EPA will conduct a one-time information collection effort to
update critical landfill data necessary for evaluating future LFGE
project potential. 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.

General Guidelines

This information collection request was prepared in compliance with
OMB’s and EPA’s guidelines for ICR preparation.

Confidentiality

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

Sensitive Questions

No questions of a sensitive nature are asked in the MOU, pre-populated
landfill and LFGE project data spreadsheets, or periodic information
updates.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

 4(a) Respondent NAICS 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 engine and turbine manufacturers,
engineering firms, construction companies, environmental consultants,
and other companies involved in the logistics of developing LFGE
projects such as law firms and financing companies. Industry Partners
are further divided into two groups: (1) developers are organizations
that facilitate, finance, and implement LFGE projects; (2)
non-developers are manufacturers or suppliers of equipment or expertise
needed to collect and utilize LFG. Energy Partners include utility
companies who purchase energy generated from landfills, power marketers,
and direct end users of energy from the landfill. The end user category
is potentially the most diverse category. Any facility located near a
landfill that utilizes fuel either in manufacturing products or in
heating the facility is a potential energy end user. Finally, Endorsers
are non-profit organizations coordinating with EPA to publicize and
promote the use of LFG among their members or constituents. These
include several trade associations representing the solid waste
industry, public works, municipalities, and renewable energy. Table 4
provides the North American Industry Classification System (NAICS) code
and description for the respondents.

Table 4: Respondents to Information Collection

Partner Type	NAICS Code	NAICS Description

Community Partners and State Partners	  924	Public Administration,
Administration of

Environmental Quality Programs

	924110	Public Administration, Administration of Air and

Water Resource and Solid Waste Management

Programs

	926130	Public Administration, Regulation and Administration

of Communications, Electric, Gas, and Other Utilities





Industry Partners	333611	Turbine and Turbine Generator Set Units
Manufacturing

	333618	Other Engine Equipment Manufacturing

	541330	Engineering Services

	541620	Environmental Consulting Services

	562212	Administrative and Support and Waste Management

and Remediation Services, Solid Waste Landfill

	541110	Offices of Lawyers

	522110	Commercial Banking

	523910	Financial Investments and Related Activities,

Miscellaneous Intermediation





Energy Partners



         Direct usersa	611310	Colleges, Universities, and Professional
Schools

	325412	Pharmaceutical Preparation Manufacturing

	327121	Brick and Structural Clay Tile Manufacturing

	327310	Cement Manufacturing

	334210	Telephone Apparatus Manufacturing

	334220	Radio and Television Broadcasting and Wireless

Communications Equipment Manufacturing

	336111	Automobile Manufacturing

	325411	Medicinal and Botanical Manufacturing

	331511	Iron Foundries

	311111	Dog and Cat Food Manufacturing

	311421	Fruit and Vegetable Canning

	311911	Other Food Manufacturing





Power marketers

and utilities	221121	Electric Bulk Power Transmission and Control

	221122	Electric Power Distribution

	221119	Other Electric Power Generation





Endorsers	813910	Business Associations

		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. A subset of the NAICS codes and descriptions from current
direct 	energy users are included in Table 4.

		4(b) Information Requested

(i)	Data Items, Including Recordkeeping Requirements

Information will be collected in MOU, pre-populated electronic
spreadsheets, 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 e-mail address;

Brief description of the organization (except for Endorsers);

Organization’s Web site address; and

A camera-ready copy of the organization’s logo or seal.

Pre-populated electronic spreadsheets request Industry Developer
Partners and Community Partners to update existing critical LFGE project
data necessary for tracking greenhouse gas reductions from LFGE
projects, such as project size and start year. 

All Partners may provide information through periodic updates. These
updates will mainly be changes to contact information for LMOP
coordinators and experts, but they can also include providing or
updating a brief (optional) description of the organization which LMOP
will post on the LMOP Web site to provide publicity and encourage
networking among Partners. LMOP may also call a selection of Partners to
confirm or update project information that LMOP has received through the
media or industry contacts.

The pre-populated electronic spreadsheets sent to other landfill
owners/operators without a LFGE project request that landfill
owners/operators update information on landfill physical and operational
data, waste data, and gas collection system. The data fields requested
are limited to fields critical for evaluating a landfill’s LFGE
potential and for estimating potential methane emissions reductions.

Participation in LMOP does not require any records to be kept, although
Partners will likely keep file copies of MOU and spreadsheets 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 MOU;

complete the MOU online or in hardcopy;

sign and submit the form electronically or in hardcopy to EPA; and

file a copy of the MOU. 

In completing the pre-populated spreadsheets, respondents will:

review the spreadsheet and instructions;

gather information;

complete or update information in the spreadsheet;

e-mail or mail the spreadsheet to EPA; and

file a copy of the spreadsheet.

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

gather information; and

provide information via the LMOP Web site, e-mail, 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 MOU;

return a copy of the signed MOU to the Partner;

enter the information into a database; and

file the MOU.

In requesting and receiving information through a pre-populated
spreadsheet, the agency will:

populate the spreadsheet with landfill and/or project data specific to
the Partner or other landfill owners/operators and send the spreadsheet
via e-mail when an electronic address is available or via mail when an
electronic address is not available;

review the information provided and follow up if necessary;

enter information into a database; and

file the spreadsheet.

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

review the data; and

revise data in the database based on the update.

In initiating an information update, the agency will:

call or e-mail the 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 information
will be posted on the LMOP Web site where it can be reviewed for
accuracy by the Partner and revised if necessary. Spreadsheets will be
e-mailed to all Industry Developer and Community Partners. When an
e-mail address is available, spreadsheets will be e-mailed to other
landfill owners/operators. To maximize electronic communication, LMOP
will spend time reviewing appropriate Web sites for e-mail addresses for
other landfill owner/operator contacts. If no e-mail address is
available, LMOP will mail a cover letter and pre-populated spreadsheet
printout to the other landfill owner/operator and will offer to e-mail
an electronic copy of the spreadsheet if the landfill owner/operator
sends their e-mail address. The landfill owner/operator can e-mail LMOP
with the updates or mail a hardcopy of the completed spreadsheet back to
LMOP.

All information received through the spreadsheets (electronically or via
hard copy) will be reviewed by EPA before being entered into the
Landfill and Landfill Gas Energy Project database.

Small Entity Flexibility

EPA expects that some LMOP Partners and other landfill owners/operators
are small entities. LMOP reviewed company Web sites and organization
descriptions when available for all Energy Partners and a portion of
Industry Partners to help determine the companies' small entity status.
LMOP determined whether Community Partners are small entities based on
the population served by these government agencies as further described
below. LMOP assumed for this estimate of small entities that all State
Partners, which represent State governments, are not classified as small
entities, since each State population is greater than 50,000. LMOP also
assumed that all of its Endorsers, which are non-profits, were
classified as small entities. For other respondents, LMOP assumed that
public sector landfill owners/operators would have the same distribution
of small entities as Community Partners, and private sector landfill
owners/operators would have the same distribution of small entities as
Industry non-developer Partners. As a result of these estimates and
assumptions, LMOP estimated the number of small entities affected per
year according to the type of respondent, as shown in Table 5. The
numbers in Table 5 reflect LMOP’s assumption that the distribution of
small entities within each new Partner category will be similar to the
distribution analyzed for each existing Partner category.

Table 5: Estimate of Small Entities for Each Respondent Category

Respondent Category	New	Existing

State Partners	0	0

Community Partners	1	10

Endorsers	3	26

Energy	2	18

Industry Partner, developers	4	26

Industry Partner, non-developers	11	76

Other (public sector)	0	72

Other (private sector)	0	40

Total	20	258

 

For Community Partners, which represent local or regional government
entities, LMOP reviewed the list of Community Partners and compared it
to a table corresponding to 2006 city or county populations in order to
determine the small entity status. Approximately nine percent of
existing Community Partners were in cities or counties with populations
less than 50,000, which is the threshold for small entities within the
public administration sector.

The majority of Energy Partners are power providers, marketers, or
energy end users. Within the power provider sector, the only small
businesses are a number of rural cooperatives that have joined as
Partners; the rest of the power providers are utilities or power
marketers that are large businesses. Within the energy end-user sector,
many of the companies are large corporations such as Wal-Mart, PepsiCo,
Ajinomoto, and Nucor Steel, which have a larger energy demand.
Approximately seven small businesses, such as Ohio Valley Creative
Energy and Novus Energy, have a single facility that uses LFG to meet
its energy needs.

 	Given the large number of Industry Partners, LMOP reviewed Web sites
and organization descriptions for 58% of the project developer Partners
and 51% of the non-developer Partners. The companies whose Web sites
were not reviewed were assumed to contain a similar percentage of
small businesses to those reviewed. Within the developer category, a
majority of these Partners have a national presence in the LFG industry
and are involved in multiple projects, likely meeting the size criteria
for large businesses, and thus are not considered small businesses.
Seventeen percent of the developers reviewed were classified as a small
business. Most of these small businesses serve a small niche market,
have an obvious small number of employees, or work within a small
service region. The non-developer Industry Partner category includes
manufacturers or suppliers of equipment or expertise needed to collect
and utilize LFG. Again, a majority of these businesses are large and
supply multiple solid waste facilities with the engineering, equipment,
or construction services needed to build and maintain a LFGE project or
LFG collection system. Based on a review of Web sites, 20% of
non-developers were classified as small businesses; these businesses may
include smaller local engineering companies, or other niche products
that are not needed in all LFGE applications.

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, LMOP has reduced the
number of data fields requested from Industry Developer Partners and
Community Partners. Additionally, LMOP no longer requests updates on
LFGE project data from Energy Partners. LMOP also polled Partners on the
preferred format for making updates to project data, and Partners
considered the pre-populated spreadsheet to be more efficient or no less
efficient than the old online forms. Participation in LMOP is voluntary.
Any small entity that finds the information collection overly burdensome
is not required to participate.

Collection Schedule

EPA will collect general information in the MOU, which are completed and
submitted by each Partner upon their agreement to participate in the
program. EPA will collect additional information through pre-populated
spreadsheets. These spreadsheets will be completed annually by Industry
Developer Partners and Community Partners. Information may also be
updated periodically at the request of EPA or the Partner. For other
landfill owners/operators, EPA will conduct a one-time information
collection using pre-populated spreadsheets.

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 number of data fields has been reduced and
the collection methodology was simplified. Cost estimates were increased
to account for an increase in wages and the number of Partners.
Attachment A presents the estimated average annual Partner respondent
burden and costs during the next 3-year ICR period for each type of
Partner. Attachment B presents the estimated first year (and only year)
of other owners/operators' respondent burden and costs for information
collection activities associated with LMOP. Table 6 presents a summary
of the respondent burden.

Estimating Respondent Costs

Estimating Labor Costs

For private-sector respondents (Industry and Energy Partners and other
privately-owned or operated landfills), EPA used a national average
hourly labor rate (hourly rate plus 110% overhead) of $124.74 for legal
staff, $105.26 for managerial staff, $78.22 for technical staff, and
$43.51 for clerical staff. Managerial, technical, and clerical labor
rates were obtained from the Bureau of Labor and Statistics average
rates for Professional, Scientific, and Technical Services (NAICS code
541000). Legal rates were based on lawyers, management wages were based
on managers (all other), technical wages were based on environmental
engineers, and clerical rates were based on executive secretaries and
administrative assistants for May 2006. A June 2007 labor rate for all
rates was estimated by applying a 3.5% growth factor from the Employment
Cost Index to account for increases in wages from June 2006 to June
2007. The Employment Cost Index for wages and salaries, by ownership,
occupational group, and industry is located at:
http://www.bls.gov/news.release/eci.t02.htm.

 For public-sector respondents (Community and State Partners, and other
publicly-owned or operated landfills), 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 in 2000 and using them for all
public-sector employees provides consistency. 

For non-profit sector respondents (Endorsers), EPA used a national
average hourly labor rate (hourly rate plus 110% overhead) of $113.06
for legal staff, $85.46 for managerial staff, $86.59 for technical
staff, and $42.01 for clerical staff. Managerial, technical, and
clerical labor rates were obtained from the Bureau of Labor and
Statistics average rates for Business, Professional, Labor, Political,
and Similar Organizations (NAICS code 813900). Legal rates were based on
lawyers, management wages were based on managers (all other), technical
wages were based on environmental engineers, and clerical rates were
based on executive secretaries and administrative assistants for May
2006. A June 2007 labor rate for all rates was estimated by applying a
3.5% growth factor from the Employment Cost Index to account for
increases in wages from June 2006 to June 2007. The Employment Cost
Index for wages and salaries, by ownership, occupational group, and
industry is located at:   HYPERLINK
"http://www.bls.gov/news.release/eci.t02.htm" 
http://www.bls.gov/news.release/eci.t02.htm .

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. 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 potentially necessary to mail in the MOU and possibly
spreadsheets. A postage cost of $3.00 is attributed to all activities
involving mailing materials to account for the use of trackable mail. It
is assumed that all LFGE project data updates from Community and
Industry Developer Partners will be submitted electronically, so their
only trackable mail costs are associated with submitting their MOU. It
is assumed that some of the other landfill owners/operators will submit
their one-time only spreadsheet updates by mail. The average annual O&M
cost over three years is $342.

Table 6: Summary of Respondent Burden





New	Existing

	 	Partner	Average Annual Burden	Total for 3-year ICR Period

Hours	Community	149	668	2,450

	Endorser	6	10	47

	Energy and Industry Non-Developer	228	608	2,505

	Industry Project Developer	456	1,178	4,901

	State	2	16	54

	Subtotal Hours	840	2,479	9,956

	Average Burden per Partner	7.4	3.0	-- 

	Other Landfill Owners/Operators1

	Public owners and/or operators	1,333	0	4,000

	Private owners and/or operators	1,233	0	3,700

	Subtotal Hours	2,567	0	7,700

	Average Burden per Landfill Owner/Operator	7.7	--	7.7

	Total Hours	3,406	2,479	17,656

	Average Burden per Respondent	7.6	3.0	 --

Cost	Partner

	Community	$6,913	$30,381	$111,881

	Endorser	$460	$844	$3,913

	Energy and Industry Non-Developer	$19,365	$47,521	$200,660

	Industry Project Developer	$33,856	$88,927	$368,348

	State	$110	$770	$2,640

	Subtotal Cost	$60,703	$168,444	$687,442

	Average Cost per Partner	$532	$203	 --

	Other Landfill Owners/Operators1

	Public owners and/or operators	$61,203	$0	$183,610

	Private owners and/or operators	$54,477	$0	$163,430

	Subtotal Cost	$115,680	$0	$347,039

	Average Cost per Landfill Owner/Operator	$347	--	$347

	Total Cost	$176,383	$168,444	$1,034,482

	Average Labor and O&M Cost per Respondent	$394	$203	-- 

1 For other landfill owners/operators, burden and costs are only
associated with 2008. To get an average annual burden for the 3-year ICR
period, the 2008 burden was divided by 3.

Estimating Agency Burden and Costs

Attachment C presents the estimated Agency burden hours and costs for
the information collection activities associated with LMOP. Table 7
presents a summary of the agency burden. EPA estimates an average hourly
labor cost (labor plus 60% for overhead) of $71.34 for managerial staff,
$48.91 for technical staff, and $19.65 for clerical staff. To derive
these estimates, EPA used the “Salary Table 2007 - 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

Table 7: Summary of Agency Burden

 	2008	2009	2010	Average	Total

Hours	4,001	1,401	1,551	2,318	6,953

Cost	$190,352	$67,485	$74,822	$110,886	$332,658



Estimating the Respondent Universe

The number of LMOP Partners has grown significantly since the last ICR
renewal. Table 8 presents a summary of the respondent universe by LMOP
Partner category for the next 3-year ICR period. The burden estimates
are based on the total respondent universe. The historical response
rates to previous LMOP ICRs are approximately 30%.

Table 8: Summary of LMOP Partners and Other Respondents

 	2008 	2009 	2010 	Average

Partner	Existing	New	Existing	New	Existing	New	Existing	New

Community1	108	19 	127	19 	146	19 	127	19 

Endorser2	23	3 	26	3 	29	3 	26	3 

Energy1	93	14 	107	14 	121	14 	107	14 

Industry1	 	 	 	 	 	 	 	 

   non-developers	323	56 	379	56 	435	56 	379	56 

   developers	131	21 	152	21 	173	21 	152	21 

State3	40	1 	41	1 	42	1 	41	1 

TOTAL	718	114	832	114	946	114	832	114

Other LF Owner/Oper.	0 	1,000	0	0 	0	0 	0	333

1 Staff with experience in managing the LMOP Partner database provided
insight on future program growth by Partner category. The number of new
Community, Industry, and Energy Partners increased significantly from
2004 to 2005, and again from 2005 to 2006. The number of new Partners
anticipated for both 2007 and 2008 is expected to be similar to the
number of Partners that joined in 2006. Higher numbers of Partners are
expected in the future due to: enhanced media coverage of LFG energy,
climate change, and LMOP in recent months, and the benefit of improved
LMOP resources for Partners-only such as LFGcost-Web. Additionally,
planned outreach to the 1,000 other landfill owners/operators with
landfills potentially able to support LFG energy will introduce many
communities to LMOP.

2 The number of new Endorsers was assumed to equal an average of the
number of Endorsers that joined during the 3-year period from 2004 to
2006. 

3 Staff with experience in managing the LMOP Partner database provided
insight on future program growth by Partner category. The number of new
State Partners is anticipated to be one per year. The majority of states
have already joined LMOP and there is not expected to be any significant
increase in the growth rate during this 3-year ICR period.

Bottom Line Burden Hours and Costs

Over the 3-year period covered by this ICR, EPA estimates the respondent
burden of the program to be 17,656 hours and $1,034,482, of which $4,026
is O&M. EPA estimates the Agency burden to be 6,953 hours and $332,658.
The total annual burden, averaged over the three-year period, is 5,885
hours and $344,827, of which $1,342 is O&M for respondents, and 2,318
hours and $110,886 for EPA.

The total burden for existing Partner respondents will increase
gradually over each year of the 3-year ICR period to reflect an increase
in the total number of existing Partners, although the burden per
respondent will remain constant. The burden and costs shown for each
existing Partner category in Attachment A reflect the average number of
Partners during the 3-year ICR period. The bottom line burden for new
Partners will stay the same for each year of this ICR, since the number
of new Partners joining each year is expected to remain relatively
constant over the 3-year ICR period. The bottom line burden and costs
for other landfill owners/operators will exist only during the first
year of this ICR, since this is a one-time information collection
effort.

Reasons for Change in Burden

Under this renewal ICR, the total respondent burden over the 3-year
period is 17,656 

hours, or an average of 5,885 hours per year. Of this, the total burden
on LMOP Partners is 9,956 hours or 3,318 hours per year. The 2003 ICR
total burden was 4,598 hours, or an average of 1,533 per year. 

Since the last ICR renewal, LMOP no longer collects information annually
from Energy, State, and non-developer Industry Partners, the information
forms have been simplified into pre-populated spreadsheets, and other
collection efficiencies have been implemented such as the option to
submit MOUs electronically. As a result of these changes, the average
number of hours per Partner has decreased, but the total hourly burden
for LMOP Partners still increased because of an increase in the number
of Partners. For perspective on the magnitude of Partner growth, the
number of Partners at the end of 2003 was 365, whereas there were 675
Partners as of July 2007. In addition, 49 new Partners joined LMOP in
2004 while the number of new Partners in 2006 was 117. 

The remainder of the increase in total hourly burden is due to the
initiative to collect from other landfill owners/operators critical
landfill data that are necessary to evaluate the future potential of LFG
energy. This type of data collection has not occurred during LMOP’s
history.

The total cost estimate over the 3-year period for this renewal ICR is
$1,034,482, or an average of $344,827 per year, of which $4,026 is O&M
costs. The total cost to LMOP Partners is $687,442 ($1,026 is O&M), or
$229,148 ($342 is O&M) per year. In the previous 2003 ICR renewal, the
total cost over the 3-year period was $268,893. The total cost estimate
increase for Partners is due to an increase in the number of Partners
and increases in wages. The total cost estimate increase for other
landfill owners/operators is due to the planned initiative to collect
data from this new group of respondents.

Burden Statement

The overall annual public reporting and recordkeeping burden for this
collection of information is estimated to average 4.6 hours and $270 per
respondent. The burden per respondent is determined by which types of
information collection requests the respondent is affected. The average
annual burden for new LMOP Partners is 7.4 hours per respondent, the
average annual burden for existing Partners is 3.0 hours per respondent,
and the average burden for other landfill owners/operators is a one-time
burden of 7.7 hours per respondent. Over the 3-year period covered by
this ICR, EPA estimates the burden of the program to be 17,656 hours and
$1,034,482 for respondents, and 6,953 hours and $332,658 for EPA. 

Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, and disclose or provide
information to or for a Federal agency. This includes the time needed to
review instructions; develop, acquire, install, and utilize technology
and systems for the purposes of collecting, validating, and verifying
information, processing and maintaining information, and disclosing and
providing information; adjust the existing ways to comply with any
previously applicable instructions and requirements; train personnel to
be able to respond to a collection of information; search data sources;
complete and review the collection of information; and transmit or
otherwise disclose the information. An agency may not conduct or
sponsor, and a person is not required to respond to, a collection of
information unless it displays a currently valid OMB control number. The
OMB control numbers for EPA's regulations are listed in 40 CFR part 9
and 48 CFR chapter 15.

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 Industry Developer and
Community Partner activities associated with completing the
pre-populated spreadsheets is estimated to be 8.5 hours. The burden
ranges from 4 hours for existing Community Partners to 18.5 hours for
new Industry Partners who are developers. The burden estimate includes
time to review the spreadsheet and instructions, gather the requested
information, complete/update the spreadsheet, and submit the spreadsheet
to EPA. The burden for each type of Partner is shown in Attachment A and
the total burden is summarized in Table 6.

The average per facility reporting burden for activities associated with
periodic information updates is estimated to be 2.5 hours for Energy,
Industry, and Community Partners. The average per facility reporting
burden for activities associated with periodic information updates is
estimated to be 1 hour for State Partners and Endorsers. The burden
estimate includes time to gather the requested information and provide
the information to EPA.

The average per facility reporting burden for activities associated with
completing the other landfill owners/operators' pre-populated
spreadsheets is estimated to be 11.75 hours. The burden ranges from 5
hours for public-sector respondents (who likely have only a single
landfill) to 18.5 hours for private-sector respondents (who may have to
complete information for more than one site). 

To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a docket for this ICR under Docket ID
EPA-HQ-OAR-2003-0078, which is available for online viewing at
www.regulations.gov, or in hard copy at EPA Docket, EPA/DC, EPA West,
Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA/DC Public
Reading Room is open from 8 a.m. to 4:30 p.m., Monday through Friday,
excluding legal holidays. The telephone number for the Reading Room is
202-566-1744, and the telephone number for the Air and Radiation Docket
Center is 202-566-1742.

	An electronic version of the public docket is available at
www.regulations.gov. This site can be used to submit or view public
comments, access the index listing of the contents of the public docket,
and access those documents in the public docket that are available
electronically. In the system, select “search,” then key in the
Docket ID Number identified above. Alternatively, send comments to the
Office of Information and Regulatory Affairs, Office of Management and
Budget, 725 17th Street, NW, Washington, DC 20503, Attention: Desk
Office for EPA. Please include the EPA Docket ID No.
EPA-HQ-OAR-2003-0078 in any correspondence.ATTACHMENT A - ESTIMATED
AVERAGE RESPONDENT BURDEN AND COST

A-1 Existing State Partners

A-2 New State Partners

A-3 Existing Endorsers

A-4 New Endorsers

A-5 Existing Energy and Non-Developer Industry Partners

A-6 New Energy and Non-Developer Industry Partners

A-7 Existing Community Partners

A-8 New Community Partners 

A-9 Existing Project Developer Industry Partners

A-10 New Project Developer Industry Partners 

ATTACHMENT B - ESTIMATED YEAR 1 RESPONDENT BURDEN AND COST: 

B-1 Publicly-Owned and/or Operated Landfills with LFGE Potential 

B-2 Privately-Owned and/or Operated Landfills with LFGE Potential 

ATTACHMENT C - ESTIMATED AGENCY BURDEN AND COST 

C-1 Agency Burden 2008 

C-2 Agency Burden 2009 

C-3 Agency Burden 2010 

 http://www.census.gov/popest/datasets.html

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