                                       
                                       
                                       
                                       
                                       
                                       
                           SUPPORTING STATEMENT FOR 
               EPA INFORMATION COLLECTION REQUEST NUMBER 1736.08
                       EPA'S NATURAL GAS STAR PROGRAM
                                       
                                August 27. 2018
                                       
                                       
                                       
	TABLE OF CONTENTS

1.	IDENTIFICATION OF THE INFORMATION COLLECTION	3
1(a)	Title of the Information Collection	3
1(b)	Short Characterization/Abstract	3
1(c)	Terms of Clearance of the Information Collection	4
2.	NEED FOR AND USE OF THE COLLECTION	5
2(a)	Need/Authority for the Collection	5
2(b)	Practical Utility/Users of the Data	6
3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA	6
3(a)	Nonduplication	6
3(b)	Public Notice Required Prior to ICR Submission to OMB	7
3(c)	Consultations	7
3(d)	Effects of Less Frequent Collection	8
3(e)	General Guidelines	8
3(f)	Confidentiality	8
3(g)	Sensitive Questions	8
4. 	THE RESPONDENTS AND THE INFORMATION REQUESTED	8
4(a)	Respondents/NAICS Codes	9
4(b)	Information Requested	9
5.	THE INFORMATION COLLECTED-AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	13
5(a)	Agency Activities	13
5(b)	Collection Methodology and Management	14
5(c)	Small Entity Flexibility	15
5(d)	Collection Schedule	15
6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION	15
6(a)	Estimating Respondent Burden	15
6(b)	Estimating Respondent Costs	15
6(c)	Estimating Agency Burden and Costs	16
6(d)	Estimating the Respondent Universe and Total Burden and Costs	16
6(e)	Bottom Line Burden Hours and Costs	21
6(f)	Reasons for Change in Burden	21
6(g)	Burden Statement	22
      
      
1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title of the Information Collection

      "Reporting and Recordkeeping Requirements Under EPA's Natural Gas STAR Program," ICR renewal number 1736.08, OMB Control No. 2060-0328.

1(b)	Short Characterization/Abstract

      Natural Gas STAR is a voluntary program sponsored by the U.S. Environmental Protection Agency (EPA) since 1993 that encourages oil and natural gas companies to adopt cost effective technologies and practice that improve operational efficiency and reduce methane emissions. Methane is the pri - mary component of natural gas and a potent greenhouse gas. The Program works with oil and natural gas companies in the production, gathering & processing, transmission, and distribution sectors to remove barriers that inhibit the implementation of technologies and practices that reduce methane emissions. The Program effectively promotes the adoption of emission reduction technologies and practices by helping Natural Gas Star partners evaluate Best Management Practices (BMPs) and Partner Reported Opportunities (PROs) in the context of their current operations, and implement them where cost effective. Implementation of the Program's BMPs and PROs saves participants money, improves operational efficiency, and enhances the protection of the environment.
      
      Oil and natural gas companies become partners by completing and submitting a one-page Partnership Agreement that outlines responsibilities of the partner company and EPA. The agreement commits a Natural Gas STAR partner to review its activities that result in methane emissions and consider implementation of appropriate BMPs and PROs that reduce methane emissions, generate revenue, and improve operational efficiency. 
      
      Natural Gas STAR partners agree to submit an Implementation Plan within six to twelve months (depending on partner sector) of signing the Partnership Agreement and to submit an annual report. Annual reporting is a key requirement to the Program. After one full year of participation in the Program, partners agree to submit an annual report documenting the previous year's methane emission reduction activities. Partners agree to report methane emission reduction activities on an annual basis to remain in good standing. Partners are encouraged to communicate their Program successes to the general public. EPA also provides Program implementation assistance by analyzing emerging technologies and conducting technology transfer workshops and webinars. 
      
      The voluntary agreement can be terminated by the Natural Gas STAR partner or EPA at any time without notice, penalties or further obligation.	

1(c)	Terms of Clearance of the Information Collection
      
      OMB noted the following "terms of clearance" when it renewed the Program's information collection request in 2011:
      
      The data gathered under this collection represents estimates of emissions reductions associated with activities reported by participants in the Natural Gas STAR Program. Some of the activities and emissions reductions may have been achieved in the absence of the Natural Gas STAR program. For this reason, the data is not appropriate for use as an aggregate summary of emissions reductions resulting from the program, but is instead correctly characterized as activities and reductions associated with Program partners' reported activities. The Agency should exercise care to ensure that the data not be characterized inappropriately in program effectiveness measures, on the Program website, or in other communications. When this ICR is resubmitted for renewal, EPA should continue to address the extent to which the partners would have reduced their emissions in the absence of this program.
      
      EPA recognizes that some of the activities and emissions reductions reported by partners may have been achieved in the absence of the Program.  EPA also recognizes that there are emissions reductions occurring in the industry that have been a direct or indirect result of the influence of the Program, but that are not being reported to EPA.  EPA will continue to be clear in any Program-related communication that provides a summary or an aggregation of emission reductions that these reductions result from partners' reported activities.
      
      As discussed in prior ICR Supporting Statements, the extent to which Partners would have reduced emission in the absence of the Program is a challenging question. Natural Gas STAR Program partners are requested to submit Implementation Plans to describe the methane emissions reduction practices they plan to evaluate and implement. Partners are also asked to submit annual progress reports detailing their emission reduction activities during the previous calendar year. The Natural Gas STAR Program focuses on partner implementation of BMPs and PROs that were undertaken voluntarily, not reductions attributable to compliance with existing regulations. Because of increased state and local regulations focused on greenhouse gas emissions and air quality issues, the number of voluntary practices that would have counted as emission reductions achieved by Natural Gas STAR partners has been reduced in recent years. This trend is expected to continue in the future.
      
      The methane emission reductions reported by partners include reductions associated with the implementation of BMPs and through the adoption of PROs. PROs are activities identified by Natural Gas STAR partners, beyond the core BMPs, that result in methane emissions reductions. A significant portion of Natural Gas STAR's efforts in recent years has been devoted to promoting PROs by highlighting them on the Program's website, developing technical documents, and hosting technology transfer workshops. 
      
      The methane emission reduction data that are submitted to EPA are used to determine Program emission reduction totals and measure the overall effectiveness of the Natural Gas STAR Program. EPA does not attribute all methane emission reductions to the Program.   For example, Distribution BMP 2 -- Identify and Rehabilitate Leaky Distribution Pipes -- is an activity that is required by DOT regulations and is not included in our characterization of Program accomplishments.  Additionally, annual reports are reviewed to confirm check submitted datum are accurate and voluntary. Inconsistencies are resolved through EPA correspondence with the Natural Gas STAR partner company.  
      
      The Program aims to help partners overcome regulatory, informational, and other barriers that inhibit the implementation of methane emission reduction activities. Natural Gas STAR overcomes these barriers through a variety of activities including:
      
      -	Developing technical fact sheets, reports, and articles;
      -	Hosting Technology Transfer Workshops; and 
      -	Maintaining a mechanism for companies to record and store information regarding their methane reduction projects. 
      
      In addition to benefiting Natural Gas STAR partners, the above activities also benefit non-partner companies. For example, 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. Therefore, it is fair to assume that a substantial portion of the oil and natural gas industry (not participating in Natural Gas STAR) also implement some of the methane emission reduction activities promoted by the Program. 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 as outlined in the one-page Partnership Agreement. The Partnership Agreement provides general information on the Natural Gas STAR partner company and includes relevant points of contact. 
      
      Implementation plans and annual reporting are necessary to evaluate a partner's progress in implementing the Program and to assess overall Program results. The information shared also allows EPA to track the BMPs and PROs most commonly reported and to provide assistance to other partners. 
      
      
2(b)	Practical Utility/Users of the Data

      EPA uses the information provided in the Partnership Agreement to populate its contacts database/tracking system (including information on current and past Natural Gas STAR partners). This information serves as a source of general information and a mailing list. 
      
      EPA uses the information submitted in the Implementation Plans and annual reports to document the progress of partner companies in implementing the Program and reducing methane emissions. On an annual basis, EPA also aggregates these data and provides updated accomplishments information on its website and prepares partner summary reports. 
      
      With partner permission, EPA uses these data to develop technical documents on specific technologies and practices and prepare case studies showing successful implementation experiences. These documents are publicly available and demonstrate the benefits that can be realized through the implementation of technologies and practices. 

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a)	Nonduplication

      EPA implements Subpart W of the Greenhouse Gas Reporting Program (GHGRP) that requires companies to begin collecting methane emissions data as of January 1, 2011. The first year of mandatory greenhouse gas data collection for the oil and natural gas industry was 2011. While the data collected for GHGRP is methane emissions (rather than methane emission reductions), this information complements and augments data EPA has received from companies over the years. 
      
      The newly launched Methane Challenge Program also differs from Natural Gas STAR in that it expands on the existing Natural Gas STAR Program by creating a more open structure through which companies make specific, ambitious voluntary commitments and annually submit information through Subpart W of the GHGRP (with some additional voluntary supplemental data) that will be made publicly available on a company-specific level allowing transparent tracking of progress. This is a significant departure from Natural Gas STAR, where companies make a general commitment, participate at a range of levels (e.g., company-wide, facility or regional level), and only report information on emission reduction actions. Thus, the reporting requirements are very different between the two programs.

      The information to be obtained under this ICR is not collected by EPA or any other Federal agency.
      
3(b)	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 XXX (76 FR 6460). No comments were received in response to the notice.
      
3(c)	Consultations

      Since the last ICR Renewal, all information collection procedures for Natural Gas STAR have remained largely the same. EPA consulted with the following Implementation Managers regarding the burden estimate for this information renewal request: 
      
      Christina Fine
      Iroquois Gas Transmission
      One Corporate Drive, Suite 600
      Shelton, CT 06484
      (203) 944-7037
      
      Teresa Marion
      Seneca Resources
      51 Zents Blvd.
      Brookville, PA 15825
      Phone: (814) 220-1591
      
      Kelly Kinsman
      Extraction Oil and Gas
      8670 Wolff Court, Suite 135
      Westminster, CO 80031
      Phone: (970) 556-4712
      
        
3(d)	Effects of Less Frequent Collection

      The completion and submittal of the Partnership Agreement is a one-time activity for companies that voluntarily choose to become a partner in the Program. Partners agree to prepare and submit an Implementation Plan and to revise the plan as necessary. Partners also agree to submit annual reports. EPA believes that a reduction in the frequency of the information collection and submission of annual reporting data would impede efforts by EPA to evaluate the progress of partners in achieving their voluntary emission reductions.
                        
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 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. The Program discourages the submission of any sensitive or confidential information.

3(g)	Sensitive Questions
      No sensitive questions are asked in the Partnership Agreement, Implementation Plan, or the annual report.
      
      Regarding privacy of the information provided, any contact information for company representatives is used to identify the point of contact for implementation of the Natural Gas STAR. Such information will only be used to communicate and coordinate with Partner companies about their participation, such as annual reporting, attending upcoming Program workshops, and progress on their Program commitments. However, some information may be made available to public as required by the Freedom of Information Act, 5 U.S.C. § 552.
      

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:

      2111		Oil and Gas Extraction
      2212		Natural Gas Distribution
      4862		Pipeline Transportation of Natural Gas

4(b)	Information Requested

      EPA's Natural Gas STAR Program specifies requirements for partners. The following identifies the partnership forms contained in this ICR.  A detailed justification for each reporting requirement immediately follows.  Burden estimates are summarized in Exhibit A.
      
Partnership Agreement

      Companies that wish to become partners sign and submit a one-page Partnership Agreement with EPA which describes the terms of participation in the Program. The Partnership Agreement identifies company points of contact and initiates the partnership in the Program. This agreement replaces the previous Memorandum of Understanding (MOU) for the Program. The Partnership Agreement covering all industry segments under this ICR includes the following form:
      
  Natural Gas STAR Partnership Agreement:  EPA Form No. 5900-105
      
      (i)	Data items:

      Partners provide the following information in the Partnership Agreement:

 The name, title, address, telephone, and email address of a Natural Gas STAR Program Implementation Manager and a Media Liaison.
 The name and signature of the partners' Authorized Company Representative.

      (ii)	Respondent activities:

      In signing the Partnership Agreement, companies agree to perform the following activities:

 Download (from the Natural Gas STAR website) and review the one-page Partnership Agreement; 
 Gather requested information and complete the agreement; and
 Sign the agreement and submit it to EPA.
         
Implementation Plan

      Partners agree to complete and submit a Natural Gas STAR Implementation Plan within six to twelve months of signing the Partnership Agreement.  The Implementation Plan facilitates development of a strategy outlining how partners will identify non-regulatory methane emission reduction activities they intend to undertake, plan for new activities, and develop mechanisms for tracking methane emission reduction data and activities. An Implementation Plan is a living document that changes over time as each partner's goals and commitment evolve.  The Implementation Plan forms covered under this ICR include:
      
  Production Partners:  EPA Form No. 5900-103
 Transmission Partners:   EPA Form No. 5900-109
 Distribution Partners:  EPA Form No. 5900-97
 Gathering and Processing Partners:  EPA Form No. 5900-100
      
      (i)	Data items:

      The Implementation Plan form requests the following information:

 General company information (e.g., company name and contact, position, mail and e-mail addresses, telephone and facsimile numbers, etc.);
 Summary of activities that the partner intends to implement;
 Information on applicable BMPs that the partner might implement. The BMPs are sector specific and include the following (for example): 
 Directed inspection and maintenance at gate stations and surface facilities
 Identify and rehabilitate leaky distribution pipe
 Implement directed inspection and maintenance at compressor stations
 Use of turbines at compressor stations
 Identify and replace high bleed pneumatic devices
 Install flash tank separators on glycol dehydrators
 Convert gas pneumatics to instrument air systems
 Directed inspection and maintenance at gas plants and booster stations
 Information on PROs that the company chooses to evaluate and implement; and
 Plans to inventory past methane emission reductions as the Program encourages partners to report past emission reduction activities not previously reported to EPA.  

      (ii)	Respondent activities:

	Partners 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 as priorities shift overtime. The Plan is revised or updated by submitting a new form to EPA. 

Annual Report

      Annual reporting is a key requirement to remaining a partner in the Natural Gas STAR Program. After one full year of participation in the Program, partners agree to submit an annual report documenting the previous year's methane emission reduction activities. The report documents voluntary (non-regulatory driven) methane emission reduction activities that partner companies have implemented in the previous year, including corresponding methane emissions reductions achieved, and to the extent available, the economics associated with each activity.  Annual reports are submitted by partners almost exclusively through the on-line reporting tool. The annual reporting forms covered under this ICR include:
      
  Production Partners:  EPA Form No. 5900-104
 Transmission Partners:   EPA Form No. 5900-95
 Distribution Partners:  EPA Form No. 5900-99
 Gathering and Processing Partners:  EPA Form No. 5900-102
      
      (i)	Data items:

      The annual report form requests the following information:

 General company information (e.g., company name and contact, position, mail and e-mail addresses, telephone and facsimile numbers, period covered by report, etc.);
 Annual report summary;
 Information on Best Management Practices implemented. These are sector specific and reported as:
 Directed inspection and maintenance at gate stations and surface facilities
 Identify and rehabilitate leaky distribution pipe
 Implement directed inspection and maintenance at compressor stations
 Use of turbines at compressor stations
 Identify and replace high bleed pneumatic devices
 Install flash tank separators on glycol dehydrators
 Convert gas pneumatics to instrument air systems
 Directed inspection and maintenance at gas plants and booster stations
 Information on applicable PROs that the company implemented; and
 Information on additional program accomplishments that a partner wishes to share. This might include efforts to strengthen program participation (e.g., training/education, innovative technologies or activities, pilot projects, employee incentive programs) and/or efforts to communicate participation (e.g., newsletters, press releases, external website). 

      (ii)	Respondent activities:

      Partners conduct the following activities in preparing their 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.

Other Activities

      During participation in the Program, partners agree to notify EPA within two weeks if there is a change to the Natural Gas STAR Program Implementation Manager or Media Liaison responsibility.

      (i)	 Data items:

      As points of contact may change over time, partner companies agree to provide EPA with updated contact information for the designated Implementation Manager for the Program.

      (ii) 	Respondent activities:
      
      Notify EPA within two weeks of any change in Natural Gas STAR Implementation Manager or Media Liaison responsibility.	

5.	THE INFORMATION COLLECTED - AGENCY ACTIVITIES: COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a)	Agency Activities

      The Natural Gas STAR Program performs various activities after a partner submits an Partnership Agreement, Implementation Plan, or annual report. 
      
Partnership Agreement 
      
      EPA performs the following activities upon receipt of a Partnership Agreement:
      
 Review the agreement to ensure completeness and accuracy, and conduct follow up, if necessary;
       Countersign the agreement;
       Develop a cover letter and welcome packet with relevant program information;
       Copy the cover letters and agreements;
       Send cover letter, original agreement and welcome packet to partner;
       File copies of cover letters and agreements; and
       Enter agreement information into tracking database.
      
Implementation Plan
      
      EPA performs the following activities upon receipt of an Implementation Plan:
      
 Review the plan to ensure completeness and accuracy, and conduct follow-up, if necessary;
       Make copies of the plan for the program files;
       File copies of the plan; and
       Enter information into a tracking database.
      
Annual Report
      
      EPA performs the following activities upon receipt of an annual report:
      
 Review the report to ensure completeness and accuracy, and conduct follow-up, if necessary;
       Make copies of the report;
       File copies of the report; and
 Enter information into an emissions reduction data management database and review the entered data to ensure correctness (quality assurance and/or quality control).
      
Additional Activities
      
      EPA also enters any changes in partner's contact information into a database (e.g., Implementation Manager's responsibility and updates to newsletter mailing list). 
      
      Regarding privacy of the information provided, any contact information for company representatives is used to identify the point of contact for implementation of the Natural Gas STAR. Such information will only be used to communicate and coordinate with Partner companies about their participation in the Natural Gas STAR Program, such as annual reporting, attending upcoming Program workshops, and progress on their Program commitments. However, some information may be made available to public as required by the Freedom of Information Act, 5 U.S.C. § 552.
      
      Service Provider Directory 
      
      As a service to partner companies, EPA proposes to create a "service provider directory" to share information on services and technologies available to oil and natural gas companies seeking to reduce methane emissions from their operations. Third-party vendors (service providers) will complete an on-line form providing contact information and a short description of their technology, product or service in order to be added to the directory listing. EPA does not endorse any company or product in the directory. This contact information is provided to foster the exchange of information.   

5(b)	Collection Methodology and Management

      In collecting and analyzing the information associated with this ICR, EPA uses typical office equipment such as telephones, computers, and database and word processing software systems.
        
      For the collection of Program information, Natural Gas STAR has developed an on-line tool to assist partners. The Natural Gas STAR Partnership Agreement and Implementation Plan template are both available on the Program website in PDF format. Partners can submit data to EPA electronically via email, but EPA encourages partners to use the on-line reporting tool for this purpose. 
      
      EPA ensures the accuracy and completeness of collected information by reviewing each submission. EPA enters the information obtained from the Partnership Agreement, Implementation Plan, and annual reports into a database and aggregates data obtained from annual reports to track the progress of partners in reducing methane emissions.

5(c)	Small Entity Flexibility
      
      EPA has designed its Program forms and associated electronic reporting system to minimize respondent burden while obtaining sufficient and accurate information; the estimated burden cannot be further reduced for small entities. It should be noted that the estimated burden associated with the Natural Gas STAR Program is reduced over the course of a partner's participation based on the familiarity of the process partners gain over time. 

5(d)	Collection Schedule

      EPA collects initial partner information in the one-page Partnership Agreement, which is completed and submitted by each partner upon their decision to participate in the Program. The Implementation Plan is submitted by partners within six to twelve months of signing the Partnership Agreement. Each spring, EPA collects information in the annual report to monitor methane emissions reductions progress.  EPA may also collect other Program information on a periodic basis, such as notification of a change in Implementation Manager or changes in the operating circumstances of a company (change in ownership, assets, etc.).

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

      (i) Estimating Labor Costs
      EPA used a national average hourly labor rate including an hourly rate plus 60% overhead of $113.81 for legal staff, $109.06 for managerial staff, $84.88 for technical staff, and $46.38 for clerical staff. Legal, managerial, technical, and clerical labor rates were obtained from the Bureau of Labor and Statistics average rates for NAICS Code 541100 and 221200. Legal rates were based on lawyers, management wages were based on general and operations managers, technical wages were based on environmental engineers, and clerical rates were based on executive secretaries and administrative assistants. 
      
      (ii) Estimating Capital and Operations and Maintenance Costs
      
      EPA consulted with members of the oil and gas industry and believes that the capital or operations and maintenance costs of this Program are insignificant. Most Natural Gas STAR partners use the online reporting system to submit annual reports or submit reports via e-mail. Also, partners submit Partnership Agreements and Implementation Plans via e-mail as scanned PDFs.
      
      (iii) Capital/Start-up vs. Operating and Maintenance (O&M) Costs
      
      There are no capital/start-up costs or O&M costs associated with this information collection.
      
      (iv) Annualizing Capital Costs
      
      There are no capital costs associated with this information collection.

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 $103.34 for legal staff, $96.64 for managerial staff, $70.85 for technical staff, and $28.45 for clerical staff. To derive these estimates, EPA used the "Hourly Salary Table 2018 - 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-05, Step 1
      
      To derive the loaded hourly estimates, EPA 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 92 Natural Gas STAR Program partners. These oil and natural gas firms are a mix of large and relatively small companies. Based on recent trends, EPA anticipates an average of three companies will join the Program annually. This number is expected to remain constant or potentially fall as more companies join the Methane Challenge 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 2019-2021

                                Type of Partner
                                     2019
                                     2020
                                     2021
                                    Average
                                  New Partner
                                       3
                                       3
                                       3
                                       3
                            Total Program Partners
                                      95
                                      98
                                      101
                                      98


Partnership Agreement
      
      Each partner completes and submits a one-page Partnership Agreement to join the Program. EPA anticipates that three new partners will complete and submit an agreement each year. 

Implementation Plan
      
      Each new partner agrees to complete and submit the Implementation Plan within six to twelve months after joining the Program. EPA estimates that 5 existing partner companies will update the Implementation Plan and submit it to EPA each year.

Annual Report
      
      Existing partners agree to complete and submit an annual report after one full (calendar) year of joining the Program, and annually in subsequent years. EPA anticipates that the three new Program partners will join each year and complete and submit an annual report, and an average of 57 existing partners will complete and submit subsequent reports, for a total of 60 report submissions annually.
      

Additional Activities
      
      EPA estimates that approximately 15 Natural Gas STAR partners experience changes in their Implementation Manager and/or Media Liaison responsibilities each year. Thus, EPA estimates that 15 partners will notify EPA of changes in Implementation Manager and/or Media Liaison responsibilities.
      
Service Provider Directory
      
      EPA estimates that approximately 10 companies will complete the on-line form to promote the services and technologies they provide to oil and natural gas companies seeking to reduce methane emissions from their operations. 
EXHIBIT 1  -  ESTIMATED ANNUAL RESPONDENT BURDEN AND COST
                      INFORMATION COLLECTION ACTIVITY[1]
                    Hours and Costs Per Respondent/Activity
                             Total Hours and Costs
                                       
                                     Leg.
                                    $113.81
                                     Hour
                                     Mgr.
                                    $109.06
                                     Hour
                                     Tech.
                                    $84.88
                                     Hour
                                     Cler.
                                    $46.38
                                     Hour
                                    Respon.
                                    Hours/
                                   Activity
                                     Labor
                                     Cost/
                                   Activity
                                   Capital/
                                    Startup
                                     Cost
                                   O & M
                                     Cost
                                    Respon.
                                      or
                                  Activities
                                Number of Total
                                    Hours/
                                     Year
                                     Total
                                     Cost/
                                     Year
Partnership Agreement
 
 
 
 
 
                                                                              
 
 
 
 
 
  Receive and review the Partnership Agreement
                                       2
                                       8
                                      16
                                       4
                                      30
                                                                      $2,643.70
                                      $0
                                      $0
                                       3
                                      90
                                                                      $7,931.10
  Gather information and fill out Partnership Agreement data sheet
                                       1
                                      25
                                       0
                                       2
                                      28
                                                                      $2,933.07
                                      $0
                                      $0
                                       3
                                      84
                                                                      $8,799.21
  Sign and submit Partnership Agreement to EPA
                                       0
                                      0.5
                                       0
                                      0.5
                                       1
                                                                         $77.72
                                      $0
                                      $0
                                       3
                                       3
                                                                        $233.16
SUBTOTAL
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                      177
                                  $16,963.47
Implementation Plan
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                       

  Review instructions
                                       0
                                       2
                                       0
                                       0
                                       2
                                                                        $218.12
                                      $0
                                      $0
                                       3
                                       6
                                                                        $654.36
  Gather information and develop the Implementation Plan
                                       0
                                      10
                                      10
                                       0
                                      20
                                                                      $1,939.40
                                      $0
                                      $0
                                       3
                                      60
                                                                      $5,818.20
  Complete the form(s)
                                       0
                                       1
                                       0
                                       1
                                       2
                                                                        $155.44
                                      $0
                                      $0
                                       3
                                       6
                                                                        $466.32
  Sign and submit plan to EPA
                                       0
                                      0.5
                                       0
                                      0.5
                                       1
                                                                         $77.72
                                      $0
                                      $0
                                       3
                                       3
                                                                        $233.16
  Update Implementation Plan, as necessary and Submit to EPA
                                       0
                                      6.5
                                       4
                                      1.5
                                      12
                                                                      $1,117.98
                                      $0
                                      $0
                                       5
                                      60
                                                                      $5,589.90
SUBTOTAL
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                      135
                                  $12,761.94
Annual Report 
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                       

  Review instructions for the initial report
                                       0
                                       7
                                       0
                                       0
                                       7
                                                                        $763.42
                                      $0
                                      $0
                                       3
                                      21
                                                                      $2,290.26
  Gather the requested information for the initial report
                                       0
                                      10
                                      37
                                       0
                                      47
                                                                      $4,231.16
                                      $0
                                      $0
                                       3
                                      141
                                                                     $12,693.48
  Complete the initial form(s)
                                       0
                                       4
                                       0
                                       1
                                       5
                                                                        $482.62
                                      $0
                                      $0
                                       3
                                      15
                                                                      $1,447.86
  Sign and submit the initial report to EPA
                                       0
                                      0.5
                                       0
                                      0.5
                                       1
                                                                         $77.72
                                      $0
                                      $0
                                       3
                                       3
                                                                        $233.16
  Prepare and submit a subsequent Annual Report
                                       0
                                       9
                                      17
                                       1
                                      27
                                                                      $2,470.88
                                      $0
                                      $0
                                      57
                                     1539
                                                                    $140,840.16
SUBTOTAL
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                     1,719
                                  $157,504.92
Additional Activities
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                       

  Notify EPA within two weeks of any change in Natural
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                       

  Gas Star Implementation Manager responsibility
                                       0
                                       1
                                       0
                                      0.5
                                      1.5
                                                                        $132.25
                                      $0
                                      $0
                                      15
                                     22.5
                                                                      $1,983.75
TOTAL PARTNER ACTIVITIES
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                     2,054
                                  $189,214.08
Other Activities
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                       
                                       
Service Provider Directory Requests - Complete the form
                                       0
                                      .25
                                       0
                                       0
                                      .25
                                                                         $27.27
                                      $0
                                      $0
                                      10
                                      2.5
                                    $272.65
EXHIBIT 2  -  ESTIMATED ANNUAL AGENCY BURDEN AND COST
                        INFORMATION COLLECTION ACTIVITY
                    Hours and Costs for Agency Per Activity
                             Total Hours and Costs
                                       
                                     Leg.
                                    $103.34
                                     Hour
                                     Mgr.
                                    $96.64
                                     Hour
                                     Tech.
                                    $70.85
                                     Hour
                                     Cler.
                                    $28.45
                                     Hour
                                    Agency
                                    Hours/
                                   Activity
                                     Labor
                                     Cost/
                                   Activity
                                   Capital/
                                    Startup
                                     Cost
                                   O & M
                                     Cost
                                    Respon.
                                      or
                                  Activities
                                Number of Total
                                    Hours/
                                     Year
                                     Total
                                     Cost/
                                     Year
Partnership Agreement
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
                                       
 
Review agreement and follow up, if necessary
                                       0
                                       0
                                       1
                                       0
                                       1
                                                                         $70.85
                                      $0
                                      $0
                                       3
                                       3
                                                                       $212.55 
Sign the agreement
                                       0
                                     0.05
                                       0
                                       0
                                     0.05
                                                                          $4.83
                                      $0
                                      $0
                                       3
                                     0.15
                                                                        $14.50 
Develop a cover letter
                                       0
                                       0
                                       0
                                      0.1
                                      0.1
                                                                          $2.85
                                      $0
                                      $0
                                       3
                                      0.3
                                                                         $8.54 
Copy cover letters and agreements
                                       0
                                       0
                                       0
                                     0.08
                                     0.08
                                                                          $2.28
                                      $0
                                      $0
                                       3
                                     0.24
                                                                         $6.83 
Send cover letters and original agreement back to partner
                                       0
                                       0
                                       0
                                      0.1
                                      0.1
                                                                          $2.85
                                      $0
                                      $0
                                       3
                                      0.3
                                                                         $8.54 
File copies of cover letters and agreements
                                       0
                                       0
                                       0
                                      0.1
                                      0.1
                                                                          $2.85
                                      $0
                                      $0
                                       3
                                      0.3
                                                                         $8.54 
Enter agreement information into a data base
                                       0
                                       0
                                       0
                                     0.25
                                     0.25
                                                                          $7.11
                                      $0
                                      $0
                                       3
                                     0.75
                                                                        $21.34 
Subtotal
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                     5.04
                                                                        $280.82
Implementation Plan
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                       
 
Review plan and follow up, if necessary
                                       0
                                       0
                                       2
                                       0
                                       2
                                                                        $141.70
                                      $0
                                      $0
                                       8
                                      16
                                                                     $1,133.60 
Make copies of plan
                                       0
                                       0
                                       0
                                     0.08
                                     0.08
                                                                          $2.28
                                      $0
                                      $0
                                       8
                                     0.64
                                                                        $18.21 
File copies of plan
                                       0
                                       0
                                       0
                                      0.1
                                      0.1
                                                                          $2.85
                                      $0
                                      $0
                                       8
                                      0.8
                                                                        $22.76 
Enter information into data base
                                       0
                                       0
                                       0
                                     0.25
                                     0.25
                                                                          $7.11
                                      $0
                                      $0
                                       8
                                       2
                                                                        $56.90 
Subtotal
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                     19.44
                                                                      $1,231.47
Annual Report
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                       
 
Review report and follow up, if necessary
                                       0
                                       0
                                       4
                                       0
                                       4
                                                                        $283.40
                                      $0
                                      $0
                                      60
                                      240
                                                                    $17,004.00 
Make copies of report
                                       0
                                       0
                                       0
                                     0.08
                                     0.08
                                                                          $2.28
                                      $0
                                      $0
                                      60
                                      4.8
                                                                       $136.56 
File copies of report
                                       0
                                       0
                                       0
                                      0.1
                                      0.1
                                                                          $2.85
                                      $0
                                      $0
                                      60
                                       6
                                                                       $170.70 
Enter information into data base
                                       0
                                       0
                                       0
                                      0.5
                                      0.5
                                                                         $14.23
                                      $0
                                      $0
                                      60
                                      30
                                                                       $853.50 
Subtotal
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                     280.8
                                                                     $18,164.76
Additional Activities
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                       
 
Enter updated information into data base
                                       0
                                       0
                                       0
                                     0.25
                                     0.25
                                                                          $7.11
                                      $0
                                      $0
                                      15
                                     3.75
                                                                       $106.69 
Service Provider Directory Requests
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                       
                                                                               
Review forms
                                       0
                                       0
                                     0.25
                                       0
                                     0.25
                                                                         $17.71
                                      $0
                                      $0
                                      10
                                      2.5
                                                                        $177.13
TOTAL
                                       
                                       
                                       
                                       
                                       
                                                                               
                                       
                                       
                                       
                                    311.53
                                                                     $19,960.86
      
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. 
      
      (i)  Respondent Tally
      
      The total burden for Partner respondents is estimated to be approximately 2,054 hours per year with an annual cost of approximately $189,214. For vendors completing the Service Provide Directory form, the annual burden is estimated to be 2.5 hours and $1,984.  
      
      (ii)  The Agency Tally
      
      The total annual burden to the Agency is approximately 312 hours with a cost of approximately $19,961 per year. 
      
      (iii)  Variations In The Annual Bottom Line
      
      EPA anticipates minimal variation in the annual respondent reporting/recordkeeping burden over the three-year period covered by this ICR.

6(f)	Reasons for Change in Burden

      The overall annual reporting burden for Partner respondents decreased from 6,995 hours in the previous ICR to 2,054 hours in the current ICR. This change is attributed to the Program's maturity, a decrease in the number of companies joining Gas STAR, and a decrease in the estimated number of partners submitting reports annually. 
      
      The average burden per partner decreased to 22.3 hours per partner. This can be attributed to a larger percentage of partners using the online annual report forms and/or internal data collection systems, fewer new partners joining the program, and the maturity of the program.  Program information requested and the collection methodology did not change.  Partner use of the online reporting system has been steadily increasing each year since its availability to partners. 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 for Partners decreased from $390,185 to $189,214. 

6(g)	Burden Statement

      The average annual burden for information collection requirements associated with this ICR is estimated to be 22.3 hours per respondent. 
      
      For new partners, the average reporting burden per partner for information collection requirements associated with completing the Partnership Agreement is estimated to be 59 hours. The burden estimate includes time to receive and review the agreement; gather information and fill out the data sheet; and sign and submit the agreement to EPA.
      
      For new partners, the average reporting burden per partner for information collection requirements associated with completing the Implementation Plan is estimated to be 25 hours. The burden estimate includes time to 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 hours. The burden estimate includes time to review the reporting package (forms and any Program updates); gather the requested information; complete the form; sign and date the form; and submit the form to EPA. 
      
      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 and/or Media Liaison 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.
      
      

