Supporting
Statement
for
EPA
Information
Collection
Request
Number
2053.01
"
Information
Collection
Activities
Associated
with
the
Best
Workplaces
for
Commuters
Program"

April
30,
2004
Table
of
Contents
Part
A
1
Identification
of
the
Information
Collection
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1
1(
a)
Title
of
the
Information
Collection
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1
1(
b)
Short
Characterization/
Abstract
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1
2
Need
for
and
Use
of
the
Collection
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2
2(
a)
Need/
Authority
for
the
Collection
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2
2(
b)
Practical
Utility/
Users
of
the
Data
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3
3
Nonduplication,
Consultations,
and
Other
Collection
Criteria
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3
3(
a)
Nonduplication
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3
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
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3
3(
c)
Consultations
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4
3(
d)
Effects
of
Less
Frequent
Collections
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4
3(
e)
General
Guidelines
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4
3(
f)
Confidentiality
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5
3(
g)
Sensitive
Questions
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5
4
The
Respondents
and
the
Information
Requested
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5
4(
a)
Respondents
and
NAICS
Codes
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5
4(
b)
Information
Requested
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5
5
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
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7
5(
a)
Agency
Activities
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7
5(
b)
Collection
Methodology
and
Management
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8
5(
c)
Small
Entity
Flexibility
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9
5(
d)
Collection
Schedule
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9
6
Estimating
the
Burden
and
Cost
of
the
Collection
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9
6(
a)
Estimating
Respondent
Burden
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9
6(
b)
Estimating
Respondent
Costs
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9
6(
c)
Estimating
Agency
Burden
and
Costs
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10
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
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10
6(
e)
Bottom
Line
Burden
Hours
and
Costs
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18
6(
f)
Reasons
for
Change
in
Burden
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18
6(
g)
Burden
Statement
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19
Part
B
1
Introduction
to
Part
B
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20
2
Survey
Objectives,
Key
Variables,
and
Survey
Design
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20
3
Pretests,
Pilot
Tests,
Collection
Methods,
and
Analyzing
Survey
Results
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21
APPENDIX
A:
LIST
OF
THE
NAICS
CODES
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A­
1
APPENDIX
B:
BWC
APPLICATION
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B­
1
APPENDIX
C:
ANNUAL
CHECK­
IN
FORM
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C­
1
APPENDIX
D:
EMPLOYEE
SURVEY
AND
RELATED
QUESTIONNAIRES
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D­
1
1
Part
A
1
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
This
Information
Collection
Request
(
ICR)
is
entitled
"
Information
Collection
Activities
Associated
with
the
Best
Workplaces
for
Commuters
Program,"
EPA
ICR
Number
2053.01.

1(
b)
Short
Characterization/
Abstract
Best
Workplaces
for
CommutersSM
(
BWC;
originally
known
as
the
Commuter
Choice
Leadership
Initiative)
is
a
unique
designation
granted
by
the
U.
S.
Environmental
Protection
Agency
(
EPA)
and
the
U.
S.
Department
of
Transportation
(
DOT)
to
employers
that
offer
superior
commuter
benefits
to
their
employees.
These
benefits
give
employees
incentives
to
commute
by
means
other
than
driving
alone,
and
hence
reduce
vehicle
miles
of
travel
and
vehicle
emissions.
EPA
is
partnering
with
a
variety
of
national,
state,
regional,
and
local
organizations
to
challenge
U.
S.
employers
to
meet
a
National
Standard
of
Excellence
in
commuter
benefits
and
to
recognize
those
that
do
as
"
Best
Workplaces
for
Commuters."
The
program
highlights
the
environmental
and
congestion
relief
benefits
along
with
the
potential
financial
benefits
of
offering
employee
commuter
benefits,
such
as
improved
recruiting
and
retention,
tax
savings,
and
other
cost
savings.
EPA
works
to
gain
public
recognition
for
companies
recognized
as
Best
Workplaces
for
Commuters
and
provides
networking
opportunities,
training,
web­
based
tools,
and
one­
on­
one
assistance
for
its
partners.

This
ICR
covers
the
reporting
activities
associated
with
an
employer's
participation
in
BWC.
Employers
must
provide
data
for
three
discrete
information
collections.
Each
of
these
is
discussed
separately
below
and
throughout
the
ICR.
There
are
no
record
keeping
requirements.

Best
Workplaces
for
Commuters
Application
Prospective
BWC
Employer
must
complete
and
submit
the
BWC
Application,
which
outlines
the
qualification
for
an
employer
to
receive
the
BWC
designation
including
promoting
the
availability
of
commuter
benefits
to
their
employees,
providing
those
benefits,
and
reporting
on
program
progress
and
success.
In
addition,
the
Application
requires
an
employer
to
designate
a
central
point
of
contact
and
register
their
specific
work
sites
covered
by
the
BWC
designation.
Employers
need
only
submit
one
BWC
Application,
and
may
amend
it
to
add
more
work
sites.
Employers
can
apply
online
at
http://
www.
ergweb.
com/
projects/
ccli/
enroll/
enroll.
htm.
In
addition,
employers
may
submit
historical
information
about
their
employees'
commuting
habits
prior
to
becoming
a
BWC
Employer.
2
Best
Workplaces
for
Commuters
Annual
Check­
in
Form
Employers
must
complete
and
submit
the
BWC
Annual
Check­
in
Form
for
each
registered
work
site
during
a
month
they
specify
in
their
Application
and
each
year
thereafter,
around
the
same
general
time.
Each
BWC
Employer
is
directed
by
an
e­
mail
message
to
a
secure
web
site
where
their
unique
Annual
Check­
in
Form,
each
of
which
has
an
employer­
specific
password
that
is
given
only
to
the
employer,
can
be
found
pre­
populated
with
information
from
their
earlier
BWC
Application,
including
contact
information
for
the
primary
point
of
contact,
the
types
of
benefits
offered,
and
the
number
of
employees
covered
by
the
commuter
benefits.
The
Annual
Check­
in
Form
also
includes
optional
information
on
the
number
of
employees
taking
advantage
of
the
employers'
commuter
benefits
and
asks
the
employer
to
certify
that
the
minimum
benchmark
of
fourteen
percent
of
their
employees
commuting
by
means
other
than
driving
alone
is
being
met.

Best
Workplaces
for
Commuters
Employee
Survey
In
order
to
gather
information
by
which
to
develop
estimates
of
the
congestion
reduction
and
air
quality
benefits
of
BWC,
EPA
will
conduct
annual
scientific
surveys
of
employees
at
a
small
group
of
randomly
selected
employers
to
determine
their
commuting
habits
and
compare
them
with
the
commuting
habits
of
a
randomly
selected
sample
of
similar
commuters
who
do
not
receive
commuter
benefits.
The
primary
means
of
administering
the
survey
will
be
via
the
internet.
There
is
also
a
short
set
of
questions
for
the
primary
point
of
contact
at
the
BWC
work
site
providing
EPA
some
additional
background
information
on
the
commuter
benefits
program.
Finally
there
is
also
a
survey
administered
to
a
randomly
selected
group
of
commuters,
not
employed
by
BWC
employers,
who
do
not
receive
commuter
benefits,
to
derive
a
benchmark
against
which
to
compare
the
effects
of
the
BWC
program.
Development
of
the
survey
is
discussed
in
detail
in
Part
B.

2
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
In
February
2002,
the
Administration
announced
a
commitment
to
reduce
greenhouse
gas
intensity
in
the
United
States
by
18
percent
by
2012
(
equivalent
to
a
reduction
of
more
than
100
million
metric
tons
of
greenhouse
gas
emissions
in
that
year)
through
voluntary,
incentive­
based,
and
existing
mandatory
measures.
With
respect
to
transportation
actions,
the
Administration's
plan
commits
to
prevent
13
Million
Metric
Tons
Carbon
Equivalent
(
MMTCE)
in
2012,
in
addition
to
the
2
MMTCE
prevented
annually
as
of
2002.
In
addition,
section
103
of
the
Clean
Air
Act
requires
EPA
to
develop
a
national
research
and
development
program
to,
among
other
things,
"
conduct
and
promote
coordination
and
acceleration
of
training
for
individuals
relating
to
the
causes,
effects,
extent,
prevention,
and
control
of
air
pollution."
BWC
is
an
important
part
of
the
overall
effort
to
develop,
implement,
and
evaluate
innovative
transportation
strategies
in
promoting
public
awareness
of
air
pollution
prevention,
reducing
Vehicle
Miles
Traveled
(
VMT)
3
and
greenhouse
gas
emissions,
and
meeting
Clean
Air
Act
air
quality
standards.

As
described
in
this
ICR,
EPA
needs
to
collect
information
from
employers
to
establish
participation
in
BWC,
to
develop
a
baseline
on
employee
commuter
benefits
and
commuting
habits,
to
ensure
minimum
employee
participation,
to
develop
and
promote
employee
commuter
benefit
programs,
to
provide
support
for
and
recognize
BWC
Employers,
and
to
monitor
and
measure
the
success
of
the
BWC
program.

2(
b)
Practical
Utility/
Users
of
the
Data
EPA
will
use
the
information
collected
from
BWC
Employers
for
a
variety
of
purposes.
EPA
will
use
information
from
the
Application
to
establish
participation
in
BWC
and
to
gather
contact
information
for
BWC
Employers
and
their
registered
work
sites.
EPA
will
use
the
information
on
the
annual
Check­
in
Form
to
ensure
minimum
employee
participation,
to
establish
a
baseline
for
commuting
habits
and
commuter
benefits,
to
develop
and
promote
employee
commuter
benefit
programs,
to
provide
support
for
and
recognize
employers,
and
to
monitor
and
measure
the
success
of
BWC.
EPA
also
will
use
Check­
in
information
to
update
the
Agency's
records
of
Best
Workplaces
for
Commuter
Employer
contact
information.
EPA
will
use
the
information
from
the
Employee
Surveys
to
evaluate
the
environmental
impact
of
the
Best
Workplaces
for
Commuters
Program
and
to
better
understand
the
commuting
habits
of
employees,
how
BWC
programs
and
benefits
affect
that
behavior,
and
what
might
be
changed
in
or
added
to
BWC
programs.

3
Nonduplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Nonduplication
Neither
EPA
nor
any
other
Federal
Agency
or
Department
has
collected
the
information
covered
by
this
ICR.
EPA
needs
this
information
to
establish
participation
in
BWC,
to
establish
a
baseline
of
commuting
habits,
and
to
develop,
implement,
and
evaluate
BWC
programs
and
benefits.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
To
comply
with
the
Paperwork
Reduction
Act
of
1995,
EPA
issued
a
public
notice
in
the
Federal
Register
on
April
9,
2002
[
FRL­
7169­
2].
The
public
comment
period
extended
through
June
10,
2002.
EPA
received
no
public
comments.
4
3(
c)
Consultations
In
preparing
respondent
burden
hour
and
cost
estimates
in
this
ICR,
EPA
conducted
consultations
with
the
following
six
prospective
BWC
Employers:

S
Chevron,

S
City
of
Aspen,

S
County
of
Westchester
Commute
Alternatives
Program,

S
Downtown
Denver
Partnership,

S
ICF
Consulting,
and
S
Wheels,
Inc.

As
discussed
in
Part
B,
additional
consultations
have
occurred
in
developing
the
replacement
Employer
Survey
and
its
smaller,
random­
sampling
plan
compared
with
EPA's
original
ICR
proposal.

3(
d)
Effects
of
Less
Frequent
Collections
The
BWC
Application
is
a
one­
time
information
submittal;
less
frequent
collection
is
not
possible.
Best
Workplaces
for
Commuters'
Employers
(
BWC
Employers)
may
amend
the
Application
to
add
more
work
sites.

The
annual
Check­
in
Form
is
used
to
develop
and
promote
Best
Workplaces
for
Commuters
programs,
to
provide
support
for
and
recognize
employers,
and
to
monitor
and
measure
the
success
of
an
employer's
BWC
program.
In
addition,
EPA
will
use
information
on
the
Check­
in
Form
to
update
the
Agency's
records
of
BWC
employer
contact
information.
EPA
believes
that
any
reduction
in
the
frequency
of
this
information
collection
would
have
a
negative
impact
on
program
development,
implementation,
customer
support
activities,
and
evaluation.

The
Employee
Survey
solicits
the
minimal
amount
of
information
needed
to
develop
a
basic
understanding
of
the
effectiveness
of
the
program,
measured
in
terms
of
the
number
of
commuter
benefits
that
employers
provide
and
the
number
of
employees
who
take
advantage
of
these
benefits
over
time.
EPA
already
has
reduced
the
scale
of
this
collection
from
a
census
of
all
BWC
employers
to
a
random­
subset
collection
and
believes
that
any
reduction
in
the
frequency
will
dilute
its
value
and
diminish
the
Agency's
ability
to
measure
the
overall
effectiveness
of
the
program.

3(
e)
General
Guidelines
The
BWC
information
collections
described
in
this
ICR
do
not
violate
any
of
OMB's
General
Guidelines.
In
fact,
BWC
information
collections
are
reported
once
or
annually.
In
addition,
there
are
no
recordkeeping
requirements.
5
3(
f)
Confidentiality
This
information
collection
does
not
require
employers
to
disclose
any
confidential
business
information
nor
employees
to
disclose
any
personal
information.
In
addition,
BWC
is
a
voluntary
program
that
only
requires
general
information
on
commuter
benefits
and
habits.
Further,
EPA
intends
to
summarize
and
present
only
aggregated
data
on
commuter
benefits
and
habits.
However,
from
time
to
time,
EPA
intends
to
publicize
the
success
of
BWC
and
of
certain
employers;
EPA
will
do
so
with
the
employers'
knowledge
and
consent.

3(
g)
Sensitive
Questions
The
information
collections
covered
by
this
ICR,
including
the
Employee
Survey,
do
not
ask
sensitive
questions,
such
as
those
pertaining
to
sexual
attitudes
or
behavior
or
religious
beliefs.

4
The
Respondents
and
the
Information
Requested
4(
a)
Respondents
and
NAICS
Codes
Refer
to
Appendix
A
for
a
list
of
the
North
American
Industrial
Classification
System
(
NAICS)
codes
associated
with
employers
most
likely
to
join
BWC.

4(
b)
Information
Requested
BWC
Employers
must
report
information
associated
with
three
discrete
information
collections.
Each
of
these
three
information
collections,
along
with
their
data
items
and
respondent
activities,
are
described
separately
below.
There
are
no
recordkeeping
requirements.

4(
b)(
i)
Data
Items
Best
Workplaces
for
Commuters
Application
The
Application
confirms
the
participation
of
the
employer
in
BWC.
The
Application
includes
contact
information
for
the
authorized
representative
and
additional
employer
contacts,
information
on
employer
work
sites,
and
the
option
of
providing
the
company
logo
or
other
company
marks
for
EPA's
use
in
its
recognition
and
marketing
materials.
This
form
is
available
electronically
on
the
BWC
website.
A
copy
of
the
BWC
Application
is
included
in
Appendix
B.

Annual
Check­
in
Form
The
Annual
Check­
in
Form
is
divided
into
three
sections.
Section
I
covers
updates
to
employer
contact
information.
Section
II
includes
two
questions
concerning
how
employers
centralize
their
information
about
commuter
benefits
and
how
they
communicate
this
information
6
to
their
employees.
Section
II
also
includes
lists
of
primary
and
secondary
commuter
benefits
employers
provide
to
their
employees.
Finally,
employers
have
the
option
to
provide
with
their
initial
report
historical
information
about
their
employees'
commuting
habits
prior
to
joining
BWC.
This
form
is
available
electronically
and
is
pre­
populated
for
participating
employers
to
confirm
and
update.
A
copy
of
the
Annual
Check­
in
Form
is
included
in
Appendix
C.

Employee
Survey
The
Employee
Survey
asks
for
the
mode(
s)
of
transportation
employees
use
to
commute
to
work
each
day
during
a
particular
week.
It
also
asks
how
far
they
must
commute,
and
asks
some
questions
to
determine
their
awareness
of
their
employer's
commuter
benefits
programs,
their
past
commuting
behaviors
and
what
factors
motivated
their
choice
of
commute
mode.
This
form
is
distributed
electronically.
A
similar
survey
is
administered
by
telephone
to
a
randomly
selected
group
of
commuters
who
do
not
receive
commuter
benefits.
There
is
also
a
set
of
questions
asked
of
the
work
site
primary
point
of
contact
to
obtain
additional
background
information
on
the
company's
benefits
program.
Copies
of
these
survey
forms
are
included
in
Appendix
D.

4(
b)(
ii)
Respondent
Activities
Best
Workplaces
for
Commuters
Application
BWC
Employers
perform
the
following
activities
once
to
execute
the
Application
and
establish
participation
in
the
program.
However,
the
Application
may
be
amended
to
add
more
work
sites.

°
Receive
and
read
the
Application
and
informational
materials;
°
Provide
the
required
information
on
the
Application;
and
°
Submit
the
Application
electronically
(
alternatively,
it
may
be
faxed
or
mailed).

Annual
Check­
in
Form
Each
year,
BWC
Employers
complete
and
submit
Sections
I
and
II
of
the
Check­
in
Form
for
each
registered
work
site.
In
addition,
employers
have
the
option
to
provide
with
their
initial
report
historical
information
about
their
employees'
commuting
habits.
Specifically,
employers
perform
the
following
activities
associated
with
the
Annual
Check­
in
Form:

°
Read
the
instructions
for
the
Annual
Check­
in
Form;
°
Update
contact
information
and
complete
Section
I
(
annually);
°
Gather
information
on
commuter
benefits
and
complete
Section
II
(
annually);
°
Provide
historical
information
(
optional);
and
°
Electronically
send
the
Check­
in
Form.
7
Employee
Survey
When
selected
as
part
of
the
annual
random
sample,
BWC
Employers
perform
the
following
activities
to
survey
their
employees
on
their
commuting
habits:

°
Complete
the
Questionnaire
for
the
BWC
Contact
prior
to,
or
concurrently
with
the
administration
of
the
survey
to
all
employees
at
work
sites
up
to
750
employees
and
to
a
percentage
of
employees
at
larger
worksites.
°
Distribute
survey
to
their
employees
for
completion;
°
Assist
their
employees
in
completing
the
survey,
if
necessary,
and
°
Return
completed
surveys
to
EPA
(
or
designated
contractor)
for
analysis.

In
order
to
obtain
a
baseline
against
which
to
measure
the
effects
of
the
BWC
program,
a
group
of
commuters
not
employed
by
BWC
employers,
who
do
not
receive
employer­
provided
commuter
benefits
will
be
selected
at
random
to
be
surveyed
by
telephone.

5
Information
Collected:
Agency
Activities,
Collection
Methodology,
and
Information
Management
5(
a)
Agency
Activities
EPA
will
perform
certain
activities
associated
with
each
of
the
three
discrete
information
collections
described
in
this
ICR
to
develop,
implement,
and
evaluate
BWC.
Each
of
these
three
information
collections,
and
the
Agency's
activities
associated
with
them,
are
described
in
more
detail
below.

Best
Workplaces
for
Commuters
Application
EPA
will
perform
the
following
activities
related
to
the
BWC
Application
and
any
amendments
to
it:

°
Develop
the
Application
and
associated
information
materials;
°
Disseminate
the
Application;
°
Review
completed
Applications
received
from
BWC
Employers;
°
Enter
information
from
the
Applications
and
Amendments
into
an
internal
EPA
database;
and
°
Provide
technical
assistance
to
employers
as
needed.
8
Annual
Check­
in
Form
EPA
will
perform
the
following
activities
related
to
the
Annual
Check­
in
Form:

°
Develop
the
Annual
Check­
in
Form
and
associated
instructions;
°
Send
e­
mail
reminders
to
complete
the
Annual
Check­
in
Form
with
instructions
on
how
to
log
on
to
the
secure
web
site;
°
Review
the
initial
and
subsequent
Annual
Check­
in
Forms;
°
Review
any
historical
information
provided
by
BWC
Employers;
°
Enter
information
from
the
Check­
in
Forms
into
an
internal
EPA
database
and
analyze
results;
and
°
Provide
technical
assistance
to
employer
representatives
as
needed.

Employee
Survey
Annually,
EPA
will
perform
the
following
activities
associated
with
the
Employee
Survey:

°
Design
a
sampling
plan
meeting
employer
size
distribution
criteria;
°
Design
the
survey
form;
°
Develop
a
data
collection
tool
using
an
automated
system;
°
Develop
instructions
for
completing
the
survey;
°
Randomly
select
employers
to
participate,
contact
them,
obtain
their
assistance
to
help
notify
employees
of
the
survey
and
the
web
address
for
completing
it,
ask
the
questions
for
the
BWC
primary
contact;
and
°
Enter
information
from
the
survey
form
into
an
internal
EPA
database
and
analyze
the
results.

Further
information
on
the
survey
plan
is
found
in
Part
B.

5(
b)
Collection
Methodology
and
Management
EPA
has
taken
steps
to
ensure
that
the
information
being
collected
under
this
ICR
will
be
accurate,
reliable,
and
retrievable.
Specifically,
EPA
has
developed
data
collection
instruments
that
are
simple,
structured,
and
easy
to
fill
out.
In
collecting
and
analyzing
the
information
under
this
ICR,
EPA
will
use
state­
of­
the­
art
phone
systems,
personal
computers,
and
database
software.
EPA
will
ensure
the
accuracy
and
completeness
of
collected
information
by
reviewing
each
submittal.
EPA
will
enter
the
information
provided
into
an
internal
EPA
database
to
implement,
evaluate,
and
disseminate
information
about
BWC.
9
5(
c)
Small
Entity
Flexibility
The
collection
methodology
should
not
impose
any
undue
burden
on
small
entities.
In
fact,
small
entities
will
likely
incur
a
much
smaller
burden
than
other
entities,
due
to
the
fact
that
they
have
fewer
employees
on
whom
to
report
in
the
Annual
Check­
in
Forms.
In
addition,
the
Application
to
join
BWC
is
voluntary.

5(
d)
Collection
Schedule
EPA
collects
information
from
the
BWC
Application
once.
However,
EPA
may
collect
additional
information
if
an
employer
chooses
to
amend
this
Application
to
add
more
work
sites.
EPA
collects
information
in
Sections
I
and
II
of
the
Check­
in
Form
each
year.
In
addition,
EPA
collects
information
from
the
Employee
Surveys
through
random
sampling
of
a
subset
of
participating
employers
every
year.
Finally,
EPA
may
collect
historical
information
on
commuting
habits
from
employers
who
have
such
information
and
provide
it
with
their
Check­
in
Form.

6
Estimating
the
Burden
and
Cost
of
the
Collection
6(
a)
Estimating
Respondent
Burden
EPA
estimates
the
respondent
burden
hours
for
all
information
collection
activities
covered
by
this
ICR
in
Exhibits
1
and
2,
except
for
the
negligible
activity
of
a
control
group
for
benchmarking
the
Employee
Survey
which
is
discussed
in
the
total
burden.
Each
exhibit
includes
the
number
of
hours
required
to
conduct
each
information
collection
activity.
Exhibit
1
summarizes
burden
hours
for
BWC
Employers
from
private
sector
firms,
while
Exhibit
2
summarizes
burden
for
BWC
Employers
that
are
state
and
local
governments.

6(
b)
Estimating
Respondent
Costs
In
Exhibits
1
and
2,
EPA
also
estimates
respondent
costs
associated
with
each
information
collection
requirement.
In
the
following
two
sections,
EPA
describes
the
cost
assumptions
used
in
these
exhibits.

6(
b)(
i)
Estimating
Labor
Costs
For
BWC
Employers
from
private
sector
firms,
EPA
estimates
an
average
hourly
respondent
labor
cost
(
including
overhead)
of
$
96.60
for
legal
staff;
$
74.38
for
managerial
staff,
$
58.31
for
technical
staff,
and
$
26.07
for
clerical
staff.
For
BWC
Employers
that
are
state
and
local
governments,
EPA
estimates
an
average
hourly
respondent
labor
cost
(
including
overhead)
of
$
44.37
for
legal
staff;
$
43.10
for
managerial
staff,
$
37.87
for
technical
staff,
and
$
22.42
for
clerical
staff.
To
arrive
at
these
estimates,
EPA
consulted
with
prospective
BWC
Employers
in
2001,
and
later
reviewed
employer
data
from
the
Bureau
of
Labor
Statistics
(
BLS)
and
applied
the
2002
and
2003
changes
in
total
compensation
for
private
sector
and
for
state
and
local
10
government
employees.

6(
b)(
ii)
Estimating
Capital
and
Operations
and
Maintenance
(
O&
M)
Costs
EPA
estimates
that
there
are
no
capital
costs
associated
with
any
of
the
information
collection
activities
in
this
ICR.
However,
EPA
estimates
that
BWC
Employers
will
incur
nominal
O&
M
costs
for
submitting
information
to
EPA.
These
O&
M
costs
are
expected
to
be
incurred
on
an
ongoing,
annual,
or
periodic
basis
per
the
associated
assumptions
for
reporting
in
this
ICR.
There
are
no
costs
associated
with
the
purchase
of
a
service
included
in
the
O&
M
costs.

Submittals
of
the
Application
and
Annual
Check­
in
Forms
will
be
made
via
internet
in
nearly
all
cases,
hence
the
only
costs
involved
are
staff
time.
A
cost
allowance
is
made
for
6%
of
the
Employee
Surveys
to
be
completed
manually;
EPA
estimates
that
BWC
Employers
will
incur
$
0.37
in
postage
costs
to
submit
those
surveys.

6(
c)
Estimating
Agency
Burden
and
Costs
As
shown
in
Exhibit
3,
EPA
estimates
the
annual
Agency
burden
and
costs
for
the
information
collection
activities
associated
with
BWC.
EPA
conducted
consultations
with
staff
who
work
on
BWC
to
obtain
estimates
of
the
hours
to
complete
each
information
collection
activity.
These
estimates
are
summarized
in
Exhibit
3.

EPA
estimates
an
average
hourly
labor
cost
of
$
76.85
for
legal
staff,
$
74.18
for
managerial
staff,
$
54.38
for
technical
staff,
and
$
21.84
for
clerical
staff.
These
labor
rates
are
based
on
the
following
GS
levels
and
steps:
GS
Level
15,
Step
1
for
legal
staff;
GS
Level
14,
Step
4
for
managerial
staff;
GS
Level
12,
Step
5
for
technical
staff;
and
GS
Level
5,
Step
1
for
clerical
staff
for
legal
staff
located
in
DC
and
for
all
other
staff
located
in
Ann
Arbor,
MI.
To
derive
the
hourly
labor
rates,
EPA
first
used
the
corresponding
hourly
basic
labor
rates
with
locality
pay
from
the
2004
General
Schedule
and
then
multiplied
these
rates
by
1.6,
the
standard
government
benefits
multiplier.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Respondent
Burden
and
Cost
Respondent
Universe
As
shown
in
Exhibits
1
and
2,
EPA
estimates
the
average
annual
universe
of
respondents
subject
to
the
BWC
information
collection
activities.
Specifically,
EPA
estimates
the
number
of
BWC
Employers
who
will
complete
each
of
the
three
discrete
information
collections.
In
addition,
EPA
also
estimates
in
these
same
exhibits,
the
average
annual
number
of
respondents
or
activities
associated
with
each
of
these
information
collections.
In
Tables
1
and
2,
EPA
first
presents
the
overall
universe
estimates
and
then,
in
Tables
3
to
7,
presents
the
specific
assumptions
used
in
developing
these
average
annual
universe
estimates
for
each
of
the
three
11
discrete
information
collections.

Over
the
three­
year
period
to
be
covered
by
this
ICR,
EPA
estimates
that
the
employers
joining
BWC
will
register
2,181
work
sites
according
to
the
schedule
in
Table
1.
As
such,
EPA
estimates
that
1,907
work
sites
will
come
from
private
sector
firms
and
the
other
274
will
come
from
state
and
local
governments.
For
private
sector
firms,
EPA
further
assumes
that
approximately
24
percent
of
the
work
sites
will
come
from
small
firms
with
fewer
than
50
employees,
33
percent
from
medium­
sized
firms
with
50
to
500
employees,
and
the
remaining
42
percent
from
large
firms
with
more
than
500
employees.

Table
1
Estimated
Average
Number
of
New
BWC
Employers'
Registered
Work
Sites
Employer
Type
Year
1
Year
2
Year
3
Total
Average
All
Private
Sector
Firms
840
478
589
1,907
636
Small
Firms
203
119
143
465
155
Medium­
sized
Firms
285
152
197
633
211
Large
Firms
353
208
249
809
270
State/
Local
Governments
119
70
84
274
91
All
Employers
959
549
673
2,181
727
In
the
first
year
(
see
Table
2),
the
number
of
voluntary
participants
is
expected
to
double
the
cumulative
participation
of
the
preceding
few
years
during
which
the
program
was
developed.

Table
2
Estimated
Cumulative
Number
of
BWC
Employers'
Registered
Work
Sites
Employer
Type
Year
1
Year
2
Year
3
All
Private
Sector
Firms
1,828
2,306
2,895
Small
Firms
441
560
703
Medium­
sized
Firms
619
771
968
Large
Firms
768
975
1,224
State/
Local
Governments
260
330
415
All
Employers
2,088
2,637
3,310
EPA
also
estimates
that
BWC
Employers
will
have
an
average
number
of
employees
per
registered
work
site
as
shown
as
in
Table
3.
12
Table
3
Average
Number
of
Employees
of
BWC
Employers
per
Registered
Work
Site
Employer
Type
Average
Number
of
Employees
Small
Firms
32
Medium­
sized
Firms
182
Large
Firms
3,172
State/
Local
Governments
1,564
Best
Workplaces
for
Commuters
Application
Based
on
the
projected
incremental
growth
rate
in
Table
1,
EPA
estimates
that
an
average
of
727
Applications
(
636
from
private
firms
and
91
from
state
and
local
governments)
will
be
submitted
for
each
of
the
three
years
covered
by
this
ICR.

Annual
Check­
in
Form
Based
on
Table
2
and
an
assumption
that
each
employer
will
start
submitting
the
Annual
Check­
in
Form
after
it
has
been
in
the
program
for
one
year,
EPA
estimates
that
an
average
of
1,951
employers
(
1,707
private
firms
and
244
state
and
local
governments)
will
complete
Annual
Check­
in
Forms
each
year
per
the
schedule
in
Table
4.

Table
4
Average
Number
of
Work
Sites
Completing
Annual
Check­
ins
Employer
Type
Year
1
Year
2
Year
3
Total
Average
All
Private
Sector
Firms
988
1,828
2,306
5,122
1,707
Small
Firms
238
441
560
1,239
413
Medium­
sized
Firms
335
619
771
1,725
575
Large
Firms
415
768
975
2,158
719
State/
Local
Governments
141
260
330
731
244
All
Employers
1,129
2,088
2,637
5,854
1,951
13
In
addition,
EPA
estimates
that
10
percent
of
all
employers
will
submit
historical
information
on
their
employees'
commuting
habits
for
each
of
their
registered
work
sites
with
their
Check­
in
Forms.
As
such,
EPA
estimates
that
an
average
70
BWC
Employers
(
60
private
firms
and
10
state
and
local
governments)
will
submit
historical
information
on
their
work
sites
each
year.

Employee
Survey
EPA
will
survey
100
randomly
selected
employers
per
year.
This
represents
roughly
nine
percent
of
employers
in
Year
1,
five
percent
in
Year
2,
and
four
percent
in
Year
3.

Table
5
Average
Number
of
Employees
Surveyed
Employer
Type
Year
1
Year
2
Year
3
Total
Average
All
Private
Sector
Firms
39,169
39,169
39,169
117,507
39,169
Small
Firms
(
32)
676
676
676
2,027
676
Medium­
sized
Firms
(
182)
5,397
5,397
5,397
16,192
5,397
Large
Firms
(
3,172)
33,096
33,096
33,096
99,288
33,096
State/
Local
Governments
(
1,564)
8,719
8,719
8,719
26,157
8,719
All
Employers
47,888
47,888
47,888
143,664
47,888
In
addition,
telephone
surveys
of
2,000
commuters
who
do
not
get
commuter
benefits
will
be
conducted
every
year.
Further
information
on
the
survey
plan
in
Part
B.

Based
in
part
on
BLS
data,
EPA
estimates
that
all
employees
fall
into
the
four
labor
categories
presented
in
this
ICR
based
on
the
percentages
shown
in
Table
6.

Table
6
Percentage
of
All
Employees
by
Labor
Category
Labor
Category
Percent
of
All
Employees
Legal
0.6
%

Managerial
9.8
%

Technical
56.3
%

Clerical
33.3
%

Further,
based
on
Tables
5
and
6,
EPA
estimates
the
average
annual
number
of
employees
14
surveyed
by
labor
category
and
employer
type
as
shown
in
Table
7.

Table
7
Average
Number
of
Employees
Surveyed
by
Labor
Category
and
Employer
Type
Labor
Category
Firms
State/
Local
Governments
Legal
(
0.6
%)
235
52
Managerial
(
9.8
%)
3,838
854
Technical
(
56.3
%)
22,052
4,908
Clerical
(
33.3
%)
13,043
2,903
EPA
will
solicit
the
employers'
assistance
in
notifying
their
employees
of
the
survey
and
the
web
location
for
taking
it.
However,
the
work
of
compiling
and
analyzing
the
results
will
be
done
by
EPA.

Total
Respondent
Burden
and
Costs
Using
the
assumptions
in
Tables
1
through
7
and
in
Sections
6(
a)
and
6(
b),
EPA
estimates
the
annual
respondent
burden
and
costs
for
BWC
Employers
from
private
sector
firms
and
state
and
local
governments
in
Exhibits
1
and
2,
respectively.
EPA
anticipates
receiving
50,666
BWC
responses
on
average
annually,
based
on
Tables
1,
4,
and
5
and
Exhibit
1.

In
addition,
a
control
group
of
2,000
commuters
not
employed
by
BWC
employers
and
who
receive
no
employer­
provided
commuter
benefits
will
be
selected
at
random
and
surveyed
by
telephone
to
obtain
a
benchmark
against
which
to
measure
the
effects
of
the
BWC
program
(
EPA
is
exploring
the
possibility
of
using
a
web
survey
for
this
group
as
well).
Each
completed
survey
will
take
five
minutes
to
perform,
hence
the
total
time
burden
to
the
affected
public
will
be
167
hours.
To
estimate
the
burden,
EPA
assumed
the
same
labor
category
distribution
as
in
Table
6,
and
the
costs
as
discussed
in
6(
b).

The
surveys
will
be
administered
by
EPA
or
a
contractor
to
EPA.
It
is
estimated
that
for
each
completed
interview
there
will
be
three
failed
attempts,
because
the
randomly
selected
individual
will
either
not
answer
the
telephone
or
refuse
to
participate.
Each
of
these
is
expected
to
take
half
a
minute
for
a
total
of
50
hours,
which
is
additive
to
the
167
hours
that
EPA
will
also
have
to
spend
to
complete
the
successful
surveys.
Additionally,
each
completed
survey
will
required
one
minute
to
enter
the
data
into
the
database
for
analysis,
for
a
total
of
33
hours.

See
Section
6(
e)
of
this
ICR
for
a
summary
of
all
this
information.
15
EXHIBIT
1
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST:
PRIVATE
SECTOR
FIRMS
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
INFORMATION
COLLECTION
ACTIVITY
Legal
$
96.60/
hr
Manager
$
74.38/
hr
Technical
$
58.31/
hr
Clerical
$
26.07/
hr
Response
Hours/

Year
Labor
Cost/

Year
Capital/

Startup
Costs
O&
M
Costs
Number
of
Respondents
or
Activities
Total
Hours/

Year
Total
Cost/

Year
Best
Workplaces
for
Commuters
Application
(
per
Registered
Work
Site)

Receive
and
Read
Application/
Informational
Materials
0.00
1.00
2.00
0.00
3.00
$
191.00
$
0.00
$
0.00
636
1,908
$
121,476
Estimate
Costs
&
Benefits
of
Participation
0.00
4.00
8.00
0.00
12.00
$
764.00
$
0.00
$
0.00
636
7,632
$
485,904
Provide
Required
Information
on
the
Application
0.00
0.00
0.25
0.00
0.25
$
14.58
$
0.00
$
0.00
636
159
$
9,271
Sign
and
Send
Application
0.00
0.10
0.00
0.05
0.15
$
8.74
$
0.00
$
0.00
636
95
$
5,560
Annual
Check­
in
Form
(
per
Registered
Work
Site)

Read
Instructions
0.00
0.00
1.00
0.00
1.00
$
58.31
$
0.00
$
0.00
1,707
1,707
$
99,535
Update
Contact
Information
&
Complete
Section
I
0.00
0.00
0.05
0.00
0.05
$
2.92
$
0.00
$
0.00
1,707
85
$
4,977
Gather
Information
on
Commuter
Benefits
and
Complete
Section
II
0.00
0.00
0.50
0.00
0.50
$
29.16
$
0.00
$
0.00
1,707
854
$
49,768
Provide
Historical
Info.
(
once;
optional;
10%

of
Employers)
0.00
0.05
0.25
0.00
0.30
$
18.30
$
0.00
$
0.00
60
18
$
1,098
Electronically
Send
Check­
in
Form
0.00
0.00
0.00
0.05
0.05
$
1.30
$
0.00
$
0.00
1,707
85
$
2,225
Employee
Survey
(
Annual;
per
Randomly
Sampled
Registered
Work
Site)

Employer
Contact
Responds
to
Background
Questionnaire
0.00
0.00
0.25
0.00
0.25
$
14.58
$
0.00
$
0.00
86
22
$
1,254
Distribute
Surveys
to
Employees
(
Automated)
0.00
0.00
1.00
0.00
1.00
$
58.31
$
0.00
$
0.00
1,605
1,605
$
93,563
Distribute
Surveys
to
Employees
(
Manual)
0.00
0.00
4.00
8.00
12.00
$
441.80
$
0.00
$
0.00
102
1,229
$
45,249
Employees
Fill
out
Survey
(
Legal)
0.10
0.00
0.00
0.00
0.10
$
9.66
$
0.00
$
0.00
235
24
$
2,270
Employees
Fill
out
Survey
(
Managerial)
0.00
0.10
0.00
0.00
0.10
$
7.44
$
0.00
$
0.00
3,839
384
$
28,551
Employees
Fill
out
Survey
(
Technical)
0.00
0.00
0.10
0.00
0.10
$
5.83
$
0.00
$
0.00
22,052
2,205
$
128,586
Employees
Fill
out
Survey
(
Clerical)
0.00
0.00
0.00
0.10
0.10
$
2.61
$
0.00
$
0.00
13,043
1,304
$
34,004
Employees
Send
Survey
(
Electronically)
0.00
0.00
0.02
0.01
0.03
$
1.00
$
0.00
$
0.00
36,819
1,105
$
36,756
Employees
Send
Survey
(
Manually)
0.00
0.00
0.03
0.02
0.05
$
1.66
$
0.00
$
0.37
2,350
118
$
4,780
Total
20,538
$
1,154,827
16
EXHIBIT
2
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST:
STATE
AND
LOCAL
GOVERNMENTS
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
INFORMATION
COLLECTION
ACTIVITY
Legal
$
44.37/
hr
Manager
$
43.10/
hr
Technical
$
37.87/
hr
Clerical
$
22.42/
hr
Response
Hours/

Year
Labor
Cost/

Year
Capital/

Startup
Costs
O&
M
Costs
Number
of
Respondent
s
or
Activities
Total
Hours/

Year
Total
Cost/

Year
Best
Workplaces
for
Commuters
Application
(
per
Registered
Work
Site)

Receive
and
Read
Application/
Informational
Materials
0.00
1.00
2.00
0.00
3.00
$
118.84
$
0.00
$
0.00
91
273
$
10,814
Estimate
Costs
&
Benefits
of
Participation
0.00
4.00
8.00
0.00
12.00
$
475.36
$
0.00
$
0.00
91
1,092
$
43,258
Provide
Required
Information
on
the
Application
0.00
0.00
0.25
0.00
0.25
$
9.47
$
0.00
$
0.00
91
23
$
862
Sign
and
Send
Application
0.00
0.10
0.00
0.05
0.15
$
5.43
$
0.00
$
0.00
91
14
$
494
Annual
Check­
in
Form
(
per
Registered
Work
Site)

Read
Instructions
0.00
0.00
1.00
0.00
1.00
$
37.87
$
0.00
$
0.00
244
244
$
9,240
Update
Contact
Information
&
Complete
Section
I
0.00
0.00
0.05
0.00
0.05
$
1.89
$
0.00
$
0.00
244
12
$
462
Gather
Information
on
Commuter
Benefits
and
Complete
Section
II
0.00
0.00
0.50
0.00
0.50
$
18.94
$
0.00
$
0.00
244
122
$
4,620
Provide
Historical
Info.
(
once;
optional;
10%
of
Employers)
0.00
0.05
0.25
0.00
0.30
$
11.62
$
0.00
$
0.00
10
3
$
116
Electronically
Send
Check­
in
Form
0.00
0.00
0.00
0.05
0.05
$
1.12
$
0.00
$
0.00
244
12
$
274
Employee
Survey
(
Annual;
per
Randomly
Sampled
Registered
Work
Site)

Employer
Contact
Responds
to
Background
Questionnaire
0.00
0.00
0.25
0.00
0.25
$
14.58
$
0.00
$
0.00
14
4
$
204
Distribute
Survey
Website
to
Employees
(
Automated)
0.00
0.00
1.00
0.00
1.00
$
37.87
$
0.00
$
0.00
229
229
$
8,686
Distribute
Survey
Website
to
Employees
(
Manual)
0.00
0.00
4.00
8.00
12.00
$
441.80
$
0.00
$
0.00
15
176
$
6,468
Employees
Fill
out
Survey
(
Legal)
0.10
0.00
0.00
0.00
0.10
$
4.44
$
0.00
$
0.00
52
5
$
232
Employees
Fill
out
Survey
(
Managerial)
0.00
0.10
0.00
0.00
0.10
$
4.31
$
0.00
$
0.00
854
85
$
3,683
Employees
Fill
out
Survey
(
Technical)
0.00
0.00
0.10
0.00
0.10
$
3.79
$
0.00
$
0.00
4,909
491
$
18,590
Employees
Fill
out
Survey
(
Clerical)
0.00
0.00
0.00
0.10
0.10
$
2.24
$
0.00
$
0.00
2,903
290
$
6,509
Employees
Send
Survey
(
Electronically)
0.00
0.00
0.02
0.01
0.03
$
1.00
$
0.00
$
0.00
8,196
246
$
8,182
Employees
Send
Survey
(
Manually)
0.00
0.00
0.03
0.02
0.05
$
1.66
$
0.00
$
0.37
523
26
$
1,064
17
Total
3,347
$
123,758
EXHIBIT
3
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
Hours
and
Costs
per
Respondent
Total
Hours
and
Costs
INFORMATION
COLLECTION
ACTIVITY
Legal
$
76.85/
hr
Manager
$
74.18/
hr
Technical
$
54.38/
hr
Clerical
$
21.84/
hr
Agency
Hours/

Year
Labor
Cost/

Year
Capital/

Startup
Costs
O&
M
Costs
Number
of
Respondents
or
Activities
Total
Hours/

Year
Total
Cost/

Year
Best
Workplaces
for
Commuters
Application
(
per
Registered
Work
Site)

Develop
the
Application/
Info.
Materials
and
Post
to
Web
4.00
8.00
40.00
24.00
76.00
$
3,600.2
0
$
0.00
$
0.00
1
76
$
3,600
Review
Completed
Applications
0.00
0.10
0.30
0.10
0.50
$
25.92
$
0.00
$
0.00
727
364
$
18,841
Annual
Check­
in
Form
(
per
Registered
Work
Site)

Develop
the
Check­
in
Form/
Associated
Instructions
0.00
4.00
16.00
8.00
28.00
$
1,341.5
2
$
0.00
$
0.00
1
28
$
1,342
Pre­
populate
the
Check­
in
Form
with
Existing
Information
0.00
0.00
0.10
0.00
0.10
$
5.44
$
0.00
$
0.00
1,951
195
$
10,610
Disseminate
the
Check­
in
Form's
Secure
Website
Address
and
Work
Site
Passwords
0.00
0.00
0.05
0.10
0.15
$
4.90
$
0.00
$
0.00
1,951
293
$
9,566
Review
the
Check­
in
Forms
0.00
0.05
0.50
0.20
0.75
$
35.27
$
0.00
$
0.00
1,951
1,463
$
68,806
Review
Optional
Historical
Information
0.00
0.10
0.50
0.40
1.00
$
43.34
$
0.00
$
0.00
195
195
$
8,452
Employee
Survey
(
Annual;
per
Randomly
Sampled
Registered
Work
Site)

Design
Sampling
Plan
0.00
4.00
16.00
8.00
28.00
$
1,341.5
2
$
0.00
$
0.00
1
28
$
1,342
Design
Survey
Form
0.00
4.00
16.00
8.00
28.00
$
1,341.5
2
$
0.00
$
0.00
1
28
$
1,342
Develop
Survey
Instructions
0.00
6.00
20.00
8.00
34.00
$
1,707.4
0
$
0.00
$
0.00
1
34
$
1,707
Develop
Data
Collection
Tool
(
Automated)
0.00
0.00
20.00
0.00
20.00
$
1,166.2
0
$
0.00
$
0.00
1
20
$
1,166
Disseminate
the
Survey's
Secure
Website
Address
and
Work
Site
Passwords
to
Selected
Employers
0.00
0.00
0.05
0.10
0.15
$
5.52
$
0.00
$
0.00
100
15
$
552
18
Compile
and
Analyze
Survey
Data
by
Employer
(
Automated)
into
Internal
Database
0.00
0.00
0.25
0.00
0.25
$
14.58
$
0.00
$
0.00
94
24
$
1,370
Compile
and
Anaylze
Survey
Data
by
Employer
(
Manual)
into
Internal
Database
0.00
0.00
2.00
4.00
6.00
$
220.90
$
0.00
$
0.00
6
36
$
1,325
Total
2,739
$
127,325
19
6(
e)
Bottom
Line
Burden
Hours
and
Costs
6(
e)(
i)
Respondent
Tally
In
Table
8,
EPA
presents
a
summary
of
the
total
estimated
annual
respondent
burden
and
costs
for
BWC
Employers
and
for
the
control
group.

Table
8
Total
Estimated
Average
Annual
Respondent
Burden
and
Cost
Employer
Type
Total
Hours
Total
Labor
Cost
Total
Capital
Cost
Total
O&
M
Cost
Total
Costs
Firms
20,538
$
1,153,957
$
0
$
870
$
1,154,827
State/
Local
Governments
3,347
$
123,564
$
0
$
194
$
123,758
Respondents
23,885
$
1,277,521
$
0
$
1,064
$
1,278,585
Control
Group
167
$
5,557
$
0
$
0
$
5,557
Total
24,052
$
1,283,078
$
0
$
1,064
$
1,284,142
6(
e)(
ii)
Agency
Tally
In
Table
9,
EPA
presents
a
summary
of
the
total
estimated
annual
Agency
burden
and
costs
for
BWC.

Table
9
Total
Estimated
Annual
Agency
Burden
and
Cost
Agency
Total
Hours
Total
Labor
Cost
Total
Capital
Cost
Total
O&
M
Cost
Total
Costs
EPA:

Respondents
2,739
$
127,325
$
0
$
0
$
127,325
Control
Group
250
$
9,468
$
0
$
0
$
9,468
Total
2,989
$
136,793
$
0
$
0
$
136,793
6(
f)
Reasons
for
Change
in
Burden
This
is
a
new
information
collection,
and
as
such,
this
section
does
not
apply.
20
6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
collection
of
information
is
estimated
to
average
0.5
hours
per
response.
Burden
means
the
total
time,
effort,
or
financial
resources
expended
by
persons
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
agency.
This
includes
the
time
needed
to
review
instructions;
develop,
acquire,
install,
and
utilize
technology
and
systems
for
the
purposes
of
collecting,
validating,
and
verifying
information,
processing
and
maintaining
information,
and
disclosing
and
providing
information;
adjust
the
existing
ways
to
comply
with
any
previously
applicable
instructions
and
requirements;
train
personnel
to
be
able
to
respond
to
a
collection
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.

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
2004­
0071,
which
is
available
for
public
viewing
at
the
Office
of
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
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Office
of
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
2004­
0071)
in
any
correspondence.
21
Part
B
1
Introduction
to
Part
B
In
this
part,
the
rationale,
objectives,
methods,
etc.,
for
the
sampling
survey
to
be
conducted
annually
within
the
Best
Workplaces
for
Commuters
(
BWC)
program
is
discussed.
The
information
collection
requirements
for
this
program,
as
originally
proposed
called
for
each
employer
enrolled
in
BWC
to
survey
their
own
employees
every
two
years
and
report
those
results
to
EPA.
Because
this
requirement
fell
on
all
BWC
employers,
the
Supporting
Statement
for
the
Information
Request
as
originally
proposed
did
not
contain
a
Part
B.
By
replacing
the
biennial
survey
and
report
requirement
with
a
sampling
survey,
EPA
is
significantly
reducing
the
burden
on
BWC
employers
since
only
a
few
will
be
selected
over
the
course
of
the
two­
year
period
during
which
all
BWC
employers
were
to
have
been
required
to
perform
surveys
of
all
their
employees
under
the
original
requirement.
Additionally,
the
work
of
developing
the
survey
instrument
and
collecting
and
analyzing
the
data,
previously
the
responsibility
of
the
BWC
employer,
is
now
being
done
by
EPA.

2
Survey
Objectives,
Key
Variables,
and
Survey
Design
The
primary
objective
of
the
survey
is
to
obtain
data
by
which
to
estimate
the
air
quality
benefits
and
greenhouse
gas
reductions
that
result
from
the
changes
in
commuting
behavior
by
employees
of
BWC
employers
wrought
by
the
subsidies
and
other
inducements
they
receive.
The
key
variables
are
the
distribution
of
commute
modes
(
i.
e.,
driving
alone,
carpooling,
riding
transit,
teleworking,
etc.)
among
commuters
surveyed
and
their
distances
from
home
to
work.
Additional
variables
of
interest
are
the
commuter's
level
of
awareness
of
the
incentives
offered
by
their
employers,
and
factors
that
motivate
their
choice
of
commute
mode.

EPA
has
sought
extensive
expert
input
on
the
design
of
the
survey,
the
sampling
methodology,
and
the
questionnaire.
The
initial
drafts
of
these
items
were
sent
for
peer
review
and
have
been
revised
based
upon
the
input
received
from
the
review
group.
An
experienced
survey
firm
will
be
retained
to
manage
the
survey
and
the
data
analysis
will
be
peer
reviewed
as
well.

For
the
survey,
EPA
will
randomly
select
100
employers
distributed
over
four
urban
areas
in
which
EPA
recruiting
and
publicity
activities
have
been
focused,
and
survey
(
see
Appendix
D)
all
employees
at
each
selected
work
site.
EPA
is
working
with
survey
research
experts
to
determine
the
best
method
to
do
this.
The
primary
means
of
administering
the
survey
will
be
via
the
internet.
After
randomly
selecting
the
companies
to
survey,
EPA
will
work
with
the
primary
contact
at
each
company
to
notify
employees
of
the
survey
and
direct
them
to
the
survey
web
site.
Follow­
ups
via
regular
mail
will
be
conducted
as
needed
to
obtain
the
necessary
response
rate.
The
contact
for
BWC
Employers
also
will
be
asked
to
answer
a
short
questionnaire
(
also
in
Appendix
D),
supplying
some
additional
important
background
information.
To
obtain
a
baseline
against
which
to
measure
the
effects
of
the
program,
EPA
will
also
conduct
phone
surveys
with
2,000
randomly
selected
commuters
across
the
same
urban
areas
who
are
not
employed
by
BWC
22
employers,
and
do
not
receive
employer­
provided
commuter
benefits
(
also
in
Appendix
D.).
The
questionnaire
will
be
similar
to
that
used
for
the
BWC
employees,
but
with
some
modifications
to
screen
out
the
unemployed,
the
self­
employed,
and
those
who
receive
commuter
benefits.
The
forms
in
Appendix
D
are
expected
to
be
modified
slightly
based
on
the
results
of
pilot
testing,
expert
comment,
and
new
analytical
needs
that
might
arise
in
future
years.

3
Pretests,
Pilot
Tests,
Collection
Methods,
and
Analyzing
Survey
Results
EPA
will
conduct
a
small
pilot
survey
to
ensure
that
all
technical
aspects
of
the
web
survey
delivery
and
data
collection
systems
are
functioning
properly
and
that
the
survey
time
is
as
short
and
questions
as
understandable
as
we
think
they
are.
The
survey
will
be
conducted
at
three
work
sites
of
BWC
employers
who
volunteered
to
be
part
of
the
pilot.
These
employers
will
then
be
removed
from
the
pool
of
candidates
for
the
first
round
of
the
official
survey.

The
primary
method
of
administering
the
survey
will
be
via
the
internet.
The
responses
will
be
transferred
automatically
to
EPA's
internal
database
from
the
web
survey
for
collection
and
analysis.
For
those
surveys
that
have
to
be
administered
by
mail,
the
results
will
be
manually
entered
into
the
database
by
EPA.
Results
from
the
telephone
surveys
of
the
control
group
will
also
be
entered
into
the
database,
either
transcribed
from
paper
records
of
the
phone
calls,
or
entered
directly
into
the
database
via
a
computer
used
by
the
interviewer
at
the
time
of
the
call.

Both
the
control
group
questionnaire
and
the
BWC
employee
questionnaire
ask
what
commute
mode
the
respondent
used
to
get
to
work
each
day
of
the
preceding
week.
The
primary
goal
of
the
survey
analysis
will
be
to
determine
if
there
is
a
statistically
significant
difference
in
the
incidence
of
the
use
of
alternative
commute
modes,
as
opposed
to
driving
to
work
alone
in
the
two
groups.
In
addition,
the
BWC
employee
results
will
be
analyzed
to
determine
level
of
awareness
of
the
incentives
available
to
them
and
motivating
factors
in
their
choices
of
modes.
APPENDIX
A
LIST
OF
THE
NAICS
CODES
ASSOCIATED
WITH
INDUSTRIES
MOST
LIKELY
TO
JOIN
BWC
A­
1
11
Agriculture,
Forestry,
Fishing
and
Hunting
111
Crop
Production
112
Animal
Production
113
Forestry
and
Logging
114
Fishing,
Hunting
and
Trapping
115
Support
Activities
for
Agriculture
and
Forestry
21
Mining
211
Oil
and
Gas
Extraction
212
Mining
(
except
Oil
and
Gas)
213
Support
Activities
for
Mining
22
Utilities
221
Utilities
23
Construction
233
Building,
Developing,
and
General
Contracting
234
Heavy
Construction
235
Special
Trade
Contractors
31
Manufacturing
311
Food
Manufacturing
312
Beverage
and
Tobacco
Product
Manufacturing
313
Textile
Mills
314
Textile
Product
Mills
315
Apparel
Manufacturing
316
Leather
and
Allied
Product
Manufacturing
321
Wood
Product
Manufacturing
322
Paper
Manufacturing
323
Printing
and
Related
Support
Activities
324
Petroleum
and
Coal
Products
Manufacturing
325
Chemical
Manufacturing
326
Plastics
and
Rubber
Products
Manufacturing
327
Nonmetallic
Mineral
Product
Manufacturing
331
Primary
Metal
Manufacturing
332
Fabricated
Metal
Product
Manufacturing
333
Machinery
Manufacturing
334
Computer
and
Electronic
Product
Manufacturing
335
Electrical
Equipment,
Appliance,
and
Component
Manufacturing
336
Transportation
Equipment
Manufacturing
337
Furniture
and
Related
Product
Manufacturing
339
Miscellaneous
Manufacturing
42
Wholesale
Trade
421
Wholesale
Trade,
Durable
Goods
422
Wholesale
Trade,
Nondurable
Goods
44­
45
Retail
Trade
441
Motor
Vehicle
and
Parts
Dealers
442
Furniture
and
Home
Furnishings
Stores
443
Electronics
and
Appliance
Stores
444
Building
Material
and
Garden
Equipment
and
Supplies
Dealers
445
Food
and
Beverage
Stores
446
Health
and
Personal
Care
Stores
447
Gasoline
Stations
448
Clothing
and
Clothing
Accessories
Stores
451
Sporting
Goods,
Hobby,
Book,
and
Music
Stores
452
General
Merchandise
Stores
453
Miscellaneous
Store
Retailers
454
Nonstore
Retailers
48­
49
Transportation
and
Warehousing
481
Air
Transportation
482
Rail
Transportation
483
Water
Transportation
484
Truck
Transportation
485
Transit
and
Ground
Passenger
Transportation
486
Pipeline
Transportation
487
Scenic
and
Sightseeing
Transportation
488
Support
Activities
for
Transportation
491
Postal
Service
492
Couriers
and
Messengers
493
Warehousing
and
Storage
51
Information
511
Publishing
Industries
512
Motion
Picture
and
Sound
Recording
Industries
513
Broadcasting
and
Telecommunications
514
Information
Services
and
Data
Processing
Services
52
Finance
and
Insurance
521
Monetary
Authorities
­
Central
Bank
522
Credit
Intermediation
and
Related
Activities
523
Securities,
Commodity
Contracts,
and
Other
Financial
Investments
and
Related
Activities
524
Insurance
Carriers
and
Related
Activities
525
Funds,
Trusts,
and
Other
Financial
Vehicles
53
Real
Estate
and
Rental
and
Leasing
531
Real
Estate
532
Rental
and
Leasing
Services
533
Lessors
of
Nonfinancial
Intangible
Assets
(
except
Copyrighted
Works)

54
Professional,
Scientific,
and
Technical
Services
541
Professional,
Scientific,
and
Technical
Services
55
Management
of
Companies
and
Enterprises
551
Management
of
Companies
and
Enterprises
56
Administrative
and
Support
and
Waste
Management
and
Remediation
Services
561
Administrative
and
Support
Services
562
Waste
Management
and
Remediation
Services
61
Educational
Services
611
Educational
Services
62
Health
Care
and
Social
Assistance
A­
2
621
Ambulatory
Health
Care
Services
622
Hospitals
623
Nursing
and
Residential
Care
Facilities
624
Social
Assistance
71
Arts,
Entertainment,
and
Recreation
711
Performing
Arts,
Spectator
Sports,
and
Related
Industries
712
Museums,
Historical
Sites,
and
Similar
Institutions
713
Amusement,
Gambling,
and
Recreation
Industries
72
Accommodation
and
Food
Services
721
Accommodation
722
Food
Services
and
Drinking
Places
81
Other
Services
(
except
Public
Administration)
811
Repair
and
Maintenance
812
Personal
and
Laundry
Services
813
Religious,
Grantmaking,
Civic,
Professional,
and
Similar
814
Private
Households
92
Public
Administration
921
Executive,
Legislative,
and
Other
General
Government
Support
922
Justice,
Public
Order,
and
Safety
Activities
923
Administration
of
Human
Resource
Programs
924
Administration
of
Environmental
Quality
Programs
925
Administration
of
Housing
Programs,
Urban
Planning,
and
Community
Development
926
Administration
of
Economic
Programs
927
Space
Research
and
Technology
928
National
Security
and
International
Affairs
APPENDIX
B
BWC
APPLICATION
APPENDIX
C
ANNUAL
CHECK­
IN
FORM
APPENDIX
D
EMPLOYEE
SURVEY
AND
RELATED
QUESTIONNAIRES
