SUPPORTING STATEMENT FOR 

EPA INFORMATION COLLECTION REQUEST NUMBER 1736.04

(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

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 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 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.

	

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

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.

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
agency-specific 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:

Partners must provide the following information in the MOU:

(	The name, title, address, telephone and facsimile number, and e-mail
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:

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; 

(	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;

(	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 follow-up, 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 follow-up,
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.).

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

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.



EXHIBIT 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



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



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



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 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 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.  

  SEQ CHAPTER \h \r 1 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.

	

	

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