  SEQ CHAPTER \h \r 1 

INFORMATION COLLECTION REQUEST

for

GREEN POWER PARTNERSHIP AND COMBINED

HEAT AND POWER PARTNERSHIP

EPA ICR NUMBER 2173.02

OMB CONTROL NUMBER 2060-0578

SUPPORTING STATEMENT A

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

	1(a)	Title and Number of the Information Collection Request

	Reporting Requirements under EPA’s Green Power Partnership and CHP
Partnership (Renewal) EPA ICR No. 2173.02, OMB Control No. 2060-0578	

	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 launched two new partnership programs with
industry and other stakeholders: the Green Power Partnership and the
Combined Heat and Power (CHP) Partnership.  These voluntary 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 voluntary 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 Partnership
Agreement or Letter of Intent (LOI) respectively; (2) for the Green
Power Partnership, reporting to EPA, on a annual basis, their progress
toward their green power commitment via a 2-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 organizational 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

	EPA needs to collect the information in the Partnership Agreement or
LOI to formally establish participation in the Green Power Partnership
or CHP Partnership program and to obtain general information about 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 qualifying 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

	EPA uses the information submitted in the Partnership Agreement or LOI
to update its database of Green Power or CHP Partners.  The database
serves as a source of general information and a contact list.  EPA uses
the information submitted in additional forms to monitor the progress of
current participation and projects and identify new opportunities.  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 provide updates to existing information through a Partner
Yearly Report.  Existing CHP Partners with ongoing CHP project
development activities review and update a CHP Partners Project Data
Form every year.  Some CHP Partners, such as certain end-users and
city/state programs, 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 are pre-populated with
previously submitted information from the database.  Recipients of the
forms are 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 provides 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 October 31, 2008, in compliance with the Paperwork Reduction Act of
1995, EPA solicited public comments on the ICR through an announcement
in the Federal Register

(73FR 64941).   EPA received no comments.

 3(c)	Consultations

	In 2004, EPA consulted with three Green Power Partners and three CHP
Partners regarding the burden of information collection for the
programs. 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 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.

	In 2008, EPA consulted with three Green Power Partners and three CHP
Partners regarding the burden of this information collection. The
contacted Partners were provided copies of the information collection
forms, estimates of the labor burden derived from Partners responses in
2004, and labor wage rates from the Bureau of Labor Statistics (BLS). 
EPA requested comments on whether the labor burden estimates and labor
rates were appropriate. Generally, the estimates provided by the
Partners were similar and were consistent with the estimates provided by
EPA. EPA averaged Partner responses for the labor burden estimates and
labor rates for use in this ICR renewal.

	3(d)	Effects of Less Frequent Collection

	The Partnership Agreement or 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 asked to update an annual report. All CHP
Partners with ongoing project development activities, including all
project developers, energy service companies, consulting engineers,
equipment manufacturers, and approximately 33% of utility Partners will
review their project information and provide updates every year.  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 respective partnership Web sites.  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. 

	3(f)	Confidentiality

	Participation in the Green Power Partnership and CHP Partnership is
voluntary.  Participants are not asked to reveal Confidential Business
Information (CBI).  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.

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)	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 purchased electricity use from eligible renewable energy
resources 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 government agencies.  

NAICS	SIC	Description

Full-scale Partners a

611310	8221	Colleges, Universities, and Professional Schools

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

aGiven the breadth of industries who are currently Green Power Partners,
only a subset of their NAICS/SIC codes is listed to provide examples.

	

	(ii)	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	9631	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

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  (Except Newsprint Mills)

336111		3711	Automobile Manufacturing

813110	8661	Religious Organizations

331111	3317	 Steel Mills

721110	7011	Hotels (Except Casino Hotels) and Motels

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.

	4(b)	Information Requested

(i)	Data Items, Including Recordkeeping Requirements

	Green Power Partnership.  Information will be collected through the
Partnership Agreement and Partner Yearly Report, as well as through
clarification follow-ups and calls or e-mails as needed.  Each activity
is described below. 

The Partnership Agreement requests the following information from all
Partners:

Organization name;

Scope of entity/entities joining Partnership;

Total purchased electricity use and green power purchase commitment;

Signature and printed name and title of authorized organization
representative;

Contact information about the organizational liaison to the Green Power
Partnership, including name, title address, phone number, fax number and
e-mail address; 

Purchase details such as retailer name, the type of green power product
delivered (utility product, renewable energy certificates, or on-site
generation), type of renewable resource; and

Questions about product certification status and contract dates.



The Green Power Partnership Partner Yearly Reports collect or update the
following information:

Updates to liaison information listed above;

Updates to commitment details, including total annual energy
consumption, annual green power commitment;

Updates purchase details such as retailer name, the type of green power
product delivered (utility product, renewable energy certificates, or
on-site generation), type of renewable resource; 

Updates to product certification status and contract dates; and

Short paragraph description of Partner’s Green Power Commitment.     

	A company profile will be available on the Green Power Partnership Web
site.  Partners may submit corrections or updates to their profile via
the Web site or electronically 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 communications and outreach
efforts more effectively.



	

CHP Partnership.  Information will be collected through the LOI and the
CHP Partners Project Data Form, as well as through clarification
follow-up calls or e-mails as needed.  The LOI requests the following
information from all new Partners:

Organization name;

Designated CHP Partner Liaison’s contact information;

Organization CHP-related service or activity; and

Organization web site address and/or CHP-related Web page.

CHP Partners Project Data Forms are used to collect information on
completed or planned CHP projects on a yearly basis, and will be
completed by company or institutional Partners involved in planned or
operational CHP projects.  The requested information includes:

Project Owner;

Project Name and address;

Project information including start-up date, fuel type, annual operating
hours, average net power output, percentage of electricity sold offsite
or to grid and percentage of thermal output sold offsite;

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.

	After the first submittal, EPA will send the Partner spreadsheets
containing all previously-submitted information on planned projects for
the Partner to review annually.

	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
the LOI and CHP Partner Projects Data information forms submitted to
EPA.

The Partnership Agreement form will be updated by removing the approval
expiration date, which is currently located in the top right corner of
the form.

The Partnership Agreement form statement regarding the one year length
of time the green power purchase must be completed by will be updated to
read as follows: "Buy green power that meets or exceeds Partnership
requirements within six months of signing this Partnership Agreement."  

	(ii)	Respondent Activities

	The respondent activities depend on the aspect of the information
collection to which they are responding.  In completing the Partnership
Agreement or 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 pre-populated Green Power Partner Yearly Report or the
pre-populated CHP Partner Projects Data Form, respondents will:

Read the forms and instructions;

Update the pre-populated report or form with new information where
necessary;

Submit the yearly report (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 to the Green Power
Partnership or CHP Partnership via the Web site, an e-mail, or a
telephone interview.





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

	5(a)	Agency Activities

	(i)	Agency Activities for the Green Power Partnership’s Partnership
Agreements 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 Partnership Agreement or LOI for either the Green Power
Partnership or CHP Partnership, the Agency will:

Review the information provided;

Enter the information into a database; and

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 Partner Yearly Report
Form sent to Partners one year after they join the Partnership and
annually thereafter, the Agency will:

Prepare pre-populated partner data and mail the Partner Yearly Report
annually;

Receive and review the information provided on completed forms;

Enter the information into a database; and

File the form.

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

Call or email Partners;

Request updated information or clarification on Partnership Agreements
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 through the Green Power Partnership Web site;
and

Revise data in the database based on the updates.

	(iii)	Agency Activities for CHP Partnership

	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 e-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, once 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; and

File the spreadsheet.	

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

Call or email Partners;

Request updated information or clarification on 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:



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
respective Partnership Agreement and LOI 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 Yearly Reports 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

	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. As discussed
above, for both Partnership programs EPA pre-populates Yearly Report
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 CHP
Partnership is voluntary.  Any small entity that finds the information
collection overly burdensome is not required to participate. 

EPA expects that some Green Power Partners are small entities. GPP
determined whether Local Government Partners are small entities based on
the population served by these government agencies. Approximately 30
percent of existing Local Government Partners are in cities or counties
with populations less than 50,000, which is the threshold for small
entities within the public administration sector. GPP assumed that all
State Government Partners are not classified as small entities, since
each State population is greater than 50,000.  Likewise, GPP assumed
that all Federal Government Partners are not small entities.

Given the large number of private sector Green Power Partners, EPA was
not able to review the small entity status of each Partner individually.
 GPP assumed that all companies on Fortune magazine’s list of the top
1,000 U.S. companies by revenue are not small entities.  GPP also
assumed that all non-profit organizations are classified as small
entities.  For the remaining private sector Partners, GPP determined the
small entity status of a portion of Partners, following the U.S. Small
Business Administration’s 2007 Table of Small Business Size Standards
Matched to North American Industry Classification System Codes.  GPP
reviewed company profiles and Web sites when available to help determine
the selected company’s small entity status.  GPP then compared the
company’s small entity status to their total electricity use, a figure
which EPA collects for all Partners.

Using this information, EPA determined an approximate electricity
baseload under which a company could reasonably be considered a small
entity.  This baseload was different for companies in manufacturing
industries than for companies in non-manufacturing industries. The
companies whose small entity status was not determined were assumed to
follow a similar correlation to those reviewed. Following this
assumption, EPA estimates that 65 percent of its private sector Partners
are small entities.  Overall, 60 percent of all Green Power Partners are
estimated to be small entities.

EPA has designed its approach for this information collection to
minimize the burden for all respondents while obtaining sufficient and
accurate information. Since the previous ICR, GPP has strived to lessen
the reporting burden on Partners by introducing reporting efficiencies,
such as a writeable Portable Document Format (PDF) version of the
Partnership Agreement that improves readability, and thereby reduces the
frequency of Agency follow up with Partners. 

EPA expects that some CHPP Partners are small entities. The CHPP
consists of the following partner categories: project developer;
consultant/engineering; energy service company (ESCO); financier;
utility; non-governmental organization (NGO); government; equipment
manufacturer; and end-user. The CHPP assumed that all utilities,
government partners, equipment manufacturers, and end-users are not
small businesses. Companies of these partner types are large in scale
and scope and are most likely not small businesses.

The CHPP assumed that all NGO partners are small businesses given they
typically have a small number of employees and typically do not work for
profit. In all, the CHPP has 19 NGO partners.

For project developer partners, the CHPP reviewed Web sites and
organization descriptions for 25 percent of the partners. The companies
whose Web sites were not reviewed were assumed to contain a similar
percentage of small businesses to those reviewed. For the 25 percent of
partners reviewed, the CHPP also evaluated the number of projects
developed by these partners as an additional gauge of whether the
project developer is a small business or not. In most cases, if the
project developer reviewed by the CHPP had zero projects, it was assumed
to be a small business. At the end of 2008, the CHPP expects to have 62
project developer partners, so 16 were evaluated for small business
applicability. Of the 16 project developers evaluated, three were
categorized as small businesses, representing 18.75 percent. Applying
this percentage to those companies not reviewed, the CHPP estimates that
12 project developer partners are small businesses.

For consultant/engineer partners, the CHPP reviewed Web sites and
organization descriptions for 25 percent of the partners. The companies
whose Web sites were not reviewed were assumed to contain a similar
percentage of small businesses to those reviewed. For the 25 percent of
partners reviewed, the CHPP also evaluated the number of projects
developed by these partners as an additional gauge of whether the
consultant/engineer is a small business or not. In most cases, if the
consultant/engineer reviewed by the CHPP had zero projects, it was
assumed to be a small business. At the end of 2008, the CHPP expects to
have 51 project developer partners, so 13 were evaluated for small
business applicability. Of the 13 consultants/engineers evaluated, three
were categorized as small businesses, representing 23 percent. Applying
this percentage to those companies not reviewed, the CHPP estimates that
12 consultant/engineer partners are small businesses.

For ESCO partners, the CHPP reviewed Web sites and organization
descriptions for all of the partners. At the end of 2008, the CHPP
expects to have six ESCO partners. Of the six ESCOs evaluated, one was
categorized as a small business due to it employing only 60 employees.

For financier partners, the CHPP reviewed Web sites and organization
descriptions for all of the partners. In most cases, if the financier
had zero projects, it was assumed to be a small business.  At the end of
2008, the CHPP expects to have 11 financier partners. Of the 11
financiers evaluated, two were categorized as a small business because
they employ less than 50 employees.

Table 1 summarizes the small entities affected per year according to
partner category. The numbers in Table 1 reflect the CHPP’s assumption
that the distribution of small entities within each new partner category
over the years 2009-2011 will be similar to the distribution analyzed
for each existing partner category.

Table 1: CHPP Estimate of Small Entities for Each Respondent Category

Respondent Category	New	Existing

Project Developer*	4	12

Consultant/Engineer*	5	12

ESCO**	0	1

Financier**	0	2

NGO**	0	19

Utility*	0	0

Government*	0	0

Equipment Manufacturer*	0	0

End-User*	0	0

Total	9	46

* The CHPP ICR burden estimate assumes the following number of new
partners for each of the years 2009-2011: project developer – 7;
consultant/engineer –7; utility – 6; government – 2; equipment
manufacturer – 6; end-user – 6 (Note: the CHPP assumed that none of
the existing or new utility, government, equipment manufacturer, or
end-user partners are small businesses).

** The CHPP ICR burden estimate assumes that there will be no new ESCO,
financier, or NGO partners in years 2009-2011.

5(d)	Collection Schedule

	EPA will collect general information from all new Partners through
either the Green Power Partnership’s Partnership Agreement or CHP
Partnership’s 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 on an
annual basis on the anniversary of EPA’s receipt of the Partner’s
last information update.  In addition, a subset of Green Power Partners
may occasionally be asked to provide additional information specific to
their industry 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 year. 

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.  In
consulting with Partners, EPA provided them with hourly burden estimates
from the last submitted ICR, as well as current labor rates from the
Bureau of Labor Statistics. Respondents were asked if the hourly burden
estimates and labor rates were appropriate and, if not, to provide
estimates based on their experience.

 The hourly burden for each activity was multiplied by the number of
Partners (respondents) performing the activity each year to estimate the
total respondent burden.  In accordance with the Paper Reduction Act,
Federal Partners were excluded from the burden estimate although we
summarize their burden in Table 5. Capital, operation and maintenance
costs were also considered. Attachment A 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 A and Table 5 include burden estimates for
Federal entities in the Green Power Partnership, but these are not
included as part of this Information Collection Request. Attachment B
presents the estimated annual respondent burden and costs for
information collection activities associated with the CHP Partnership
for each year of the collection.  Table 3 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

(i)	Estimating Labor Costs

Respondent labor rates came from direct consultations with three current
Green Power Partners and three current CHP Partners, as discussed in
section 6(a).  These consultations did not include benefits.  For
private-sector respondents, 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.  For Green Power Partners, loaded rates are $123.47 for
legal staff, $109.47 for managerial staff, $89.29 for technical staff,
and $39.05 for clerical staff. For CHP Partners, loaded rates are
$114.85 for legal staff, $91.90 for managerial staff, $81.44 for
technical staff, and $38.62 for clerical staff.

	For public sector respondents (Local and  State Partners), EPA used the
same labor rates used for EPA personnel (see Section 6(c)).  The 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.  EPA does not expect that the operations and maintenance (O&M)
costs of these programs 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 $5,466.  

	6(c)	Estimating Agency Burden and Costs

	Attachments C and D 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 $82.88 for managerial staff, $52.60 for technical staff, and $20.13
for clerical staff.  To derive these estimates, EPA used the “Salary
Table 2008 - GS Salary Table of Annual Rates by Grade and Step” dated
January 2008, from the Department of Personnel Management.  For purposes
of this ICR, EPA assigned staff the following government service levels:

Managerial Staff  -  GS-15, Step 5  	$82.88 ($51.80 +60% OH)

Technical Staff  -  GS-13, Step 1     	$52.60 ($32.88+60% OH)

Clerical Staff	-  GS-5, Step 1         	$20.13  ($12.58+60% OH)

Table 2: Summary of Agency Burden

	2009	2010	2011	Total	Annual Average 

Hours	2,470 	2,889 	3,307 	8,666 	2,889

Cost	$122,079 	$142,056	$162,033	$426,168	$142,056



	6(d)       Estimating the Respondent Universe

	Green Power Partnership.  A total of 1,040 Green Power Partners is
expected by the end of 2008.  EPA expects future growth to be constant
since the number of Partners that have joined in the past few years has
been steady. EPA anticipates that 246 new Partners will join the program
each year in 2009, 2010, and 2011.  Of these new 246 Partners joining
each year, EPA expects that 219 will be from the private sector and 27
from local and state governments, as is consistent with the
Partnership’s current makeup. Each new Partner is required to complete
and submit a Partnership Agreement form, and all participating Partners
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 1,532. 
The number of respondents in each of the three years of this information
collection and the average over the 3-year period is shown in Table 3
in Section 6(e) of this supporting statement.

	CHP Partnership.  A total of 206 Partners is expected by the end of
2008.  EPA anticipates 30-40 new Partners will join the program each
year in 2009, 2010, and 2011.  Of these new respondents, it is assumed
that there are 6 to 7 new Partners per year in each of the following
categories:  end-users, project developers, consulting engineers,
equipment manufacturers, and utilities, with up to an additional two
Partners belonging to State/Local/Tribal governments per year.  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 33% 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 33% of the
existing utilities will continue to review their project information and
provide updates every year in a project spreadsheet starting in the year
they join the Partnership.

	The average annual number of respondents over three years is 262.  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 3.


6(e)	Bottom Line Burden Hours and Costs

	Green Power Partnership.  Attachments A and C show the detailed annual
burden and cost to respondents and the Agency, respectively, for the
information collection activities associated with Green Power
Partnership.  The results are summarized in Tables 3 and 4.  The total
annual burden, averaged over the three-year period, is 4,862 hours and
$433,302 per year for respondents and 1,921 hours and $90,884 per year
for the Agency.  (See Tables 3 and 4 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 a Partnership Agreement.  In years 1, 2, and 3, existing
Partners will 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 3 and 4 for respondent
and Agency burdens in each of the three years. 

Table 5 summarizes the total annual respondent burden for Federal
Partners, although these are not included in Table 3 since, in
accordance with the Paperwork Reduction Act, Federal respondents are
excluded from Information Collection Requests. The total annual burden
for Federal Partners, averaged over the three-year period, is 82 hours
and $4,818 per year.

	CHP Partnership.  Attachments B and D show the detailed annual burden
and cost to respondents and the Agency, respectively, for the
information collection activities associated with CHP.  The results are
summarized in Tables 3 and 4.  The total annual burden, averaged over
the three-year period is 961 hours and $83,816 for Partners, and 968
hours and $51,172 for the Agency.  (See Tables 3 and 4 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 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 3 and 4 for the respondent and Agency
burdens in each of the three years.

Table 5 summarizes the total annual respondent burden for Federal
Partners, although these are not included in Table 3 since, in
accordance with the Paperwork Reduction Act, Federal respondents are
excluded from Information Collection Requests. The CHP Partnership has
no Federal Partners.

	Total.  Considering both the Green Power Partnership and the CHP
Partnership, the combined total annual burden (averaged over a 3-year
period) is 5,823 hours and $517,119 per year for respondents and 2,889
hours and $142,056 per year for the Agency.  Tables 3 and 4 show the
breakout between labor costs and O&M costs.  The burden estimates
reflect an average of 1,794 respondents per year.  The average annual
burden per respondent is 3.25 hours and $288 per year.

TABLE 3.

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*	1,286	1,532	1,778	4,596	1,532

	Number of Company/Institutional Respondents	1,138	1,357	1,576	4,071
1,357

	Number of Local/State Respondents	148	175	202	525	175

Hours	4,160	4,862	5,564	14,586	4,862

Labor Costs	$366,648	$428,706	$490,765	$1,286,119	$428,706

O&M Costs	$3,858	$4,596	$5,334	$13,788	$4,596

TOTAL Costs	$370,506	$433,302	$496,099	$1,299,907	$433,302

CHP Partnership Program	

Number of Respondents	234	262	290	786	262

	Number of Company/Institutional Respondents	232	260	288	780	260

	Number of State Respondents	2	2	2	6	2

Hours	861	960	1,061	2,882	961

Labor Costs	$74,382	$82,942	$91,515	$248,839	$82,946

O&M Costs	$786	$870	$954	$2,610	$870

TOTAL Costs	$75,168	$83,812	$92,469	$251,449	$83,816

Combined Totals for Both Programs	

Number of Respondents	1,520	1,794	2,068	5,382	1,794

Hours	5,021	5,822	6,625	17,468	5,823

Labor Costs	$441,030	$511,648	$582,280	$1,534,958	$511,653

O&M Costs	$4,644	$5,466	$6,288	$16,398	$5,466

TOTAL Costs	$445,674	$517,114	$588,568	$1,551,356	$517,119

Average annual hours per respondent	-	-	-	-	3.25

Average annual costs per respondent	-	-	-	-	$288

*In accordance with the Paperwork Reduction Act, Federal government
respondents are not included in the burden estimate in Table 3 because,
based on its experience, GPP assumes that participating Federal
facilities are not run by contractors. The burden on Federal government
respondents is shown separately in Table 5.

TABLE 4.

ESTIMATED TOTAL AGENCY BURDEN AND COST FOR GPP, CHP and COMBINED

	Year 1	Year 2	Year 3	Total	Annual Average

Green Power Partnership Program	

Number of Respondents	1,308	1,558	1,808	4,674	1,558

Hours	1,605	1,921	2,236	5,762	1,921

Labor Costs	$76,311	$90,884	$105,456	$272,651	$90,884

O&M Costs	$0	$0	$0	$0	$0

TOTAL Costs	$76,311	$90,884	$105,456	$272,651	$90,884

CHP Partnership Program	

Number of Respondents	234	262	290	786	262

Hours	866	968	1,071	2,905	968

Labor Costs	$45,768	$51,172	$56,577	$153,517	$51,172

O&M Costs	$0	$0	$0	$0	$0

TOTAL Costs	$45,768	$51,172	$56,577	$153,517	$51,172

Combined Totals for Both Programs

Number of Respondents	1,542	1,820	2,098	5,460	1,820

Hours	2,470	2,889	3,307	8,666	2,889

Labor Costs	$122,079	$142,056	$162,033	$426,168	$142,056

O&M Costs	$0	$0	$0	$0	$0

TOTAL Costs	$122,079	$142,056	$162,033	$426,168	$142,056



TABLE 5.

ESTIMATED RESPONDENT BURDEN FOR FEDERAL GOVERNMENT PARTNERS

	Year 1	Year 2	Year 3	Total	Annual Average

Green Power Partnership Program	

Number of Respondents	22	26	30	78	26

Hours	71	82	94	247	82

Labor Costs	$4,083	$4,740	$5,397	$14,220	$4,740

O&M Costs	$66	$78	$90	$234	$78

TOTAL Costs	$4,149	$4,818	$5,487	$14,454	$4,818

CHP Partnership Program	

Number of Respondents	0	0	0	0	0

Hours	0	0	0	0	0

Labor Costs	0	0	0	0	0

O&M Costs	0	0	0	0	0

TOTAL Costs	0	0	0	0	0

Combined Totals for Both Programs	

Number of Respondents	22	26	30	78	26

Hours	71	82	94	247	82

Labor Costs	$4,083	$4,740	$5,397	$14,220	$4,740

O&M Costs	$66	$78	$90	$234	$78

TOTAL Costs	$4,149	$4,818	$5,487	$14,454	$4,818

Average annual hours per respondent



	3.15

Average annual costs per respondent



	$185



	6(f)	Reasons for Change in Burden

	Under this renewal ICR, the average annual total respondent burden is
5,823 hours.  The 2004 ICR average annual respondent burden was 3,980
hours per year. 

	Since the last ICR renewal, both the Green Power Partnership and CHP
Partnership have introduced program efficiencies to reduce program
burden and simplified collection forms into pre-populated spreadsheets
or documents. As a result of these changes, the average number of hours
per Partner has decreased from 3.4 hours to 3.25 hours, but the total
hourly burden for Partners still increased because of an increase in the
number of Partners. For perspective on the magnitude of Partner growth,
the number of Partners at the end of 2004 was 865, whereas by year-end
2008 their will be an estimated 1,308.  

	6(g)	Burden Statement

	The annual public reporting and recordkeeping burden for this
collection of information is estimated to average 3.25 hours per
respondent.  The average number of annual burden hours per type of
response is: 8.8 hours for a Partnership Agreement (a one-time burden
for Green Power); 3.5 hours for a Letter of Intent (a one-time burden
for CHP Partners), 2.6 hours for the Partner Yearly Report for the GPP,
3.94 hours for the Partner Yearly Report for the CHP Partnership. 

	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
Partnership Agreement or LOI, Green Power Partner Yearly Report, or CHP
Partner project reporting.  All of these activities are included in the
annual burden estimate.

	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.  EPA-HQ-OAR-2004-0501, which is available for public
viewing at the Air and Radiation Docket and Information Center in
EPA’s Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution
Avenue, NW, Washington, DC.  EPA’s 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.  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 EPA’s Docket ID No.
EPA-HQ-OAR-2004-0501 and OMB Control Number 2060-0578 in any
correspondence.

ATTACHMENT A: Green Power Partnership Respondent Burden for Years 1
though 3

A-1 Green Power Partnership Private Sector Respondent Burden for Year 1

A-2 Green Power Partnership Private Sector Respondent Burden for Year 2

A-3 Green Power Partnership Private Sector Respondent Burden for Year 3

A-4 Green Power Partnership Local & State Government Respondent Burden
for Year 1

A-5 Green Power Partnership Local & State Government Respondent Burden
for Year 2

A-6 Green Power Partnership Local & State Government Respondent Burden
for Year 3

A-7 Green Power Partnership Federal Government Respondent Burden for
Year 1

A-8 Green Power Partnership Federal Government Respondent Burden for
Year 2

A-9 Green Power Partnership Federal Government Respondent Burden for
Year 3

ATTACHMENT B: CHP Partnership Respondent Burden for Years 1 through 3

B-1 CHP Partnership Private Sector Respondent Burden for Year 1

B-2 CHP Partnership Private Sector Respondent Burden for Year 2

B-3 CHP Partnership Private Sector Respondent Burden for Year 3

B-4 CHP Partnership State & Local Government Respondent Burden for Year
1

B-5 CHP Partnership State & Local Government Respondent Burden for Year
2

B-6 CHP Partnership State & Local Government Respondent Burden for Year
3

ATTACHMENT C:  Green Power Partnership Agency (EPA) Burden for Years 1
through 3

C-1 Green Power Partnership Agency (EPA) Burden for Year 1

C-2 Green Power Partnership Agency (EPA) Burden for Year 2

C-3 Green Power Partnership Agency (EPA) Burden for Year 3

ATTACHMENT D: CHP Partnership Agency (EPA) Burden for Years 1 through 3

D-1 CHP Partnership Agency (EPA) Burden for Year 1

D-2 CHP Partnership Agency (EPA) Burden for Year 2

D-3 CHP Partnership Agency (EPA) Burden for Year 3

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