SUPPORTING STATEMENT FOR 

EPA INFORMATION COLLECTION REQUEST NUMBER 1736.05

EPA’S NATURAL GAS STAR PROGRAM

January 15, 2008 

	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	 4

2(a)	NEED AND AUTHORITY FOR THE COLLECTION	 4

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	 5

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	 6

4(a)	RESPONDENTS/SIC CODES	 6

4(b)	INFORMATION REQUESTED	 6

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	 10

6(c)	ESTIMATING AGENCY BURDEN AND COST	 11

6(d)	ESTIMATING THE RESPONDENT UNIVERSE AND TOTAL BURDEN	14 

             6(e)	BOTTOM LINE BURDEN HOURS AND COSTS	 15

6(f)	REASONS FOR CHANGE IN BURDEN	 15

6(g)	BURDEN STATEMENT	 15



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 1736.05, OMB Control No.
2060-0328.

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 oil and natural
gas companies to adopt cost effective methods for reducing methane
emissions.  The program works with oil and 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. Implementation of
the program’s BMPs and PROs save participants money, improves
operational efficiency, and enhances 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 its activities that
result in methane emissions and consider 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 and
PROs that pertain to the Partner's operations (production, transmission,
processing, storage, and/or distribution).  Partners also agree that the
BMPs and PROs are generally cost effective for the industry, but
favorable economics are dependent upon site specific factors.

Natural Gas STAR Partners also 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 conducting 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 2004, 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 does not use the data in this manner.

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 Opportunities (PROs). PROs are activities identified
by Natural Gas STAR Partners, beyond the original BMPs, that result in
methane emissions reductions. It is worthwhile to note that for 2006,
61% of reductions reported to Natural Gas STAR were due to these Partner
identified emissions reduction activities. A significant portion of
Natural 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 project generates a positive internal rate of return. 
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.  

In support of the President’s national greenhouse gas intensity
target, EPA used the emission projections with and without
cost-effective reductions implemented and past experience with
supporting the natural gas industry to set program reduction targets for
the Natural Gas STAR Program (as illustrated by the red dotted line and
reported in the Climate Action Report (CAR)).  As illustrated by the
orange line, the Natural Gas STAR Program is tracking well against these
emission reduction targets. 

 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
STAR Program. The Program overcomes these barriers 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 Natural Gas STAR
website, and workshop attendance is not restricted to Program Partners.
Thus, it can be assumed that a substantial portion 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 Methane Emission Projections

*Notes and Data Sources:  												

Projected emissions without Gas STAR are from the Global Anthropogenic
Non-CO2 Greenhouse Gas Emissions: 1990-2020, EPA 430-R-06-003. Projected
emissions with cost effective options included are from the Global
Mitigation of Non-CO2 Greenhouse Gases, EPA 430-R-06-005.							

Program reductions are based on expert judgment and were used to measure
the GHG intensity of the U.S. economy in the U.S. Climate Action Report
- 2006, Department of State, Chapters 4-5.											

											

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 one-page 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 annual report information received from Partners
into the tracking system.  EPA also aggregates these data and prepares
various progress reports.  With Partner permission, 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

	Since the last ICR Renewal, all of the information collection
procedures for Natural Gas STAR have remained in a similar format.  EPA
contacted the following people and received no objections to this
information request.

Steven O'Connell

Environment Safety and Heath Supervisor

20 North Broadway

Oklahoma City, OK 73102-8260

405-552-4672

steve.o'connell@dvn.com

Brady Dodson

Environment, Safety and Health Specialist

1100 Louisiana St, Suite 3300

Houston, TX 77002

713-821-2161

Brady.Dodson@enbridge.com

John Cordaway

Reliability Engineer

El Paso Natural Gas Company

1001 Louisiana St., Suite 1503

Houston, TX 77002

713-420-4279

John.Cordaway@ElPaso.com

  

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 November 1, 2007 (72 FR 61875).  No comments were received
in response to the notice.

3(d)	Effects of Less Frequent Collection

The development of an MOU is a one-time information submittal from
companies that voluntarily choose to become Partners in the Natural Gas
STAR Program.  Partners must also prepare and submit an Implementation
Plan, and revise the plan every three years.  Partners must also 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 sign and submit to EPA the
one-page 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 and signature of the Partners' Authorized Company
Representative;

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 one-page MOU; 

Gather information and fill out the MOU; and

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, telephone and facsimile numbers, etc.);

An Implementation Plan Summary;

Information on applicable Best Management Practices, which are reported
by BMP type:

		Directed Inspection and Maintenance at Gate Stations and Surface
Facilities;

	Identification and Rehabilitation of Leaky Distribution Pipe;

	Directed Inspection and Maintenance programs at Compressor Stations;

	Use of Turbines at Compressor Stations;

	Identification and Replacement of High Bleed Pneumatic Devices;

	Installation of Flash Tank Separators on Glycol 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; and

Inventory of past methane emission reductions.

(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, telephone and facsimile numbers,
etc.);

An Annual Report Summary;

Information on Emission Reduction Technologies & Practices or Best
Management Practices executed, which are reported by the following BMP
type:

Directed Inspection and Maintenance at Gate Stations and 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 Glycol 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 implemented; and

Information on Additional Program Accomplishments.

(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.

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 tracking 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 tracking 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 an emissions reduction data management database.

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, 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 reviewed available company Web sites for Partner organizations that
were believed to be small entities.  Upon completion of the review, EPA
estimated that one Natural Gas STAR Partner is a small entity. 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 one-page 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

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 used a national average hourly labor rate (hourly rate plus 110%
overhead) of $141.69 for legal staff, $117.56 for managerial staff,
$89.01 for technical staff, and $44.78 for clerical staff.  Legal,
managerial, technical, and clerical labor rates were obtained from the
Bureau of Labor and Statistics average rates for Pipeline Transportation
of Natural Gas (NAICS code 486200), Natural Gas Distribution (NAICS code
221200), and Oil and Gas Extraction (NAICS code 211100).  The labor
rates used were calculated by averaging labor rates for the three NAICS
codes.  Legal rates were based on lawyers, management wages were based
on environmental managers, technical wages were based on environmental
engineers, and clerical rates were based on executive secretaries and
administrative assistants for May 2006.  A June 2007 labor rate for all
rates was estimated by applying a 3.5% growth factor from the employment
cost index to account for increases in wages from June 2006 to June
2007.  The Employment Cost Index for wages and salaries, by ownership,
occupational group, and industry is located at:
http://www.bls.gov/news.release/eci.t02.htm

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 $71.34
for legal staff, $66.72 for managerial staff, $48.91 for technical
staff, and $19.65 for clerical staff.  To derive these estimates, EPA
used the “Hourly Salary Table 2007 - GS” from the Department of
Personnel Management.  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.

	To derive the loaded hourly estimates, EPA multiplied hourly rates by
the standard government overhead factor of 1.6.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

	$141.69	$117.56	$89.01	$44.78	Hours/	Cost/	Startup	O & M	or	Hours/
Cost/

INFORMATION COLLECTION ACTIVITY1	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 	$1,082 	$0 
$0 	9	81 	$9,738 

  Gather information and fill out MOU data sheet	1.00 	25.00 	0.00 	2.00
	28.00 	$3,170 	$0 	$0 	9	252 	$28,530 

  Sign and submit MOU to EPA	0.00 	0.50 	0.00 	0.50 	1.00 	$81 	$0 	$3 
9	9 	$756 

SUBTOTAL	 	 	 	 	 	 	 	 	 	342 	$39,024 

Implementation Plan	 	 	 	 	 	 	 	 	 	 	 

  Review instructions	0.00 	2.00 	0.00 	0.00 	2.00 	$235 	$0 	$0 	9	18 
$2,115 

  Gather information and develop the Implementation Plan	0.00 	10.00 
10.00 	0.00 	20.00 	$2,066 	$0 	$0 	9	180 	$18,594 

  Complete the form(s)	0.00 	1.00 	0.00 	1.00 	2.00 	$162 	$0 	$0 	9	18 
$1,458 

  Sign and submit plan to EPA	0.00 	0.50 	0.00 	0.50 	1.00 	$81 	$0 	$3 
9	9 	$756 

  Update Implementation Plan, as necessary and Submit to EPA	0.00 	6.50 
4.00 	1.50 	12.00 	$1,187 	$0 	$3 	44	528 	$52,360 

SUBTOTAL	 	 	 	 	 	 	 	 	 	753 	$75,283 

Annual Report 	 	 	 	 	 	 	 	 	 	 	 

  Review instructions	0.00 	7.00 	0.00 	0.00 	7.00 	$823 	$0 	$0 	9	63 
$7,407 

  Gather the requested information for the initial report	0.00 	10.00 
37.00 	0.00 	47.00 	$4,469 	$0 	$0 	9	423 	$40,221 

  Complete the initial form(s)	0.00 	4.00 	0.00 	1.00 	5.00 	$515 	$0 
$0 	9	45 	$4,635 

  Sign and submit the initial report to EPA	0.00 	0.50 	0.00 	0.50 	1.00
	$81 	$0 	$3 	9	9 	$756 

  Prepare and submit a subsequent Annual Report	0.00 	9.03 	16.70 	1.35 
27.08 	$2,608 	$0 	$3 	146	3,953 	$381,206 

SUBTOTAL	 	 	 	 	 	 	 	 	 	4,493 	$434,225

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 	$140 	$0 	$3 	15	23 	$2,145 

SUBTOTAL	 	 	 	 	 	 	 	 	 	23 	$2,145 

TOTAL	 	 	 	 	 	 	 	 	 	5,610 	$550,677 













	1 Since the last ICR renewal, EPA has removed the burden for requesting
and mailing EPA Developed Materials for Natural Gas Star.  All of these
materials are now available on the Natural Gas STAR Web site, and thus
this burden is no longer relevant.





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

	$71.34	$66.72	$48.91	$19.65	Hours/	Cost/	Startup	O & M	or	Hours/	Cost/

INFORMATION COLLECTION ACTIVITY1	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 	$49
	$0 	$0 	9 	9 	$440 

Sign the MOU	0.00 	0.05 	0.00 	0.00 	0.05 	$3 	$0 	$0 	9 	0 	$30 

Develop a cover letter	0.00 	0.00 	0.00 	0.10 	0.10 	$2 	$0 	$0 	9 	1 
$18 

Copy cover letters and MOUs	0.00 	0.00 	0.00 	0.08 	0.08 	$2 	$0 	$0 	9 
1 	$14 

Send cover letters and original MOU back	 	 	 	 	 	 	 	 	 	 
 

to partner	0.00 	0.00 	0.00 	0.10 	0.10 	$2 	$0 	$3 	9 	1 	$45 

File copies of cover letters and MOUs	0.00 	0.00 	0.00 	0.10 	0.10 	$2 
$0 	$0 	9 	1 	$18 

Enter MOU information into a data base	0.00 	0.00 	0.00 	0.25 	0.25 	$5 
$0 	$0 	9 	2 	$44 

Subtotal	 	 	 	 	 	 	 	 	 	15 	$609 

Implementation Plan	 	 	 	 	 	 	 	 	 	 	 

Review plan and follow up, if necessary	0.00 	0.00 	2.00 	0.00 	2.00 
$98 	$0 	$0 	53 	106 	$5,185 

Make copies of plan	0.00 	0.00 	0.00 	0.08 	0.08 	$2 	$0 	$0 	53 	4 	$83


File copies of plan	0.00 	0.00 	0.00 	0.10 	0.10 	$2 	$0 	$0 	53 	5 
$104 

Enter information into data base	0.00 	0.00 	0.00 	0.25 	0.25 	$5 	$0 
$0 	53 	13 	$260 

Subtotal	 	 	 	 	 	 	 	 	 	129 	$5,632 

Annual Report	 	 	 	 	 	 	 	 	 	 	 

Review report and follow up, if necessary	0.00 	0.00 	4.00 	0.00 	4.00 
$196 	$0 	$0 	155 	620 	$30,325 

Make copies of report	0.00 	0.00 	0.00 	0.08 	0.08 	$2 	$0 	$0 	155 	12 
$244 

File copies of report	0.00 	0.00 	0.00 	0.10 	0.10 	$2 	$0 	$0 	155 	16 
$305 

Enter information into data base	0.00 	0.00 	0.00 	0.50 	0.50 	$10 	$0 
$0 	155 	78 	$1,523 

Subtotal	 	 	 	 	 	 	 	 	 	725 	$32,396 

Additional Activities	 	 	 	 	 	 	 	 	 	 	 

Enter updated information into data base	0.00 	0.00 	0.00 	0.25 	0.25 
$5 	$0 	$0 	15 	4 	$74 

TOTAL	 	 	 	 	 	 	 	 	 	873 	$38,711 













	1 Since the last ICR renewal, EPA has removed the burden for requesting
and mailing EPA Developed Materials for Natural Gas Star.  All of these
materials are now available on the Natural Gas STAR Web site, and thus
this burden is no longer relevant.







6(d)       Estimating the Respondent Universe and Total Burden and Costs

Currently, there are 137 Natural Gas STAR Program Partners.  Based on
recent partner activity, EPA anticipates that an average of nine new
Partners will join the program annually.  The majority of Natural Gas
STAR Partners are currently large companies and EPA believes that many
of the major relevant companies have already joined the program.  The
number of new Partners, however, remains constant because of more
international companies and smaller independent companies joining the
program.  The average annual cost and burden estimates during the next
3-year ICR period are based on the average number of Partners as shown
in Table 1.  

	TABLE 1

Estimated Number of Program Partners in Calendar Years 2008-2010

	Type of Partner

	

2008	

	2009	

	2010	

Average



New Partners Enrolled

	

9	

9	

9	

9



Total Program Partners

	

137	

146	

155	

146



Memorandum of Understanding

Each potential Partner must complete and submit a one-page MOU to
participate in the program.  EPA expects that nine new Partners will
complete and submit an MOU each year. 

Implementation Plan

Each new Partner must complete and submit the Implementation Plan within
six to twelve months of signing and submitting the MOU.  Additionally,
EPA estimates that 30 percent of all existing Partners (44 facilities)
will update the Implementation Plan and submit it to EPA each year.

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 expects that the
nine new Program Partners joining each year will complete and submit an
initial report and an average of 146 existing Partners (as shown in
table 1) will complete and submit subsequent reports.

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 15
Partners (146 x 0.1) 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 5,610 hours per year with an annual
cost of approximately $550,677, which includes $696 in O&M costs.  The
annual bottom line burden to the Agency is approximately 873 hours, at a
cost of approximately $38,711 per year.  Over the three-year period
covered by this ICR, EPA estimates the burden of the program to be
16,831 hours and $1,652,031for respondents, and 2,619 hours and $116,133
for EPA.

6(f)	Reasons for Change in Burden

The overall annual reporting burden for respondents has increased from
4,705 hours in the previous ICR to 5,610 hours in the current ICR as a
result of an increase in the number of Partners in the Natural Gas STAR
program.  Despite this increase, the average burden per partner has
decreased from 40.6 hours per Partner to 36.2 hours per Partner.  This
decrease can be attributed to a larger percentage of Partners using the
on-line Annual Report forms, and the availability of new materials on
the Natural Gas STAR Web-site. Fifty-eight percent of reporting partners
used the on-line system in 2004 while 65% of reporting partners used the
on-line system in 2007. Partners reported a subsequent decreased burden
of 15% for this activity. The hourly burden estimates for data
collection remained the same per Partner because the information
requested and the collection methodology did not change.

	  Since the last ICR renewal, the overall annual cost increased from
$402,141 to $550,677.  This change is largely the result of higher
hourly labor rates due to inflation and an increase in the number of
program participants.

6(g)	Burden Statement

The average per Partner reporting burden for information collection
requirements associated with completing this ICR is estimated to be 24.2
hours.  

For new Partners, the average per Partner reporting burden for
information collection requirements associated with developing and
completing the Implementation Plan is estimated to be 25 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. For existing Partners, the average per
Partner reporting burden for information collection requirements
associated with updating the Implementation Plan is estimated to be 12
hours.  The burden estimate includes time to review, update (if
necessary), complete, sign and submit the form to EPA. 

The average per Partner reporting burden for information collection
requirements associated with completing the initial Annual Report is
estimated to be 60 hours.  The average per Partner reporting burden for
information collection requirements associated with completing
subsequent Annual reports is estimated to be 27.1 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.

For Natural Gas STAR Partners, the average per Partner reporting burden
for information collection requirements associated with additional
activities is estimated to be 1.5 hours.  The reporting burden includes
time to notify EPA of changes in Natural Gas STAR Program Implementation
Manager responsibility. 

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.  The OMB control numbers for EPA's regulations are
listed in 40 CFR part 9 and 48 CFR chapter 15.     

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
EPA-HQ-OAR-2004-0082, which is available for online viewing at
www.regulations.gov, or in person viewing at the Air and Radiation
Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301
Constitution Avenue, NW, Washington, D.C.  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 is 202-566-1742.  An electronic version of the public docket is
available at www.regulations.gov.  This site can be used to submit or
view public comments, access the index listing of the contents of the
public docket, and 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, D.C. 20503,
Attention: Desk Officer for EPA.  Please include the EPA Docket ID
Number EPA-HQ-OAR-2004-0082 and OMB Control Number 2060-0328 in any
correspondence.

	

	

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