SUPPORTING
STATEMENT
FOR
EPA
INFORMATION
COLLECTION
REQUEST
NUMBER
2173.01
REPORTING
REQUIREMENTS
UNDER
EPA'S
GREEN
POWER
PARTNERSHIP
AND
COMBINED
HEAT
AND
POWER
PARTNERSHIP
1
1.
IDENTIFICATION
OF
THE
INFORMATION
COLLECTION
1(
a)
Title
of
the
Information
Collection
This
information
collection
is
entitled
"
Reporting
Requirements
Under
EPA's
Green
Power
Partnership
and
CHP
Partnership",
ICR
number
2173.01.

1(
b)
Short
Characterization/
Abstract
In
an
effort
to
aid
implementation
of
the
President's
May
2001
National
Energy
Strategy,

as
well
as
the
President's
February
2002
Climate
Change
Strategy,
EPA
has
launched
two
new
partnership
programs
with
industry
and
other
stakeholders:
the
Green
Power
Partnership
and
the
Combined
Heat
and
Power
(
CHP)
Partnership.
These
partnership
programs
encourage
organizations
to
invest
in
clean,
efficient
energy
technologies,
including
renewable
energy
and
combined
heat
and
power.
To
continue
to
be
successful,
it
is
critical
that
EPA
collect
information
from
Green
Power
and
CHP
Partners
to
ensure
these
organizations
are
meeting
their
renewable
energy
and
CHP
goals
and
to
assure
the
credibility
of
these
partnership
programs.

EPA
has
developed
this
ICR
to
obtain
authorization
to
collect
information
from
organizations
participating
in
the
Green
Power
Partnership
and
CHP
Partnership.
Organizations
that
join
these
programs
voluntarily
agree
to
the
following
respective
actions:
(
1)
designating
a
Green
Power
or
CHP
Partnership
liaison
and
filling
out
a
letter
of
Intent
(
LOI);
(
2)
for
the
Green
Power
Partnership,
reporting
to
EPA,
on
a
annual
basis,
their
progress
toward
their
green
power
commitment
via
a
1­
page
reporting
form;
(
3)
for
the
CHP
Partnership,
reporting
to
EPA
information
on
their
existing
CHP
projects
and
CHP
project
development
activity.
EPA
uses
the
data
obtained
from
its
Partners
to
assess
the
success
of
these
programs
in
achieving
their
national
energy
and
greenhouse
gas
(
GHG)
reduction
goals.
Partners
are
entities
that
have
volunteered
to
participate
in
either
Partnership
program.

2.
NEED
FOR
AND
USE
OF
THIS
COLLECTION
2(
a)
Need/
Authority
for
the
Collection
The
EPA
needs
to
collect
the
information
in
the
LOI
to
formally
establish
participation
in
the
Green
Power
Partnership
or
CHP
Partnership
program
and
to
obtain
general
information
about
2
new
Partners.
Additional
information
collected
through
information
forms
is
needed
to
allow
EPA
to
track
Partner
progress
toward
meeting
their
commitments,
and
to
enable
the
programs
to
facilitate
and
provide
assistance
to
encourage
green
power
purchases
and
the
implementation
of
CHP
projects,
and
to
determine
progress
in
meeting
the
programs'
national
energy
and
GHG
reduction
goals.
This
information
collection
will
assist
the
Green
Power
Partnership
in
increasing
demand
for
the
use
of
renewable
energy
sources
for
power
generation
thereby
reducing
GHG
emissions.
The
information
will
also
help
the
CHP
Partnership
to
increase
the
use
of
more
efficient,
cleaner
power
generation
and
reduce
GHG
emissions.

Participation
in
the
Green
Power
Partnership
and
CHP
Partnership
is
voluntary.
Program
participants
agree
to
provide
EPA
with
the
requested
information.

2(
b)
Practical
Utility/
Users
of
the
Data
The
EPA
uses
information
submitted
in
the
LOI
to
update
its
database
of
Green
Power
or
CHP
Partners.
The
database
serves
as
a
source
of
general
information
and
a
mailing
list.
The
EPA
uses
information
submitted
in
additional
forms
to
monitor
the
progress
of
current
participation
and
projects
and
identify
new
opportunities.
The
EPA
also
uses
the
data
to
prepare
reports
on
Green
Power
Partnership
and
CHP
projects
and
progress
as
well
as
to
determine
the
GHG
reductions
achieved
by
the
programs.
EPA
uses
case
studies
of
successful
CHP
projects
to
demonstrate
to
existing
and
potential
Partners
the
cost
savings
and
environmental
benefits
associated
with
more
efficient
energy
production
through
CHP
projects.
General
information
on
the
Partners,
green
power,
and
CHP
is
also
provided
on
the
respective
Web
sites,
making
it
available
to
other
Partners
as
well
as
the
public.

3.
NONDUPLICATION,
CONSULTATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
For
new
Partners,
the
information
to
be
collected
has
not
previously
been
collected
by
EPA
or
any
other
Federal
Agency.
Existing
Green
Power
Partners
complete
only
the
Partner
Yearly
Report.
CHP
Partners
with
operational
CHP
projects
fill
out
a
one­
time
CHP
Partner
Projects
Data
Form
for
each
completed
project.
Existing
CHP
Partners
with
ongoing
CHP
project
3
development
activities
review
and
update
the
project
spreadsheet
every
six
months.
Other
CHP
Partners
have
no
annual
reporting
requirements.

For
existing
Partners
with
both
programs,
some
of
the
information
required
is
available
in
the
existing
databases
from
previous
submittals.
To
avoid
requesting
information
that
has
already
been
collected,
forms
sent
to
existing
Partners
will
be
filled­
in
with
information
from
the
database.

Recipients
of
the
forms
will
be
asked
to
review
the
information
provided.
Only
if
the
information
is
incorrect
or
out
of
date
will
the
recipients
be
required
to
provide
updated
or
additional
information.
To
further
reduce
burden,
EPA
will
provide
CHP
Partners
who
have
ongoing
project
development
activities
with
a
simple
spreadsheet
of
previously
submitted
project
data
that
they
can
review
and
revise
electronically
rather
than
filling
out
a
form.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
On
May
4,
2005,
in
compliance
with
the
Paperwork
Reduction
Act
of
1995,
EPA
solicited
public
comments
on
the
ICR
through
an
announcement
in
the
Federal
Register
(
70
FR
23152).

EPA
received
no
comments.

3(
c)
Consultations
The
EPA
consulted
with
three
Green
Power
Partner
and
three
CHP
Partners
regarding
the
burden
of
this
information
collection.

The
contacted
Partners
were
provided
copies
of
the
information
collection
forms,
and
asked
to
provide
estimates
of
the
associated
hourly
labor
burden.
Labor
wage
rates
from
the
Bureau
of
Labor
Statistics
(
BLS)
were
provided
for
reference
and
the
EPA
requested
comments
on
whether
these
labor
rates
were
appropriate.
The
Partners
all
provided
labor
hour
estimates
of
each
activity,
and
either
provided
labor
rates
or
indicated
that
the
BLS
rates
were
representative.

Generally,
the
estimates
provided
by
the
Partners
were
similar
and
were
consistent
with
EPA
expectations
of
the
labor
burden.

3(
d)
Effects
of
Less
Frequent
Collection
The
LOI
are
submitted
once
by
organizations
that
choose
to
become
Partners
of
the
Green
Power
Partnership
or
CHP
Partnership.
To
allow
EPA
to
remain
current
on
Partner
participation
and
determine
if
green
power
purchase
commitments
are
being
met,
Green
Power
Partners
will
be
4
asked
to
update
an
annual
report.
(
However,
green
power
provider
organizations
will
not
be
asked
to
report
on
an
annual
basis
because
green
power
purchase
targets
do
not
apply
to
them.)

CHP
end­
user
Partners
will
complete
a
project
information
form
at
the
completion
of
their
project.

All
CHP
Partners
with
ongoing
project
development
activities,
including
all
project
developers,

energy
service
companies,
consulting
engineers,
and
equipment
manufacturers,
and
approximately
25%
of
utility
Partners
will
review
their
project
information
and
provide
updates
every
6
months.

These
differences
in
reporting
requirements
reflect
the
varying
dynamics
of
the
data
contained
in
the
reports
for
the
different
subcategories
of
Partners.
Partners
of
both
programs
may
also
update
company
and
contact
information
periodically
via
the
Web
sites.
The
EPA
believes
that
any
reduction
in
the
frequency
of
this
information
collection
would
impede
efforts
by
EPA
to
evaluate
results
of
the
programs,
facilitate
green
power
purchases
and
CHP
project
implementation,
and
respond
in
a
timely
manner
to
needs
of
the
Partners.

3(
e)
General
Guidelines
This
information
collection
request
was
prepared
in
compliance
with
OMB's
and
EPA's
guidelines
for
ICR
preparation.
It
does
not
exceed
any
of
the
general
guidelines
found
at
5CFR
1320.05(
d)(
2).

3(
f)
Confidentiality
Participation
in
the
Green
Power
Partnership
and
CHP
Partnership
is
voluntary.

Participants
are
not
asked
to
reveal
confidential
business
information.
Additionally,
participants
will
be
given
specific
instructions
not
to
provide
any
information
that
they
consider
confidential.

3(
g)
Sensitive
Questions
No
questions
of
a
sensitive
nature
are
asked
in
any
of
the
forms
or
periodic
information
updates.
5
4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondent
NAICS/
SIC
Codes
This
information
collection
will
encompass
a
wide
variety
of
respondents
with
most
respondents
specific
to
either
the
Green
Power
Partnership
or
CHP
Partnership.

(
i)
CHP
Respondent
NAICS/
SIC
codes
The
CHP
Partnership
classifies
its
Partners
into
ten
categories.
State,
Local
and
Tribal
Partners
include
state
and
local
energy,
environmental,
and
economic
development
agencies
who
will
promote
CHP
development
in
their
area.
The
remaining
nine
categories
are
included
in
the
commercial
and
institutional
Partner
group.
End­
user
Partners
are
comprised
of
a
broad
range
of
industrial,
commercial,
or
institutional
organizations
who
utilize
CHP
technology
to
provide
heat
and
electricity
at
their
facilities.
Equipment
suppliers
are
involved
in
the
manufacturing,
supplying,

or
installation
of
CHP­
related
products.
Other
Partner
categories
can
be
classified
as
CHP
project
promoters
and
facilitators
who
work
to
create
new
CHP
projects.
These
Partners
include
energy
services
companies
(
ESCOs),
attorneys,
CHP
project
developers,
non­
government
organizations
(
NGOs),
financiers,
and
engineering
consultants.
Utility
Partners
work
to
provide
end­
users
with
fuel
for
their
CHP
projects
or
work
to
distribute
electricity
from
CHP
sources.
The
following
list
provides
the
most
common
NAICS/
SIC
codes
for
the
various
different
types
of
CHP
Partners:

NAICS
SIC
Description
State/
Local/
Tribal
Partners
92613
9651
Public
Administration,
Regulation
and
Administration
of
Communications,
Electric,
Gas,
and
Other
Utilities
926130
9631
Public
Administration,
Energy
development
and
conservation
programs
9611
9611
Public
Administration
of
General
Economic
Programs
924
9511
Public
Administration
of
Environmental
Quality
Programs
Equipment
Manufacturers
333611
3511
Turbine
and
turbine
generator
manufacturing
335999
3699
Fuel
cells,
electrochemical
generators,
manufacturing
541512
7373
Information
management
computer
systems
integration
design
services
541614
8742
Manufacturing
operations
improvement
consulting
services
CHP
project
promoters
and
facilitators
NAICS
SIC
Description
6
541110
8111
Offices
of
Lawyers
541690
8999
Energy
consulting
services
541330
8999
Engineering
consulting
services
523910
6153
6211
6799
Financial
Investments
and
Related
Activities,
Miscellaneous
Intermediation
Utilities
221122
4911
Electric
Power
Distribution
221210
4923
Natural
Gas
Distribution
End­
Usersa
325415
2834
Pharmaceutical
Preparation
Manufacturing
611310
8221
Colleges,
Universities,
and
Professional
Schools
322121
2611
2621
Pulp
and
Paper
Mills
336111
3711
Automobile
Manufacturing
813110
8661
Religious
Organizations
331111
3317
Steel
Mills
721110
7014
Hotel
Management
Services
a
There
is
a
wide
variety
of
entities
that
could
install
CHP
projects
and
become
CHP
end
users.
Any
facility
with
a
demand
for
both
electricity
and
thermal
energy
(
i.
e.,
steam,
heating,
or
cooling)
during
most
of
the
year
and
with
access
to
fuels
is
a
potential
candidate
for
a
CHP
end­
user
Partner.
For
this
reason,
only
a
subset
of
the
end­
users
is
listed
to
provide
examples.

(
ii)
Green
Power
Respondent
NAICS/
SIC
codes
The
Green
Power
Partners
consist
of
company,
institutional,
and
public
sector
organizations
that
pledge
to
purchase
a
proportion
of
their
annual
electricity
from
renewable
energy
through
one
of
three
purchasing
options.
Companies
include
both
service
and
goods
providing
industries,
institutions
are
comprised
of
institutes
of
higher
education
and
NGOs,
and
public
sector
Partners
are
local,
state,
or
federal
level
agencies.
For
purposes
of
this
ICR,
these
Partners
are
termed
"
full
scale
Partners."
In
the
future,
another
type
of
Partner,
green
power
"
providers",
may
be
invited
to
join
the
Green
Power
Partnership.
Providers
include
companies
that
supply
green
energy
to
consumers
and
traditional
electric
utilities
who
offer
a
green
power
option
to
their
customers.

NAICS
SIC
Description
Full­
scale
Partners
a
611310
8221
Colleges,
Universities,
and
Professional
Schools
NAICS
SIC
Description
7
722110
5812
5461
Restaurants
423390
5093
Automobile
Manufacturing
445110
5411
Grocery
Stores
323110
2752
Print
shops
621111
8093
Offices
of
Physicians
924
9511
Public
Administration
of
Environmental
Quality
Programs
92411
9631
Public
Administration
of
Air
and
Water
Resource
and
Solid
Waste
Management
Programs
928110
9711
Military
bases
and
camps
927110
9661
Public
Administration
of
Space
Research
and
Technology
Provider
Partnersb
221119
4939
Other
Electric
Power
Generation
221122
4931
Electric
Power
Distribution
aGiven
the
breadth
of
industries
who
are
currently
Green
Power
Partners,
only
a
subset
of
their
NAICS/
SIC
codes
is
listed
to
provide
examples.
bCurrently
there
are
no
existing
provider
Partners
so
this
list
includes
example
NAICS/
SIC
of
some
potential
provider
Partner
categories.

4(
b)
Information
Requested
(
i)
Data
Items,
Including
Recordkeeping
Requirements
Green
Power
Partnership.
Information
will
be
collected
in
LOI,
Partner
Yearly
Reports,

clarification
follow­
ups
and
calls
or
e­
mails
as
needed.
Each
activity
is
described
below.

The
LOI
request
the
following
information
from
all
Partners:

$
Organization
name;

$
Name
of
entity/
entities
joining
Partnership;

$
Total
electric
load
and
green
power
purchase
commitment;

$
Signature
and
printed
name
and
title
of
authorized
representative;

$
Contact
information
about
Green
Power
Partnership
liaison,
including
name,
title
address,
phone
number,
fax
number
and
e­
mail
address;
and
$
Questions
about
current
green
power
usage.

The
Partner
Yearly
Reports
collect
or
update
the
following
information:
8
$
Liaison
information
listed
above;

$
Commitment
details,
including
total
annual
energy
consumption,
annual
green
power
commitment;

$
Purchase
details
such
as
retailer
name,
the
delivered
electricity
product,
renewable
energy
credits,
or
on­
site
generation;
and
$
Breakdown
of
green
power
sources
used.

A
company
profile
and
contact
information
will
be
available
on
the
Green
Power
Partnership
Web
site.
Partners
may
submit
corrections
or
updates
via
the
Web
site
at
any
time.

EPA
will
also
place
follow­
up
calls
to
clarify
any
unclear
information
submitted
by
Partners.

Occasionally,
EPA
may
request
technical
information
in
addition
to
the
standard
forms.

This
information
will
be
requested
on
a
voluntary
basis
from
a
subset
of
Green
Power
Partnership
Partners.
For
instance,
information
may
be
requested
from
the
twenty­
five
largest
green
power
purchasers
in
order
to
feature
them
on
the
GPP
Web
site.
Requested
information
may
also
be
used
to
target
outreach
efforts
more
effectively.

CHP
Partnership.
Information
will
be
collected
in
LOI
and
CHP
Partners
Project
Data
forms.
The
LOI
requests
only
the
organization's
name
and
the
name,
title
and
signature
of
the
organization
representative
authorizing
participation
in
the
Partnership,
Partner's
liaison
contact
information,
and
type
of
company/
organization.
Partner
Projects
Data
Forms
or
spreadsheets
will
also
be
used
to
collect
information
on
completed
or
planned
CHP
projects.

The
1­
page
CHP
Partner
Projects
Data
Form
for
Operational
CHP
Projects
will
be
completed
by
company
or
institutional
Partners
involved
in
operational
CHP
projects.
The
form
is
completed
one
time
for
each
operational
project.
The
requested
information
includes:

°
Project
Owner;

°
Project
Name
and
address;

°
Facility
description;

°
Project
information
including
start­
up
date,
fuel
type,
average
fuel
input,
annual
operating
hours,
average
net
power
output,
thermal
energy
availability,
thermal
output
used,
percentage
of
electricity
sold
offsite
or
to
grid
and
percentage
of
thermal
output
sold
offsite;
9
°
List
of
each
prime
mover,
including
size,
fuels
and
emission
controls;

°
Types
and
applications
of
thermal
output;

°
Contact
information
including
the
company
name,
contact
name,
phone
number
and
date
submitted;
and
°
Project
team
information
including
the
engineer,
prime
contractor,
project
developer
and
thermal
host.

CHP
Partners
with
ongoing
project
development
activities
will
be
asked
to
provide
similar,

but
less
detailed,
information
on
planned
projects
by
filling
out
a
Planned
CHP
Projects
Data
Form
or
entering
the
information
in
an
electronic
spreadsheet.
After
the
first
submittal,
EPA
will
periodically
send
the
Partner
spreadsheets
containing
all
previously­
submitted
information
on
planned
projects
for
the
Partner
to
review
and
update.

A
company
profile
and
contact
information
will
be
available
on
the
CHP
Partnership
Web
site.
Partners
may
submit
corrections
or
updates
via
the
Web
site
at
any
time.
EPA
will
also
place
follow­
up
calls
to
clarify
any
unclear
information
submitted
by
Partners.

Participation
in
Green
Power
Partnership
and
CHP
does
not
require
any
records
to
be
kept,

although
Partners
will
likely
keep
file
copies
of
LOI
and
CHP
Partner
Projects
Data
Forms
information
forms
submitted
to
EPA.

(
ii)
Respondent
Activities
The
respondent
activities
depend
on
the
aspect
of
the
information
collection
to
which
they
are
responding.
In
completing
the
LOI,
respondents
will:

$
review
the
form;

$
complete
the
form;

$
sign
and
submit
the
form
electronically
or
via
fax
or
mail
to
EPA;
and
$
file
a
copy
of
the
form.

In
completing
the
Green
Power
Partner
Yearly
Report
or
CHP
Partner
Projects
Data
Form,

respondents
will:

$
read
the
forms
and
instructions;
10
$
complete
the
form
if
they
are
new
Partners
who
have
not
previously
submitted
data.

$
review
pre­
populated
data
if
they
are
existing
Partners
who
have
previously
submitted
data;

$
update
information
where
necessary;

$
submit
the
form
(
or
CHP
project
spreadsheet)
electronically
or
via
fax
or
mail
to
EPA;
and
$
file
a
copy
of
the
form.

In
replying
to
or
initiating
an
information
update
or
clarification,
respondents
will:

$
gather
information;
and
$
provide
information
via
the
Green
Power
Partnership
or
CHP
Partnership,
Web
site,
e­
mail,
or
telephone
interview.

5.
THE
INFORMATION
COLLECTED
­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a)
Agency
Activities
(
i)
Agency
Activities
for
Green
Power
Partnership
and
CHP
Partnership
LOIs
Agency
activities
associated
with
this
information
collection
depend
on
the
aspect
of
the
information
collection
that
the
agency
has
received.
In
receiving
the
LOI
for
either
the
Green
Power
Partnership
or
CHP
Partnership,
the
agency
will:

$
review
the
information
provided;

$
enter
the
information
into
a
database;

$
file
the
form.

(
ii)
Agency
Activities
for
Green
Power
Partnership
Agency
activities
specific
to
the
Green
Power
Partnership
will
depend
on
the
types
of
activities
the
agency
will
initiate
and
receive.
In
requesting
and
receiving
the
information
through
a
11
Partner
Yearly
Report
Form
sent
to
Partners
within
one
year
after
they
join
the
Partnership,
the
agency
will:

$
prepare
and
mail
annual
forms;

$
receive
and
review
the
information
provided
on
completed
forms;

$
enter
the
information
into
a
database;
and
$
file
the
form.

In
requesting
and
receiving
information
through
an
information
form
to
Partners
who
have
previously
completed
the
Partner
Yearly
Report
Form,
the
agency
will
annually:

$
populate
Partners'
forms
with
the
previous
year's
information
for
each
Partner,
and
mail
the
forms
to
the
Partners;

$
receive
and
review
any
updates
provided
from
the
Partner
on
the
form;

$
enter
updated
information
from
the
form
into
a
database;

$
file
the
form.

In
initiating
information
updates
and
follow­
ups,
the
Agency
will:

$
call
or
email
Partners;

$
request
updated
information
or
clarification
on
LOIs
or
Partner
Yearly
Report
Forms
by
telephone
or
e­
mail;

$
request
additional
technical
information,
as
needed,
from
a
subset
of
Green
Power
Partners;
and
$
revise
data
in
the
database
based
on
these
updates.

In
receiving
information
updates
via
the
Web
site,
the
Agency
will:

$
review
the
data
received
on
the
Green
Power
Partnership
Web
site;
and
$
revise
data
in
the
database
based
on
the
updates.

(
iii)
Agency
Activities:
CHP
Partnership
12
Agency
activities
specific
to
the
CHP
Partnership
will
also
depend
on
the
types
of
activities
the
agency
will
initiate
and
receive.
In
requesting
and
receiving
the
information
on
CHP
projects
through
an
information
form
sent
to
Partners
within
the
same
year
they
join
the
Partnership,
the
agency
will:

$
prepare
and
mail
the
CHP
Partner
Projects
Data
Forms;

$
receive
and
review
the
information
provided
on
completed
forms;

$
enter
the
information
into
a
database;
and
$
file
the
form.

In
requesting
and
receiving
information
on
ongoing
project
development
activities
through
a
CHP
project
spreadsheet
already
populated
with
information
provided
on
a
Partner's
initial
project
reporting
form
or
most
recent
project
spreadsheet,
the
agency
will,
twice
a
year:

$
populate
the
Partners'
spreadsheets
with
the
project
information
from
the
most
recent
project
forms
or
spreadsheets,
which
is
contained
in
the
CHP
project
database;

$
email
the
pre­
populated
spreadsheets
to
the
appropriate
Partners;

$
receive
and
review
any
updates
provided
from
the
Partner
on
the
spreadsheet;

$
enter
updated
information
from
the
spreadsheet
into
a
database;

$
file
the
spreadsheet.

In
initiating
information
updates
and
follow­
ups,
the
Agency
will:

$
call
or
email
Partners;

$
request
updated
information
or
clarification
on
LOIs
or
CHP
Partner
Projects
Data
Forms;
and
$
revise
data
in
the
database
based
on
the
updates.

In
receiving
information
updates
via
the
Web
site,
the
Agency
will:
13
$
review
the
data
received
on
the
CHP
Partnership
Web
site;
and
$
revise
data
in
the
database
based
on
the
updates.

5(
b)
Collection
Methodology
and
Management
The
methods
selected
for
this
information
collection
are
chosen
based
on
efficiency
and
minimization
of
burden
for
respondents
and
EPA.
The
LOIs
can
be
downloaded
from
the
appropriate
Web
site
and
returned
to
EPA
either
by
fax
or
mail,
or
submitted
electronically.

General
Partner
information
will
be
posted
on
the
Green
Power
Partnership
or
CHP
Partnership
Web
site
where
it
can
be
reviewed
for
accuracy
by
the
Partners
and
revised
if
necessary.

Information
forms
will
be
available
for
Partners
electronically
on
each
Web
site
and
can
be
returned
by
fax,
mail,
or
e­
mail.
In
addition,
the
Green
Power
Partnership
will
send
pre­
populated
information
forms
to
Partners
each
year
containing
the
information
previously
submitted.
Partners
need
only
review
the
information
for
accuracy
and
submit
any
updates,
thus
minimizing
the
burden
of
the
respondents.
To
further
reduce
burden,
EPA
will
provide
CHP
Partners
who
have
ongoing
project
development
activities
with
a
simple
spreadsheet
of
previously
submitted
project
data
that
they
can
review
and
revise
electronically
rather
than
filling
out
a
form.
All
information
received
through
the
forms
(
electronically
or
via
hard
copy)
will
be
reviewed
by
EPA
before
being
entered
into
the
database.

5(
c)
Small
Entity
Flexibility
The
EPA
expects
that
some
Green
Power
Partners
and
CHP
Partners
are
small
entities.

EPA
has
designed
its
approach
for
this
information
collection
to
minimize
burden
for
all
respondents
while
obtaining
sufficient
and
accurate
information.
The
data
requested
includes
only
the
most
critical
information
and
may
be
submitted
electronically.
EPA
has
removed
from
the
Green
Power
Partnership
LOI
requests
for
detailed
information
and
asks
only
about
the
type
of
product
the
Partner
sells
or
purchases,
if
the
purchase
has
been
made
and
a
contact
name
at
the
green
power
supplier.
As
discussed
above,
for
both
Partnership
programs
EPA
pre­
populates
forms
or
spreadsheets
with
information
previously
submitted
to
avoid
duplication
of
effort
and
minimize
the
burden
for
respondents.
Additionally,
participation
in
Green
Power
Partnership
and
14
CHP
is
voluntary.
Any
small
entity
that
finds
the
information
collection
overly
burdensome
is
not
required
to
participate.

5(
d)
Collection
Schedule
The
EPA
will
collect
general
information
from
all
new
Partners
in
either
the
Green
Power
Partnership
or
CHP
Partnership
in
the
LOI,
which
is
completed
and
submitted
by
each
Partner
upon
their
agreement
to
participate
in
the
program.
In
addition,
Green
Power
Partners
will
be
asked
to
complete
a
Partner
Yearly
Report
once
per
year.
In
addition,
a
subset
of
Green
Power
Partners
may
occasionally
be
asked
to
provide
additional
information
specific
to
their
sector
or
to
an
aspect
of
the
Green
Power
Partnership
program.
Company
and
institutional
CHP
Partners
with
operational
projects
will
fill
out
a
Partner
Projects
Data
Form
one
time
for
each
operational
project.
Certain
CHP
Partners
with
ongoing
project
development
activities
will
be
asked
to
review
and
update
a
project
data
spreadsheet
every
six
months.

6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Estimating
Respondent
Burden
In
order
to
obtain
accurate
hourly
burden
and
cost
estimates,
EPA
consulted
with
six
Partners
(
respondents)
from
the
Green
Power
Partnership
and
the
CHP
Partnership.
These
responses
were
averaged
to
estimate
the
hourly
burden
for
each
activity
and
the
labor
rates.
The
hourly
burden
for
each
activity
was
multiplied
by
the
number
of
Partners
(
respondents)
performing
the
activity
each
year
to
estimate
the
total
burden.
Capital,
operation
and
maintenance
costs
were
also
considered.
Attachment
1
presents
the
estimated
annual
respondent
burden
and
costs
for
information
collection
activities
associated
with
the
Green
Power
Partnership
for
each
year
of
the
collection.
Attachment
3
presents
the
estimated
annual
respondent
burden
and
costs
for
information
collection
activities
associated
with
the
CHP
Partnership
for
each
year
of
the
collection.
Table
1
in
Section
6(
e)
of
this
supporting
statement
presents
a
summary
of
the
overall
respondent
burden
for
both
the
Green
Power
and
CHP
Partnerships
for
each
of
the
three
years
as
well
as
the
total
burden
and
the
annual
average
burden.

6(
b)
Estimating
Respondent
Costs
15
Respondent
labor
rates
came
from
direct
consultations
with
three
current
Green
Power
Partners
and
three
current
CHP
Partners.
These
consultations
did
not
include
benefits.
A
loaded
labor
rate
to
reflect
benefits
and
overhead
for
the
respondent
organizations
was
calculated
by
applying
a
110%
factor
to
the
average
of
the
base
rates
received
from
the
consultations.
Loaded
rates
are
$
153.56
for
legal
staff,
$
82.80
for
managerial
staff,
$
66.47
for
technical
staff,
and
$
30.35
for
clerical
staff.

For
CHP
State/
Local/
Tribal
Agency
Partners,
EPA
used
the
same
labor
rates
used
for
EPA
personnel
(
see
Section
6(
c)).
These
rates
are
comparable
to
rates
provided
by
a
state
Partner
and
using
them
for
all
public­
sector
employees
provides
consistency.
Labor
rates
for
management
staff
of
public­
sector
respondents
were
used
to
represent
labor
rates
for
legal
staff
of
public­
sector
respondents.

(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs
Because
this
information
collection
requires
respondents
only
to
report
information
that
is
already
available
to
them,
there
are
no
capital
costs.
The
EPA
does
not
expect
that
the
operations
and
maintenance
(
O&
M)
costs
of
this
program
will
be
significant.
The
only
O&
M
costs
expected
are
for
postage
required
to
return
any
completed
forms,
long
distance
fax
charges
if
the
forms
are
faxed
instead
of
mailed,
and
costs
to
copy
the
forms
if
Partners
wish
to
retain
them
on
file.
A
submittal
cost
of
$
3
is
attributed
to
all
activities
involving
mailing
materials
to
account
for
the
use
of
trackable
mail
or
long
distance
fax
and
copying.
If
Partners
choose
to
submit
forms
electronically,
their
costs
will
be
lower
than
estimated.
The
average
annual
O&
M
cost
over
three
years
is
$
3,248.

6(
c)
Estimating
Agency
Burden
and
Costs
Attachments
2
and
4
present
the
estimated
Agency
burden
hours
and
costs
for
the
information
collection
activities
associated
with
Green
Power
Partnership
and
CHP
Partnership,

respectively.
Table
2
presents
a
summary
of
the
agency
burden
for
both
programs
and
the
total
burden.
EPA
estimates
an
average
hourly
labor
cost
(
labor
plus
60%
for
overhead)
of
$
67.26
for
managerial
staff,
$
48.39
for
technical
staff,
and
$
21.23
for
clerical
staff.
To
derive
these
estimates,

EPA
used
the
"
Salary
Table
2004
­
GS
Salary
Table
of
Annual
Rates
by
Grade
and
Step"
from
the
16
Department
of
Personnel
Management.
For
purposes
of
this
ICR,
EPA
assigned
staff
the
following
government
service
levels:

$
Managerial
Staff
­
GS­
15,
Step
5
$
Technical
Staff
­
GS­
13,
Step
1
$
Clerical
Staff
­
GS­
5,
Step
1
6(
d)
Estimating
the
Respondent
Universe
Green
Power
Partnership.
A
total
of
500
Green
Power
Partners
is
expected
by
the
end
of
2004.
The
EPA
anticipates
that
250
new
Partners
will
join
the
program
each
year
in
2005
and
2006,
with
an
additional
25
green
power
providers
joining
in
2006.
Approximately
300
Partners
and
25
provider
Partners
are
expected
to
join
in
2007.
Each
of
the
new
Partners
(
all
types)
are
required
to
complete
the
LOI
forms,
and
all
participating
Partners
except
green
power
providers
are
expected
to
fill
out
or
update
the
Partner
Yearly
Report,
starting
the
year
after
they
join.

The
average
annual
number
of
respondents
over
three
years
is
1,033.
The
number
of
respondents
in
each
of
the
three
years
of
this
information
collection
and
the
average
over
the
3­
year
period
are
shown
in
Table
1
in
Section
6(
e)
of
this
supporting
statement.

CHP
Partnership.
A
total
of
160
Partners
is
expected
by
the
end
of
2004.
The
EPA
anticipates
28
new
Partners
will
join
the
program
each
year
in
2005
and
2006
and
29
in
2007.
Of
these
new
respondents,
it
is
assumed
that
there
are
five
new
Partners
per
year
in
each
of
the
following
categories:
end­
users,
project
developers,
consulting
engineers,
equipment
manufacturers,
and
utilities,
with
an
additional
three
Partners
belonging
to
State/
local/
tribal
governments
per
year
(
four
in
2007).
Each
of
the
new
Partners
is
expected
to
fill
out
an
LOI.
All
of
the
new
end­
users,
project
developers,
consulting
engineers,
and
equipment
manufacturers
and
25%
of
new
utility
Partners
will
complete
the
CHP
Partner
Projects
Data
Form
within
the
same
year
they
join
the
Partnership.
New
State/
Local/
Tribal
Agency
Partners
do
not
fill
out
project
forms.
All
of
the
existing
project
developers,
ESCOs,
consulting
engineers
and
equipment
manufacturers,
and
25%
of
the
existing
utilities
will
continue
to
review
their
project
information
and
provide
updates
every
6
months
in
a
project
spreadsheet
starting
in
the
year
after
they
join
the
Partnership.
17
The
average
annual
number
of
total
respondents
over
three
years
is
131.
The
number
of
respondents
in
each
of
the
three
years
of
this
information
collection
and
the
average
over
the
3­
year
period
are
shown
in
Table
1.

6(
e)
Bottom
Line
Burden
Hours
and
Costs
Green
Power
Partnership.
Attachments
1
and
2
show
the
detailed
annual
burden
and
cost
to
respondents
and
the
government,
respectively,
for
the
information
collection
activities
associated
with
Green
Power
Partnership.
The
results
are
summarized
in
Tables
1
and
2.
The
total
annual
burden,
averaged
over
the
three­
year
period,
is
3,372
hours
and
$
255,447
per
year
for
respondents
and
1,101
hours
and
$
52,435
per
year
for
EPA.
(
See
Tables
1
and
2
for
these
average
numbers.)
The
bottom
line
burden
for
respondents
will
be
the
least
in
year
1
and
will
gradually
increase
in
years
2
and
3.
This
is
because
there
are
more
Partners
responding
in
years
2
and
3.

The
burden
per
respondent
is
similar
in
all
3
years.
In
years
1,
2,
and
3,
new
Partners
will
complete
an
LOI.
In
years
1,
2,
and
3,
existing
Partners
will
complete
or
update
information
in
the
Partner
Yearly
Report
Form
as
needed.
After
the
first
submittal,
EPA
will
provide
the
information
previously
submitted
by
existing
Partners
and
only
ask
for
updates.
Similarly,
the
Agency
burden
is
the
least
in
year
1
and
will
gradually
increase
in
years
2
and
3
as
EPA
has
more
information
submittals
to
review
and
enter
into
the
database.
See
Tables
1
and
2
for
respondent
and
agency
burdens
in
each
of
the
three
years.

CHP
Partnership.
Attachments
3
and
4
show
the
detailed
annual
burden
and
cost
to
respondents
and
the
government,
respectively,
for
the
information
collection
activities
associated
with
CHP.
The
results
are
summarized
in
Tables
1
and
2.
The
total
annual
burden,
averaged
over
the
three­
year
period,
is
608
hours
and
$
43,439
for
respondents
and
325
hours
and
$
15,928
for
EPA.
(
See
Tables
1
and
2
for
these
average
numbers.)
The
bottom
line
burden
for
respondents
will
be
the
least
in
year
1
and
will
gradually
increase
in
years
2
and
3.
This
is
because
there
are
more
Partners
responding
in
years
2
and
3.
The
burden
per
respondent
is
similar
in
all
3
years.
In
years
1,
2,
and
3,
new
Partners
will
complete
an
LOI.
If
a
new
Partner
has
direct
involvement
in
CHP
projects,
they
will
submit
project
forms
in
the
year
they
join.
In
years
1,
2,
and
3,
existing
Partners
will
be
updating
information
only
as
needed.
For
Partners
with
ongoing
project
development
activities,
EPA
will
provide
the
information
previously
submitted
by
the
existing
Partners
in
a
spreadsheet
and
only
ask
for
updates.
Similarly,
the
Agency
burden
is
the
least
in
18
year
1
and
will
gradually
increase
in
years
2
and
3
as
EPA
has
more
information
submittals
to
review
and
enter
into
the
database.
See
Tables
1
and
2
for
the
respondent
and
agency
burdens
in
each
of
the
three
years.

Total.
Considering
both
the
Green
Power
Partnership
and
the
CHP
Partnership,
the
combined
total
annual
burden
(
averaged
over
a
3­
year
period)
is
3,980
hours
and
$
298,886
per
year
for
respondents
and
1,426
hours
and
$
68,363
per
year
for
EPA.
Tables
1
and
2
show
the
breakout
between
labor
costs
and
O&
M
costs.
The
burden
estimates
reflect
an
average
of
1,164
respondents
per
year.
The
average
annual
burden
per
respondent
is
3.4
hours
and
$
257
per
year.

TABLE
1.

ESTIMATED
TOTAL
RESPONDENT
BURDEN
AND
COST
FOR
GPP,
CHP
and
COMBINED
Year
1
Year
2
Year
3
Total
Annual
Average
Green
Power
Partnership
Program
Number
of
Respondents
750
1,025
1,325
3,100
1,033
Hours
2663
3,328
4,126
10,116
3,372
Labor
Costs
$
197,351
$
249,182
$
310,509
$
757,042
$
252,347
O&
M
Costs
$
2,250
$
3,075
$
3,975
$
9,300
$
3,100
TOTAL
Costs
$
199,601
$
252,257
$
314,484
$
766,342
$
255,447
CHP
Partnership
Program
Number
of
Respondents
115
131
148
394
131
Hours
517
621
686
1,824
608
Labor
Costs
$
36,788
$
44,235
$
48,850
$
129,873
$
43,291
O&
M
Costs
$
147
$
147
$
150
$
444
$
148
TOTAL
Costs
$
36,935
$
44,382
$
49,000
$
130,317
$
43,439
Combined
Totals
for
Both
Programs
Number
of
Respondents
865
1,156
1,473
3,494
1,164
Hours
3,180
3,949
4,812
11,940
3,980
Labor
Costs
$
234,139
$
293,417
$
359,359
$
886,915
$
295,638
O&
M
Costs
$
2,397
$
3,222
$
4,125
$
9,744
$
3,248
TOTAL
Costs
$
236,536
$
296,639
$
363,484
$
896,659
$
298,886
Average
annual
hour
per
respondent
­
­
­
­
3.4
Average
annual
costs
per
respondent
­
­
­
­
$
257
TABLE
2.
ESTIMATED
TOTAL
AGENCY
BURDEN
AND
COST
FOR
GPP,
CHP
and
COMBINED
Year
1
Year
2
Year
3
Total
Annual
Average
TABLE
2.
(
Continued)

19
Green
Power
Partnership
Program
Number
of
Respondents
750
1,025
1,325
3,100
1,033
Hours
777
1,094
1,432
3,303
1,101
Labor
Costs
$
36,190
$
49,873
$
64,492
$
150,555
$
50,185
O&
M
Costs
$
1,500
$
2,250
$
3,000
$
6,750
$
2,250
TOTAL
Costs
$
37,690
$
52,123
$
67,492
$
157,305
$
52,435
CHP
Partnership
Program
Number
of
Respondents
115
131
148
394
131
Hours
282
325
368
974
325
Labor
Costs
$
13,783
$
15,860
$
17,953
$
47,596
$
15,865
O&
M
Costs
$
63
$
63
$
63
$
189
$
63
TOTAL
Costs
$
13,846
$
15,923
$
18,016
$
47,785
$
15,928
Combined
Totals
for
Both
Programs
Number
of
Respondents
865
1,156
1,473
3,494
1,164
Hours
1,058
1,419
1,800
4,277
1,426
Labor
Costs
$
49,973
$
65,733
$
82,445
$
198,151
$
66,050
O&
M
Costs
$
1,563
$
2,313
$
3,063
$
6,939
$
2,313
TOTAL
Costs
$
51,536
$
68,046
$
85,508
$
205090
$
68,363
6(
f)
Reasons
for
Change
in
Burden
This
section
does
not
apply
since
this
is
a
new
information
collection
request.

6(
g)
Burden
Statement
The
annual
public
reporting
and
recordkeeping
burden
for
this
three
(
3)
year
collection
of
information
is
estimated
to
equal
3,980
hours
and
to
average
3.4
hours
per
year
per
respondent.

The
average
number
of
annual
burden
hours
per
type
of
response
is:
4.9
hours
for
a
Letter
of
Intent
(
a
one­
time
burden
for
Green
Power
and
CHP);
for
the
Green
Power
Partnership,
2.4
hours
for
the
Partner
Yearly
Report;
for
the
CHP
Partnership,
2.0
hours
for
end
user
Partners
to
report
on
completed
CHP
projects
(
a
one­
time
report),
or
1.7
hours
per
year
for
CHP
project
updates
for
Partners
with
ongoing
CHP
project
development
activities.

Partners
from
both
programs
may
also
submit
voluntary
updates
of
simple
information,
such
as
contact
information
or
company
profiles,
via
the
Web
site.
These
updates
would
take
from
15
minutes
to
0.5
hours
per
response.
A
subset
of
Partners
may
participate
in
brief
(
i.
e.,
15
minute)

telephone
calls
with
EPA
to
clarify
questions
pertaining
to
the
LOI,
Green
Power
Partner
Yearly
Report,
or
CHP
Partner
project
reporting.
All
of
these
activities
are
included
in
the
annual
burden
estimate.
20
The
estimated
number
of
annual
respondents
averaged
over
three
(
3)
years
is
1,164,
which
includes
an
average
of
1,033
respondents
for
the
Green
Power
Partnership
and
131
respondents
for
the
CHP
Partnership.

There
are
no
capital
or
start­
up
costs
associated
with
this
information
collection.
The
average
annual
operation
and
maintenance
cost
resulting
from
this
three
year
collection
of
information
is
$
3
per
respondent.
The
average
annual
labor
cost
is
$
254
per
respondent.
The
resulting
total
annual
cost
averaged
over
the
three
year
period
is
$
298,886.
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.

To
comment
on
the
Agency's
need
for
this
information,
the
accuracy
of
the
provide
burden
estimates,
and
any
suggested
methods
for
minimizing
respondent
burden,
including
the
use
of
automated
collection
techniques,
EPA
has
established
a
public
docket
for
this
ICR
under
Docket
ID
No.
OAR­
2004­
0501,
which
is
available
for
public
viewing
at
the
Air
and
Radiation
Docket
and
Information
Center
in
the
EPA
Docket
Center
(
EPA/
DC),
EPA
West,
Room
B102,
1301
Constitution
Avenue,
NW,
Washington,
DC.
The
EPA
Docket
Center
Public
Reading
Room
is
open
from
8:
30
a.
m.
to
4:
30
p.
m.,
Monday
through
Friday,
excluding
legal
holidays.
The
telephone
number
for
the
Reading
Room
is
(
202)
566­
1744,
and
the
telephone
number
for
the
Air
and
Radiation
Docket
is
(
202)
566­
1742.
An
electronic
version
of
the
public
docket
is
available
through
EPA
Dockets
(
EDOCKET)
at
http://
www.
epa.
gov/
edocket.
Use
EDOCKET
to
submit
or
view
public
comments,
access
the
index
listing
of
the
contents
of
the
public
docket,
and
to
access
those
documents
in
the
public
docket
that
are
available
electronically.
Once
in
the
system,
select
"
search,"
then
key
in
the
docket
ID
number
identified
above.
Also,
you
can
send
comments
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,

NW,
Washington,
DC
20503,
Attention:
Desk
Officer
for
EPA.
Please
Include
the
EPA
Docket
ID
No.
(
OAR­
2004­
0501)
and
OMB
control
number
in
any
correspondence.
21
Attachment
1
Estimate
of
Green
Power
Partnership
Respondent
Burden
for
Years
1
though
3
22
Attachment
2
Green
Power
Partnership
Agency
(
EPA)
Burden
for
Years
1
through
3
23
Attachment
3
CHP
Partnership
Respondent
Burden
for
Years
1
through
3
Attachment
4
CHP
Parnership
Agency
(
EPA)
Burden
for
Years
1
through
3
