SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
1736.04
A
REPORTING
AND
RECORDKEEPING
REQUIREMENTS
UNDER
EPA=
S
NATURAL
GAS
STAR
PROGRAM@

November
15,
2004
TABLE
OF
CONTENTS
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION.........................
1
1(
a)
TITLE
AND
NUMBER
OF
THE
INFORMATION
COLLECTION...................
1
1(
b)
CHARACTERIZATION
OF
THE
INFORMATION
COLLECTION.................
1
1(
c)
TERMS
OF
CLEARANCE
OF
THE
INFORMATION
COLLECTION
................
1
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION....................................
3
2(
a)
NEED
AND
AUTHORITY
FOR
THE
COLLECTION...........................
3
2(
b)
PRACTICAL
UTILITY/
USERS
OF
THE
DATA.............................
4
3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA..........
4
3(
a)
NONDUPLICATION..................................................
4
3(
b)
CONSULTATIONS...................................................
4
3(
c)
PUBLIC
NOTICE...................................................
4
3(
d)
EFFECTS
OF
LESS
FREQUENT
COLLECTION.............................
5
3(
e)
GENERAL
GUIDELINES..............................................
5
3(
f)
CONFIDENTIALITY.................................................
5
3(
g)
SENSITIVE
QUESTIONS.............................................
5
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED.........................
5
4(
a)
RESPONDENTS/
SIC
CODES...........................................
5
4(
b)
INFORMATION
REQUESTED...........................................
5
5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT...............................
9
5(
a)
AGENCY
ACTIVITIES...............................................
9
5(
b)
COLLECTION
METHODOLOGY
AND
MANAGEMENT..........................
10
5(
c)
SMALL
ENTITY
FLEXIBILITY.......................................
10
5(
d)
COLLECTION
SCHEDULE.............................................
10
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION.....................
10
6(
a)
ESTIMATING
RESPONDENT
BURDEN...................................
10
6(
b)
ESTIMATING
RESPONDENT
COSTS....................................
11
6(
c)
ESTIMATING
AGENCY
BURDEN
AND
COST..............................
11
6(
d)
ESTIMATING
THE
RESPONDENT
UNIVERSE
AND
TOTAL
BURDEN.............
15
6(
e)..........................
BOTTOM
LINE
BURDEN
HOURS
AND
COSTS
16
6(
f)
REASONS
FOR
CHANGE
IN
BURDEN...................................
16
6(
g)
BURDEN
STATEMENT
...........................................................................................................
16
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
and
Number
of
the
Information
Collection
This
ICR
is
entitled
"
Reporting
and
Recordkeeping
Requirements
Under
EPA's
Natural
Gas
STAR
Program,"
ICR
number
1736.04.

1(
b)
Characterization
of
the
Information
Collection
1
Natural
Gas
STAR
is
a
voluntary
program
sponsored
by
the
U.
S.
Environmental
Protection
Agency
(
EPA)
that
encourages
natural
gas
companies
to
adopt
cost
effective
methods
for
reducing
methane
emissions.
The
program
works
with
natural
gas
production,
processing,
storage,
transmission,
and
distribution
companies
to
remove
barriers
that
inhibit
the
implementation
of
various
emission
reduction
opportunities.
The
Program
effectively
advances
the
adoption
of
emission
reduction
technologies
by
working
with
Natural
Gas
Star
Partners
to
evaluate
a
set
of
Best
Management
Practices
(
BMPs)
and
various
Partner
Reported
Opportunities
(
PROs)
in
the
context
of
their
current
business
operations,
and
implement
them
where
cost
effective.
The
program=
s
BMPs
and
PROs
save
participants
money,
improve
operational
efficiency,
and
enhance
the
protection
of
the
environment.

Participation
in
the
program
begins
with
the
completion
and
submittal
of
a
one­
page
Memorandum
of
Understanding
(
MOU)
that
outlines
responsibilities
of
the
Natural
Gas
STAR
Partner
and
EPA.
The
MOU
commits
a
Natural
Gas
STAR
Partner
to
reviewing
all
of
its
gas­
related
operations
in
the
U.
S.
and
considering
a
set
of
options
that
reduce
emissions,
increase
profits
and
competitiveness,
and
maintain
or
enhance
gas
delivery
service.
In
addition,
Partners
agree
to
implement
BMPs
that
pertain
to
the
Partner's
operation
(
production,
transmission,
processing,
storage,
and/
or
distribution).
Partners
also
agree
that
the
BMPs
are
generally
cost
effective
for
the
industry,
but
favorable
economics
are
dependent
upon
site
specific
factors.

Natural
Gas
STAR
Partners
agree
to
submit
an
Implementation
Plan
within
six
to
twelve
months
of
signing
the
MOU.
In
subsequent
years,
Partners
must
complete
and
submit
an
Annual
Report
that
documents
the
implementation
of
BMPs
and
PROs
and
associated
methane
emission
reduction
accomplishments.
In
return
for
their
participation,
Partners
are
allowed
to
advertise
their
membership
and
involvement
in
the
program.
EPA
helps
Partners
with
their
communication
efforts
and
also
provides
program
implementation
assistance
by
analyzing
emerging
technologies
and
developing
workshops
and
training
courses.
This
voluntary
agreement
can
be
terminated
by
the
Natural
Gas
STAR
Partner
or
EPA
with
no
notice
or
penalties.

1(
c)
Terms
of
Clearance
of
the
Information
Collection
When
this
collection
was
approved
in
2001,
OMB
asked
EPA
to
evaluate
the
extent
to
which
the
partners
would
have
reduced
their
emissions
in
the
absence
of
the
program,
and
that
EPA
should
not
use
these
data
to
estimate
aggregate
emission
reductions
across
the
industry
resulting
from
the
Natural
Gas
STAR
Program.
In
regard
to
the
latter
issue,
EPA
agrees
with
OMB
and
recognizes
the
analytical
issues
associated
with
such
an
extrapolation.
As
a
result,
EPA
does
not
use
data
reported
through
the
Natural
Gas
STAR
Program
to
estimate
aggregate
emission
reductions
across
the
industry.

The
extent
to
which
partners
would
have
reduced
their
emissions
in
the
absence
of
the
Program
is
a
challenging
question,
but
one
that
EPA
takes
very
seriously.
As
is
described
later
in
this
Supporting
Statement,
Partners
of
the
Natural
Gas
STAR
Program
are
asked
to
submit
Implementation
Plans
every
three
years
describing
the
emissions
reduction
practices
they
plan
to
evaluate
and
implement.
Partners
are
then
asked
to
submit
annual
progress
reports
detailing
emission
reduction
activities
undertaken
during
the
previous
calendar
year.
The
Natural
Gas
STAR
Program
asks
that
partners
only
include
in
their
reports
practices
that
were
undertaken
voluntarily;
i.
e.
not
to
include
reductions
attributable
to
compliance
with
existing
regulations.

The
emission
reductions
reported
by
Partners
include
reductions
associated
with
the
implementation
of
traditional
program
Best
Management
Practices
(
BMPs)
and
reductions
achieved
through
the
adoption
of
Partner
2
Reported
Activities
(
PROs).
PROs
are
activities
identified
by
Gas
STAR
Partners,
beyond
the
original
BMPs,
that
result
in
methane
emissions
reductions.
It
is
worthwhile
to
note
that
in
2003,
64%
of
reductions
reported
to
Gas
STAR
were
due
to
these
Partner
identified
emissions
reduction
activities.
A
significant
portion
of
Gas
STAR's
efforts
in
recent
years
has
been
devoted
to
promoting
these
PROs
through
technical
document
development
and
hosting
of
specialized
technology
transfer
workshops.

Emission
reduction
data
submitted
to
EPA
are
used
to
measure
the
effectiveness
of
the
Natural
Gas
STAR
Program.
EPA,
however,
does
not
attribute
all
of
these
emissions
reductions
to
Natural
Gas
STAR.
In
particular,
emission
reduction
data
for
Transmission
and
Distribution
BMP
2,
Pipeline
Replacement,
is
largely
considered
regulatory
driven
and
is
not
included
when
calculating
program
accomplishments.
In
addition,
for
each
annual
report,
a
quality
assurance/
quality
control
check
is
performed
on
all
data.
Unrealistic
emissions
reduction
claims
and
any
errors
or
inconsistencies
are
identified
and
resolved
through
direct
correspondence
with
the
appropriate
company
(
ies).
If
necessary,
these
data
are
omitted
or
adjusted
prior
to
their
inclusion
in
the
accounting
of
Natural
Gas
STAR
Program
accomplishments.

In
an
effort
to
ensure
that
these
data
accurately
reflect
the
impact
of
the
Program,
EPA
has
performed
a
scenario
analysis.
As
shown
in
Figure
1,
a
business
as
usual
scenario
was
developed
that
displays
projected
methane
emissions
in
the
absence
of
the
Natural
Gas
STAR
Program.
This
emission
scenario
is
calculated
by
multiplying
emission
factors
by
projected
levels
of
production,
processing
and
transmission/
distribution
as
reported
in
the
Energy
Information
Agency's
American
Energy
Outlook
(
AEO
2002).
The
emission
factors
are
assumed
to
decline
5%
over
25
years
to
reflect
increased
efficiencies
in
the
natural
gas
system.

In
the
same
figure,
an
alternative
emissions
scenario
is
constructed
that
assumes
all
cost­
effective
mitigation
options
are
implemented
over
the
time
period.
Cost­
effective
mitigation
options
are
defined
as
those
options
where
the
cost
savings
or
revenue
is
greater
than
the
cost
of
the
mitigation
option
over
the
lifetime
of
a
given
emission
reduction
project.
While
these
options
are
cost
effective,
they
are
not
implemented
in
the
no­
action
scenario
because
of
information,
policy
and
other
non­
cost
barriers.
The
difference
between
this
emission
scenario
and
the
no­
action
scenario
represents
the
total
potential
emission
reduction
that
would
reasonably
be
achieved
by
the
Natural
Gas
STAR
Program
if
all
barriers
to
implementation
were
removed.
Details
on
this
analysis
can
be
found
at
the
following
EPA
website:
http://
www.
epa.
gov/
methane/
intlanalyses.
html.

Using
this
analysis
as
a
guide,
EPA
is
able
to
estimate
the
extent
to
which
regulatory,
information,
and
other
barriers
that
often
inhibit
the
implementation
of
these
activities
can
be
overcome
by
the
Natural
Gas
Program.
The
Program
overcomes
these
barriers
this
through
a
variety
of
activities
including:

­
Development
of
technical
fact
sheets,
reports
and
articles
­
Hosting
technology
transfer
workshops
­
Providing
analytical
support
to
Partner
companies
­
Supporting
research
activities
­
Publicizing
achievements
of
Partner
companies
­
Providing
a
mechanism
for
recording
and
storing
information
about
emission
reduction
activities
In
addition
to
benefiting
Partner
companies
who
report
these
reductions,
these
activities
benefit
non­
Partner
companies
who
are
not
reporting
to
the
Program.
For
example,
all
the
technical
documents
developed
by
the
Program
are
3
made
available
to
the
public
on
the
Gas
STAR
website,
and
workshop
attendance
is
not
restricted
to
Program
Partners.
Thus,
it
can
be
assumed
that
some
of
the
close
to
40%
of
the
natural
gas
industry
that
is
not
participating
in
the
Natural
Gas
STAR
Program
is
also
implementing
some
of
the
emission
reduction
activities
that
are
encouraged
by
the
Program.
As
noted
above,
Natural
Gas
STAR
does
not
attempt
to
estimate
the
accomplishments
of
these
companies,
even
though
their
activities
are
at
least
partially
due
to
the
existence
of
the
Natural
Gas
STAR
Program.

Figure
1:
Natural
Gas
Industry
Emission
Projections
20
25
30
35
40
45
1990
1995
2000
2005
2010
2015
2020
MMTCE
Baseline
without
Measures
Baseline
with
cost
effective
options
included
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
EPA
has
developed
this
ICR
to
obtain
authorization
to
collect
information
from
Natural
Gas
STAR
Partners.
EPA
needs
to
collect
initial
information
in
the
MOU
to
formally
establish
participation
in
the
Natural
Gas
STAR
Program
and
to
obtain
general
information
on
new
Natural
Gas
STAR
Partners.
EPA
uses
information
obtained
in
the
MOU
to
identify
and
initiate
communication
with
the
Partner=
s
Natural
Gas
STAR
Implementation
Manager
and
Media
Liaison.

By
agreeing
to
participate
in
the
Natural
Gas
STAR
Program,
the
Partner
commits
to
completing
and
submitting
an
Implementation
Plan
and
an
Annual
Report.
The
Implementation
Plan
and
Annual
Report
are
necessary
to
evaluate
a
Partner's
progress
and
performance,
and
assess
overall
program
results.
The
information
provided
in
these
communications
also
allows
EPA
to
identify
the
equipment,
systems,
maintenance
methods,
and
implementation
methods
most
commonly
utilized,
and
to
provide
technical
and
other
assistance
to
Partners
in
completing
and
enhancing
their
planned
implementation
of
BMPs
and
PROs.

2(
b)
Practical
Utility/
Users
of
the
Data
4
EPA
uses
information
submitted
in
the
MOU
to
update
its
database/
tracking
system
containing
information
on
current
and
potential
Natural
Gas
STAR
Partners.
The
database
serves
as
a
source
of
general
information
and
a
mailing
list
for
both
Partners
and
non­
partner
companies.
EPA
uses
information
submitted
in
the
Implementation
Plan
and
Annual
Report
to
document
the
progress
of
companies
and
organizations
in
implementing
the
program
and
reducing
methane
emissions.
EPA
enters
report
information
received
from
Partners
into
the
tracking
system.
EPA
also
aggregates
these
data
and
prepares
various
progress
reports.
EPA
uses
these
data
to
develop
technical
publications
on
specific
economic
emission
reduction
practices
and
case
studies
of
successful
implementation
experiences.
These
documents
serve
to
demonstrate
to
current
and
potential
Partners
the
cost
savings
that
can
be
realized
through
various
equipment
upgrades
and
maintenance
activities,
and
to
provide
technical
and
implementation
assistance.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
The
information
to
be
obtained
under
this
ICR
has
not
been
collected
by
EPA
or
any
other
Federal
agency.

3(
b)
Consultations
EPA
has
consulted
with
not
more
than
nine
Natural
Gas
STAR
Partners
to
obtain
their
views
on
this
method
of
data
collection
and
has
obtained
their
input
on
the
burden
estimate.
Organizations
consulted
included:

­
Great
Lakes
Gas
Transmission
Company;
­
Baltimore
Gas
and
Electric
Company;
­
El
Paso
Natural
Gas
Company;
­
Bay
State
Gas
Company;
­
PECO
Energy
Company;
­
ANR
Pipeline
Company;
­
Enron;
and
­
Shell
E
&
P
Company.

EPA
has
followed
up
with
some
of
these
companies
and
a
few
others
in
order
to
determine
the
reduction
of
burden
that
has
been
experienced
by
companies
utilizing
the
on­
line
reporting
system
(
first
available
in
2002).
Organizations
consulted
on
this
specific
matter
included:

­
Great
Lakes
Gas
Transmission
Company;
­
American
Electric
Power
Company;
­
Atlanta
Gas
Light
Company;
­
SCANA,
Inc.;
­
PECO
Energy
Company;
­
Burlington
Resources,
Inc.;
­
CrossCountry
Energy
Company;
and
­
Shell
E
&
P
Company.

3(
c)
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
29,
2004
(
69
FR
38893).
No
comments
were
received
in
response
to
the
notice.
5
3(
d)
Effects
of
Less
Frequent
Collection
The
development
of
an
MOU
and
Implementation
Plan
are
one­
time
information
submittals
from
companies
that
voluntarily
choose
to
become
Partners
in
the
Natural
Gas
STAR
Program.
Partners
must
also
prepare
and
submit
an
Annual
Report
while
participating
in
the
program.
EPA
believes
that
any
reduction
in
the
frequency
of
this
information
collection
would
impede
efforts
by
EPA
to
evaluate
results
of
the
program.

3(
e)
General
Guidelines
None
of
these
reporting
or
record
keeping
requirements
violate
any
of
the
regulations
established
by
OMB
in
5
CFR
1320.5.

3(
f)
Confidentiality
Participation
in
the
Natural
Gas
STAR
Program
is
voluntary.
Natural
Gas
STAR
Partners
may
designate
information
submitted
under
this
ICR
as
confidential
business
information.
EPA
will
treat
all
such
information
as
confidential
business
information
and
will
not
make
the
company
or
agencyspecific
information
collected
under
this
ICR
available
to
the
general
public.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
asked
in
the
MOU,
Implementation
Plan,
or
the
Annual
Report.

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

211111
Crude
Petroleum
and
Natural
Gas
Extraction
48621
Pipeline
Transportation
of
Natural
Gas
22121
Natural
Gas
Distribution
4(
b)
Information
Requested
EPA's
Natural
Gas
STAR
Program
specifies
requirements
for
Partners.
All
Natural
Gas
STAR
Partners
must
develop
and
submit
a
one­
page
Memorandum
of
Understanding
(
MOU)
with
the
Agency
upon
agreeing
to
participate
in
the
program.
Partners
also
must
complete
and
submit
to
EPA
a
Natural
Gas
STAR
Program
Implementation
Plan
within
six
months
of
signing
the
MOU.
The
Implementation
Plan
is
an
outline
of
what
will
happen
over
the
next
three
years,
and
serves
as
a
plan
for
the
Partner
to
follow.
Partners
also
submit
an
Annual
Report
to
the
Agency.
The
Annual
Report
documents
what
has
been
accomplished
in
the
past
year,
using
the
Implementation
Plan
as
a
guideline
for
comparison.

Memorandum
of
Understanding
Natural
Gas
STAR
Partners
are
required
to
develop
and
submit
to
EPA
an
MOU
that
describes
the
terms
of
participation
in
the
program.

(
i)
Data
items:
6
Partners
must
provide
the
following
information
in
the
MOU:

!
The
name,
title,
address,
telephone
and
facsimile
number,
and
email
address
of
a
Natural
Gas
STAR
Program
Implementation
Manager
and
a
Media
Liaison;

!
The
name,
address,
and
telephone
number
of
the
Partners's
CEO,
President,
or
Chairman,
if
applicable;

!
A
camera­
ready
version
of
the
Partner's
logo,
or
other
emblem;

(
ii)
Respondent
activities:

In
developing
the
MOU,
Partners
must
perform
the
following
activities:

!
Receive
and
review
the
MOU;

!
Gather
information
and
fill
out
the
MOU;

!
Sign
the
MOU
and
submit
it
to
EPA.

Implementation
Plan
Partners
must
complete
and
submit
a
Natural
Gas
STAR
Implementation
Plan
within
six
to
twelve
months
of
signing
the
MOU.

(
i)
Data
items:

The
Implementation
Plan
form
requests
the
following
information:

!
General
company
information
(
e.
g.,
company
name
and
contact,
position,
address,
SIC
code,
telephone
and
facsimile
numbers,
etc.);

!
An
Implementation
Plan
Summary;
and
!
Information
on
applicable
Best
Management
Practices,
which
are
reported
by
BMP
type:

­
Directed
Inspection
and
Maintenance
at
Surface
Facilities;
­
Identification
and
Rehabilitation
of
Leaky
Distribution
Pipe;
­
Directed
Inspection
and
Maintenance
programs
at
Compressor
Stations;
­
Use
of
Turbines
at
Compressor
Stations
for
New
Installations
or
When
Retiring
Reciprocating
Engines;
­
Identification
and
Replacement
of
High
Bleed
Pneumatic
Devices;
­
Installation
of
Flash
Tank
Separators
on
Dehydrators;
­
Replace
Gas
Pneumatics
with
Instrument
Air
Systems;
and
­
Implement
Directed
Inspection
and
Maintenance
at
Gas
Plants
and
Booster
Stations.

!
Information
on
applicable
Partner
Reported
Opportunities
that
the
company
chooses
to
evaluate
and
implement
(
ii)
Respondent
activities:
7
Partners
must
conduct
the
following
activities
in
preparing
the
Implementation
Plan:

!
Review
the
instructions;

!
Gather
the
requested
information
and
develop
the
Implementation
Plan;

!
Complete
the
form(
s);

!
Sign
and
submit
the
plan
to
EPA;
and
­
Update
the
plan,
if
necessary.

Annual
Report
Partners
must
complete
and
submit
a
Natural
Gas
STAR
Annual
Report
while
participating
in
the
program.

(
i)
Data
items:

The
Annual
Report
form
requests
the
following
information:

!
General
company
information
(
e.
g.,
company
name
and
contact,
position,
address,
period
covered
by
report,
SIC
code,
telephone
and
facsimile
numbers,
etc.);

!
An
Annual
Report
Summary;
and
!
Information
on
Best
Management
Practices
executed,
which
are
reported
by
BMP
type:

­
Directed
Inspection
and
Maintenance
at
Surface
Facilities;
­
Identification
and
Rehabilitation
of
Leaky
Distribution
Pipe;
­
Directed
Inspection
and
Maintenance
programs
at
Compressor
Stations;
­
Use
of
Turbines
at
Compressor
Stations
for
New
Installations
or
When
Retiring
Reciprocating
Engines;
­
Identification
and
Replacement
of
High
Bleed
Pneumatic
Devices;
­
Installation
of
Flash
Tank
Separators
on
Dehydrators;
­
Replace
Gas
Pneumatics
with
Instrument
Air
Systems;
and
­
Implement
Directed
Inspection
and
Maintenance
at
Gas
Plants
and
Booster
Stations.

!
Information
on
applicable
Partner
Reported
Opportunities
that
the
company
chooses
to
evaluate
and
implement
(
ii)
Respondent
activities:

Partners
must
conduct
the
following
activities
in
preparing
the
Annual
Report:

!
Review
the
instructions;

!
Gather
the
requested
information
for
the
initial
report;

!
Complete
the
initial
form(
s);

!
Sign
and
date
the
initial
report;
8
!
Submit
the
initial
report
to
EPA;
and
­
Prepare
and
submit
a
subsequent
Annual
Report.

Use
of
EPA­
Developed
Materials
EPA
will
loan
certain
materials
to
Natural
Gas
STAR
Partner's
for
the
purpose
of
publicizing
the
program.
The
Partner
will
reproduce
and
return
the
materials
to
the
EPA
within
30
days.

(
i)
Data
items:

Partner
may
request
camera­
ready
negatives,
mechanicals,
and
other
directly
reproducible
material
for
the
creation
of
the
following:

!
Natural
Gas
STAR
brochures;
!
Natural
Gas
STAR
briefs;
!
Natural
Gas
STAR
video;
and
!
Other
Natural
Gas
STAR
materials.

(
ii)
Respondent
activities:

!
Make
a
request
to
the
EPA
to
borrow
materials;
and
!
Return
all
borrowed
materials
within
thirty
(
30)
days
of
their
receipt.

Additional
Activities
During
participation
in
the
program,
Partners
may
be
required
to
notify
EPA
within
two
weeks
of
any
change
in
Natural
Gas
STAR
Program
Implementation
Manager
responsibility.

(
i)
Data
items:

Partner
must
provide
EPA
with
the
name
of
the
new
Implementation
Manager.

(
ii)
Respondent
activities:

­
Notify
EPA
within
two
weeks
of
any
change
in
Natural
Gas
STAR
Implementation
Manager
responsibility.

5.
THE
INFORMATION
COLLECTED­­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
The
Natural
Gas
STAR
Program
requires
EPA
to
perform
activities
after
a
Partner
submits
the
MOU,
Implementation
Plan,
and
Annual
Report.

Memorandum
of
Understanding
EPA
must
perform
the
following
activities
following
the
submittal
of
an
MOU:

!
Review
the
MOU
to
ensure
completeness
and
accuracy,
and
follow
up,
if
necessary;
9
!
Sign
the
MOU;

!
Develop
a
cover
letter;

!
Copy
the
cover
letters
and
MOUs;

!
Send
cover
letter
and
original
MOU
back
to
Partner;

!
File
copies
of
cover
letters
and
MOUs;
and
!
Enter
MOU
information
into
a
database.

Implementation
Plan
EPA
must
perform
the
following
activities
after
the
submittal
of
an
Implementation
Plan:

!
Review
the
plan
to
ensure
completeness
and
accuracy,
and
followup
if
necessary;

!
Make
copies
of
the
plan;

!
File
copies
of
the
plan;
and
!
Enter
information
into
a
database.

Annual
Report
EPA
must
perform
the
following
activities
after
the
submittal
of
an
Annual
report:

!
Review
the
report
to
ensure
completeness
and
accuracy,
and
followup
if
necessary;

!
Make
copies
of
the
report;

!
File
copies
of
the
report;
and
!
Enter
information
into
a
database.

Use
of
EPA­
Developed
Materials
EPA
may
perform
the
following
activities
after
the
receiving
a
request
for
materials:

!
Make
record
of
request;

!
Ship
materials
to
the
Partner;
and
!
Receive
returned
materials.

Additional
Activities
EPA
also
may
be
required
to
perform
the
following
additional
activity:

!
Enter
any
changes
in
Partner's
information
into
a
database
(
e.
g.,
Implementation
Manager's
responsibility,
size
of
facility,
newsletter
mailing
list,
etc.).
10
5(
b)
Collection
Methodology
and
Management
In
collecting
and
analyzing
the
information
associated
with
this
ICR,
EPA
uses
a
state­
of­
the­
art
telephone
system,
personal
computers,
and
applicable
database
and
word
processing
software.
In
addition
to
traditional
hard
copy
data
collection
methods,
all
information
can
be
submitted
to
EPA
electronically.
EPA
has
created
the
capability
for
companies
to
submit
Annual
Reports
through
a
password
protected
website
or
by
e­
mailing
an
electronic
reporting
form.

EPA
ensures
the
accuracy
and
completeness
of
collected
information
by
reviewing
each
submittal.
EPA
enters
the
information
obtained
from
the
MOU,
Implementation
Plan,
and
Annual
Reports
into
a
database
and
aggregates
data
obtained
from
the
Implementation
Plan
and
Annual
Reports
to
track
the
progress
of
Partners
in
reducing
methane
emissions.

5(
c)
Small
Entity
Flexibility
EPA
expects
that
some
Natural
Gas
STAR
Partners
may
be
small
entities.
EPA
has
designed
its
plan
and
electronic
reporting
forms
to
minimize
respondent
burden
while
obtaining
sufficient
and
accurate
information.
In
addition,
the
burden
associated
with
the
Natural
Gas
STAR
Program
is
inherently
reduced
since
the
initial
agreement
to
participate
is
voluntary.

5(
d)
Collection
Schedule
EPA
collects
initial
information
in
the
MOU,
which
is
completed
and
submitted
by
each
Partner
upon
agreement
to
participate
in
the
program.
EPA
collects
information
in
the
Implementation
Plan
six
to
twelve
months
after
receiving
a
signed
MOU.
Each
Spring,
EPA
collects
information
in
the
Annual
Report
to
monitor
emission
reduction
progress.
Finally,
EPA
may
collect
other
program
information
on
a
periodic
basis
or
as
the
information
is
submitted;
these
items
include
notification
of
changes
in
Implementation
Manager
responsibility,
and
notification
of
changes
in
a
Partner's
gas
system.

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
members
of
the
affected
universe
and
reviewed
comments
received
during
the
comment
period.
Exhibit
1
presents
the
estimated
annual
respondent
burden
and
costs
for
information
collection
activities
associated
with
the
Natural
Gas
STAR
Program.

6(
b)
Estimating
Respondent
Costs
EPA
estimates
an
average
hourly
labor
rate
(
hourly
rate
plus
overhead)
of
$
138
for
legal
staff,
$
112
for
managerial
staff,
$
80
for
technical
staff,
and
$
42
for
clerical
staff.
In
developing
these
estimates,
EPA
used
U.
S.
Bureau
of
Labor
Statistics
data
and
consulted
with
Natural
Gas
STAR
Partners.
To
develop
respondent
capital
and
O
&
M
cost
estimates,
EPA
consulted
with
members
of
the
oil
and
gas
industry.
EPA
believes
that
the
capital
or
operations
and
maintenance
costs
of
this
program
are
not
significant.
The
only
O
&
M
costs
expected
are
for
postage.
A
postage
cost
of
$
3.00
is
attributed
to
all
activities
involving
the
sending
of
materials
to
account
for
the
use
of
trackable
mail.

6(
c)
Estimating
Agency
Burden
and
Costs
11
Exhibit
2
presents
the
estimated
Agency
burden
hours
and
costs
for
the
information
collection
activities
associated
with
this
ICR.
EPA
estimates
an
average
hourly
labor
cost
(
labor
plus
overhead)
of
$
67.04
for
legal
staff,
$
62.63
for
managerial
staff,
$
45.97
for
technical
staff,
and
$
18.46
for
clerical
staff.
To
derive
these
estimates,
EPA
used
the
2004
Federal
Pay
Schedule
salary
figures.
For
purposes
of
this
ICR,
EPA
assigned
staff
the
following
government
service
levels:

­
Legal
Staff
GS­
15,
Step
1
­
Managerial
Staff
GS­
14,
Step
4
­
Technical
Staff
GS­
12,
Step
5
­
Clerical
Staff
GS­
5,
Step
1.
12
E
XHIBIT
1:
ESTIMATED
ANNUAL
RESPONDENT
BURDEN
AND
COST
Hours
and
Costs
Per
Respondent/
Activity
Total
Hours
and
Costs
Number
of
Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Respon.
Total
Total
$
137.68/
$
112.42/
$
79.58/
$
41.68/
Hours/
Cost/
Startup
O
&
M
or
Hours/
Cost/

INFORMATION
COLLECTION
ACTIVITY
Hour
Hour
Hour
Hour
Activity
Activity
Cost
Cost
Activities
Year
Year
Memorandum
of
Understanding
Receive
and
review
the
MOU
1.00
8.00
0.00
0.00
9.00
$
1,037
$
0
$
0
8
72
$
8,296
Gather
information
and
fill
out
MOU
data
sheet
1.00
25.00
0.00
2.00
28.00
$
3,032
$
0
$
0
8
224
$
24,256
Sign
and
submit
MOU
to
EPA
0.00
0.50
0.00
0.50
1.00
$
77
$
0
$
3
8
8
$
640
SUBTOTAL
304
$
33,192
Implementation
Plan
Review
instructions
0.00
2.00
0.00
0.00
2.00
$
225
$
0
$
0
8
16
$
1,800
Gather
information
and
develop
the
Implementation
Plan
0.00
10.00
10.00
0.00
20.00
$
1,920
$
0
$
0
8
160
$
15,360
Complete
the
form(
s)
0.00
1.00
0.00
1.00
2.00
$
154
$
0
$
0
8
16
$
1,232
Sign
and
submit
plan
to
EPA
0.00
0.50
0.00
0.50
1.00
$
77
$
0
$
3
8
8
$
640
Update
Implementation
Plan,
as
necessary
0.00
6.50
4.00
1.50
12.00
$
1,112
$
0
$
3
35
420
$
39,025
SUBTOTAL
620
$
58,057
Annual
Report
Review
instructions
0.00
7.00
0.00
0.00
7.00
$
787
$
0
$
0
8
56
$
6,296
Gather
the
requested
information
for
the
initial
report
0.00
10.00
37.00
0.00
47.00
$
4,069
$
0
$
0
8
376
$
32,552
Complete
the
initial
form(
s)
0.00
4.00
0.00
1.00
5.00
$
491
$
0
$
0
8
40
$
3,928
Sign
and
submit
the
initial
report
to
EPA
0.00
0.50
0.00
0.50
1.00
$
77
$
0
$
3
8
8
$
640
Prepare
and
submit
a
subsequent
Annual
Report
0.00
10.00
18.50
1.50
30.00
$
2,428
$
0
$
3
108
3,240
$
262,548
SUBTOTAL
3,720
$
305,964
Use
of
EPA
Developed
Materials
Make
request
to
EPA
for
materials
0.00
2.00
0.00
1.00
3.00
$
267
$
0
$
0
11
33
$
2,937
Return
borrowed
materials
within
30
days
0.00
0.00
0.00
1.00
1.00
$
42
$
0
$
3
11
11
$
495
SUBTOTAL
44
$
3,432
Additional
Activities
Notify
EPA
within
two
weeks
of
any
change
in
Natural
Gas
Star
Implementation
Manager
responsibility
0.00
1.00
0.00
0.50
1.50
$
133
$
0
$
3
11
17
$
1,4962
13
SUBTOTAL
17
$
1,496
TOTAL
$
0
$
21
4,705
$
402,141
EXHIBIT
2:
ESTIMATED
ANNUAL
AGENCY
BURDEN
AND
COST
Hours
and
Costs
Per
Respondent/
Activity
Total
Hours
and
Costs
Number
of
Leg.
Mgr.
Tech.
Cler.
Respon.
Labor
Capital/
Respon.
Total
Total
$
67.04/
$
62.69/
$
45.97/
$
18.46/
Hours/
Cost/
Startup
O
&
M
or
Hours/
Cost/

INFORMATION
COLLECTION
ACTIVITY
Hour
Hour
Hour
Hour
Activity
Activity
Cost
Cost
Activities
Year
Year
Memorandum
of
Understanding
Review
MOU
and
follow
up,
if
necessary
0.00
0.00
1.00
0.00
1.00
$
46
$
0
$
0
8
8
$
368
Sign
the
MOU
0.00
0.05
0.00
0.00
0.05
$
3
$
0
$
0
8
ERR
$
23
Develop
a
cover
letter
0.00
0.00
0.00
0.10
0.10
$
2
$
0
$
0
8
1
$
14
Copy
cover
letters
and
MOUs
0.00
0.00
0.00
0.08
0.08
$
1
$
0
$
0
8
1
$
11
Send
cover
letters
and
original
MOU
back
to
partner
0.00
0.00
0.00
0.10
0.10
$
2
$
0
$
3
8
1
$
38
File
copies
of
cover
letters
and
MOUs
0.00
0.00
0.00
0.10
0.10
$
2
$
0
$
0
8
1
$
14
Enter
MOU
information
into
a
data
base
0.00
0.00
0.00
0.25
0.25
$
4
$
0
$
0
8
2
$
34
Subtotal
13
$
500
Implementation
Plan
Review
plan
and
follow
up,
if
necessary
0.00
0.00
2.00
0.00
2.00
$
84
$
0
$
0
35
70
$
2,942
Make
copies
of
plan
0.00
0.00
0.00
0.08
0.08
$
1
$
0
$
0
35
3
$
47
File
copies
of
plan
0.00
0.00
0.00
0.10
0.10
$
2
$
0
$
0
35
4
$
59
Enter
information
into
data
base
0.00
0.00
0.00
0.25
0.25
$
4
$
0
$
0
35
9
$
148
Subtotal
85
$
3,196
Annual
Report
Review
report
and
follow
up,
if
necessary
0.00
0.00
4.00
0.00
4.00
$
168
$
0
$
0
116
464
$
19,502
Make
copies
of
report
0.00
0.00
0.00
0.08
0.08
$
1
$
0
$
0
116
9
$
157
File
copies
of
report
0.00
0.00
0.00
0.10
0.10
$
2
$
0
$
0
116
12
$
196
Enter
information
into
data
base
0.00
0.00
0.00
0.50
0.50
$
8
$
0
$
0
116
58
$
979
Subtotal
543
$
20,833
Use
of
EPA­
Developed
Materials
Make
record
of
request
0.00
0.00
0.00
0.10
0.10
$
2
$
0
$
0
9
1
$
15
Ship
materials
to
the
partner
0.00
0.00
0.00
0.25
0.25
$
4
$
0
$
3
9
2
$
65
Receive
returned
materials
0.00
0.00
0.00
0.25
0.25
$
4
$
0
$
0
9
2
$
38
14
Subtotal
5
$
118
Additional
Activities
Enter
updated
information
into
data
base
0.00
0.00
0.00
0.25
0.25
$
4
$
0
$
0
49
12
$
207
Subtotal
12
$
207
TOTAL
$
0
$

$
6
659
$
24,855
15
To
derive
hourly
estimates,
EPA
divided
annual
compensation
estimates
by
2,080,
which
is
the
number
of
hours
in
the
Federal
work­
year.
EPA
then
multiplied
hourly
rates
by
the
standard
government
overhead
factor
of
1.6.

6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
Currently,
there
are
108
Natural
Gas
STAR
Program
Partners,
and
EPA
anticipates
that
an
average
of
eight
new
Partners
will
join
the
program
annually.
The
average
annual
universe
numbers
are
shown
below
in
Table
1.

TABLE
1
Estimated
Number
of
Program
Partners
in
Fiscal
Years
2004­
2006
Type
of
Partner
Fiscal
Year
'
04
Fiscal
Year
'
05
Fiscal
Year
'
06
Average
New
Partners
Enrolled
9
8
8
8
Total
Program
Partners
108
116
124
116
Memorandum
of
Understanding
Each
potential
Partner
must
complete
and
submit
an
MOU
to
participate
in
the
program.
EPA
expects
that
eight
new
Partners
will
complete
and
submit
an
MOU
each
year.

Implementation
Plan
Each
Partner
must
complete
and
submit
the
Implementation
Plan
within
six
to
twelve
months
of
signing
and
submitting
the
MOU.
Thus,
the
Agency
expects
that
all
eight
new
Partners
will
prepare
and
submit
the
Implementation
Plan
each
year.
Additionally,
EPA
estimates
that
each
year,
30
percent
of
all
existing
Partners
(
35
facilities)
will
update
the
Implementation
Plan
and
submit
it
to
EPA.

Annual
Report
All
existing
Partners
must
complete
and
submit
an
Annual
Report.
EPA
estimates
that
completing
the
initial
Annual
Report
will
take
approximately
twice
as
long
as
subsequent
reports.
EPA
also
expects
that
the
eight
new
Program
Partners
joining
each
year
will
complete
and
submit
an
initial
report
and
all
108
other
existing
Partners
(
116
minus
the
eight
new
Partners)
will
complete
and
submit
subsequent
reports.

Use
of
EPA­
Developed
Materials
Each
year,
EPA
estimates
that
10
percent
of
all
Partners
will
request
the
use
of
EPA­
developed
materials
for
promotional
purposes.
Thus,
EPA
estimates
that
11
Partners
(
108
x
.1)
will
request
materials
from
EPA
each
year.

Additional
Activities
EPA
expects
that
some
additional
information
submittals
may
be
required
of
some
Partners.
EPA
estimates
that
approximately
10
percent
of
all
Partners
16
experience
changes
in
their
Implementation
Manager
responsibilities
each
year.
Thus,
EPA
estimates
that
an
average
of
11
Partners
(
108
x
.1)
will
notify
EPA
of
changes
in
Implementation
Manager
responsibilities
6(
e)
Bottom
Line
Burden
Hours
and
Costs
Exhibits
1
and
2
show
the
aggregate
annual
burden
and
cost
to
respondents
and
the
government,
respectively,
for
the
information
collection
activities
covered
under
this
ICR.
The
bottom
line
burden
for
respondents
is
approximately
4,423
hours
per
year
with
an
annual
cost
of
approximately
$
402,141.
The
annual
bottom
line
burden
to
the
Agency
is
approximately
659
hours,
at
a
cost
of
approximately
$
24,854
per
year.
Over
the
three­
year
period
covered
by
this
ICR,
EPA
estimates
the
burden
of
the
program
to
be
13,269
hours
and
$
1,261,998
for
respondents,
and
1,977
hours
and
$
74,562
for
EPA.

6(
f)
Reasons
for
Change
in
Burden
The
overall
reporting
burden
for
respondents
has
increased
from
the
previous
ICR.
Burden
hours
increased
from
4,059
to
4,423
hours
per
year
and
annual
costs
increased
from
$
321,844
to
$
402,141.
This
change
is
largely
the
result
of:

­
Higher
hourly
labor
rates
due
to
inflation;
and
­
An
increase
in
the
number
of
program
participants.

The
increase,
however,
was
tempered
by
a
reduction
in
the
estimate
of
time
spent
filling
out
and
submitting
the
annual
report
due
to
the
introduction
of
on­
line
reporting
in
2002.
Fifty­
eight
percent
of
reporting
partners
used
the
on­
line
system
in
2004,
and
partners
reported
a
subsequent
decreased
burden
of
15%
for
this
activity.
This
reduced
the
average
labor
cost
of
preparing
and
submitting
an
annual
report
from
$
2,782
to
$
2,540
(
at
constant
2004
labor
rates.)

6(
g)
Burden
Statement
The
average
per
facility
reporting
burden
for
information
collection
requirements
associated
with
completing
the
MOU
is
estimated
to
be
3.06
hours.
The
burden
estimate
includes
time
to
receive,
review,
complete,
sign,
and
submit
the
MOU.

The
average
per
facility
reporting
burden
for
information
collection
requirements
associated
with
completing
the
Implementation
Plan
is
estimated
to
be
5.3
hours.
The
burden
estimate
includes
time
to
receive
and
review
the
plan
form;
gather
the
requested
information;
complete
the
form;
sign
and
date
the
form;
and
submit
the
form
to
EPA.

The
average
per
facility
reporting
burden
for
information
collection
requirements
associated
with
completing
the
Annual
Report
for
Program
Partners
is
estimated
to
be
27.4
hours.
The
burden
estimate
includes
time
to
receive
and
review
the
report
form;
gather
the
requested
information;
complete
the
form;
sign
and
date
the
form;
and
submit
the
form
to
EPA.
This
estimate
includes
a
reduced
estimate
for
those
partners
using
the
on­
line
reporting
system,
and
a
factor
to
account
for
the
percentage
of
partners
who
are
likely
to
use
the
on­
line
reporting
system.

The
average
per
facility
reporting
burden
for
information
collection
requirements
associated
with
requesting
the
use
of
EPA­
Developed
materials
is
estimated
to
be
.4
hours.
The
burden
estimate
includes
time
to
make
the
17
request
to
the
EPA
for
the
materials
and
to
return
the
materials
to
the
EPA
within
thirty
days
of
receiving
them.

For
Natural
Gas
STAR
Partners,
the
average
per
facility
reporting
burden
for
information
collection
requirements
associated
with
additional
activities
is
estimated
to
be
.2
hours.
The
reporting
burden
includes
time
to
notify
EPA
of
changes
in
Natural
Gas
STAR
Program
Implementation
Manager
responsibility.

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
Number
OAR­
2004­
0082,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
and
Radiation
Docket
and
Information
Center
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.
When
in
the
system,
select
``
search,''
then
key
in
the
Docket
ID
Number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
include
the
EPA
Docket
ID
Number
OAR­
2004­
0082
and
OMB
Control
Number
2060­
0328
in
any
correspondence.

Part
B
of
the
Supporting
Statement
This
part
is
not
applicable
because
no
statistical
methods
were
used
in
collecting
this
information.
