	

SUPPORTING STATEMENT FOR

INFORMATION COLLECTION REQUEST NUMBER 1772.07

“INFORMATION COLLECTION ACTIVITIES ASSOCIATED WITH EPA’S ENERGY
STAR® PROGRAM IN THE COMMERCIAL AND INDUSTRIAL SECTORS”

January 20, 2016

Office of Air and Radiation

U.S. Environmental Protection Agency

	

TABLE OF CONTENTS

  TOC \o "1-3" \h \z    HYPERLINK \l "_Toc246597284"  1.	IDENTIFICATION
OF THE INFORMATION COLLECTION	  PAGEREF _Toc246597284 \h  1  

  HYPERLINK \l "_Toc246597285"  1(a)	Title and Number of the Information
Collection	  PAGEREF _Toc246597285 \h  1  

  HYPERLINK \l "_Toc246597286"  1(b)	Short Characterization or Abstract	
 PAGEREF _Toc246597286 \h  1  

  HYPERLINK \l "_Toc246597287"  2.	NEED FOR AND USE OF THE COLLECTION	 
PAGEREF _Toc246597287 \h  4  

  HYPERLINK \l "_Toc246597288"  2(a)	Need and Authority for the
Collection	  PAGEREF _Toc246597288 \h  4  

  HYPERLINK \l "_Toc246597289"  2(b)	Practical Utility and Users of the
Data	  PAGEREF _Toc246597289 \h  4  

  HYPERLINK \l "_Toc246597290"  3.	NONDUPLICATION, CONSULTATIONS, AND
OTHER COLLECTION     CRITERIA	  PAGEREF _Toc246597290 \h  5  

  HYPERLINK \l "_Toc246597291"  3(a)	Nonduplication	  PAGEREF
_Toc246597291 \h  5  

  HYPERLINK \l "_Toc246597292"  3(b)	Public Notice Required Prior to ICR
Submission to OMB	  PAGEREF _Toc246597292 \h  5  

  HYPERLINK \l "_Toc246597293"  3(c)	Consultations	  PAGEREF
_Toc246597293 \h  5  

  HYPERLINK \l "_Toc246597294"  3(d)	Effects of Less Frequent Collection
  PAGEREF _Toc246597294 \h  7  

  HYPERLINK \l "_Toc246597295"  3(e)	General Guidelines	  PAGEREF
_Toc246597295 \h  7  

  HYPERLINK \l "_Toc246597296"  3(f)	Confidentiality	  PAGEREF
_Toc246597296 \h  7  

  HYPERLINK \l "_Toc246597297"  3(g)	Sensitive Questions	  PAGEREF
_Toc246597297 \h  7  

  HYPERLINK \l "_Toc246597298"  4.	THE RESPONDENTS AND THE INFORMATION
REQUESTED	  PAGEREF _Toc246597298 \h  8  

  HYPERLINK \l "_Toc246597299"  4(a)	Respondents and SIC/NAICS Codes	 
PAGEREF _Toc246597299 \h  8  

  HYPERLINK \l "_Toc246597300"  4(b)	Information Requested	  PAGEREF
_Toc246597300 \h  8  

  HYPERLINK \l "_Toc246597301"  5.	THE INFORMATION COLLECTED, AGENCY
ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	  PAGEREF
_Toc246597301 \h  26  

  HYPERLINK \l "_Toc246597302"  5(a)	Agency Activities	  PAGEREF
_Toc246597302 \h  26  

  HYPERLINK \l "_Toc246597303"  5(b)	Collection Methodology and
Management	  PAGEREF _Toc246597303 \h  29  

  HYPERLINK \l "_Toc246597304"  5(c)	Small Entity Flexibility	  PAGEREF
_Toc246597304 \h  29  

  HYPERLINK \l "_Toc246597305"  5(d)	Collection Schedule	  PAGEREF
_Toc246597305 \h  30  

  HYPERLINK \l "_Toc246597306"  6.	ESTIMATING THE BURDEN AND COST OF THE
COLLECTION	  PAGEREF _Toc246597306 \h  31  

  HYPERLINK \l "_Toc246597307"  6(a)	Estimating Respondent Burden	 
PAGEREF _Toc246597307 \h  31  

  HYPERLINK \l "_Toc246597308"  6(b)	Estimating Respondent Costs	 
PAGEREF _Toc246597308 \h  31  

  HYPERLINK \l "_Toc246597309"  6(c)	Estimating Agency Burden and Costs	
 PAGEREF _Toc246597309 \h  31  

  HYPERLINK \l "_Toc246597310"  6(d)	Estimating the Respondent Universe	
 PAGEREF _Toc246597310 \h  33  

  HYPERLINK \l "_Toc246597311"  6(e)	Bottom Line Burden Hours and Cost
Tables	  PAGEREF _Toc246597311 \h  57  

  HYPERLINK \l "_Toc246597312"  6(f)	Reasons for Change in Burden	 
PAGEREF _Toc246597312 \h  58  

  HYPERLINK \l "_Toc246597313"  6(g)	Burden Statement	  PAGEREF
_Toc246597313 \h  62  

 

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

1(a)	Title and Number of the Information Collection

This ICR is entitled “Information Collection Activities Associated
with EPA’s ENERGY STAR® Program in the Commercial and Industrial
Sectors,” ICR Number 1772.07, OMB Control No. 2060-0347. 

1(b)	Short Characterization or Abstract

The U.S. Environmental Protection Agency (EPA) created ENERGY STAR as a
voluntary program to help businesses and individuals protect the
environment through superior energy efficiency.  The program focuses on
reducing utility-generated emissions by reducing the demand for energy. 
In 1991, EPA launched the Green Lights Program to encourage
corporations, state and local governments, colleges and universities,
and other organizations to adopt energy-efficient lighting as a
profitable means of preventing pollution and improving lighting quality.
 Since then, EPA has rolled Green Lights into ENERGY STAR for the
commercial and industrial sectors and expanded ENERGY STAR to encompass
organization-wide energy performance improvement, such as building
technology upgrades, product purchasing initiatives, and employee
training.  At the same time, EPA has streamlined the reporting
requirements of ENERGY STAR and focused on providing recognition
incentives for improvements (e.g., ENERGY STAR Awards Program).  EPA
also makes tools and resources available over the Web to help the public
overcome the barriers to evaluating their energy performance and
investing in profitable improvements.  

For several reasons, the public’s participation in the ENERGY STAR
program for commercial and industrial sectors has continued to increase
over the past several years, and EPA expects their participation to rise
even more in the coming years.  For example, President Obama and the
U.S. Congress have made energy efficiency an important component of the
federal government’s approach to energy management.  In addition, the
Energy Efficiency Improvement Act of 2015 congressionally mandates
“Tenant Star,” a new recognition program within ENERGY STAR to
improve energy efficiency in tenant-occupied spaces in commercial
buildings.  

In addition, a growing number of state and local governments are
leveraging ENERGY STAR as a way for the public to respond to rising
energy costs and global warming, including mandatory energy benchmarking
and disclosure laws that require buildings within their jurisdiction to
use EPA’s ENERGY STAR Portfolio Manager.  Participation in ENERGY STAR
has also risen dramatically because of the efforts of trade
associations, utilities, and third-party providers in promoting the
program to the public.  These organizations voluntarily communicate
ENERGY STAR messages and promote the use of ENERGY STAR tools and
strategies in an effort to help companies reduce their energy
consumption and find more environmentally friendly ways to conduct
business.

As participation has increased, EPA has taken measures to reduce the
burden on participants to take advantage of the benefits of ENERGY STAR.
For example, EPA has expanded Portfolio Manager Web Services, which is
one of several benchmarking methods available to users.  Because Web
Services integrates automated data collection and entry, it offers
significant time savings advantages over the other methods; a benchmark
using Web Services takes only about one-fifth the time of one conducted
via manual entry. Over the past several years, EPA has seen a growing
trend for users to opt for Web Services and thereby realize these
savings. This is illustrated by the bar graph below, which shows the
total number of benchmarks performed annually using Web Services and the
other methods.  In 2009, 41% of all benchmarks were performed using Web
Services.  By 2014, this had grown to 59%.

In addition to expanding Web Services, the Agency completed a
comprehensive upgrade of Portfolio Manager, allowing participants to
enter and retrieve information more quickly, and vastly simplified the
process of entering building data in the National Building Competition
so participants can register portfolios of buildings with just a few
clicks.

As a result of the efforts of Partners and others under the ENERGY STAR
Program, there have been significant benefits to the public and
environment.  For example, EPA estimates that, in 2013, the energy
efficiency efforts of commercial buildings helped to avoid 96.0 million
metric tons of carbon dioxide equivalent (MMTCO2e) of greenhouse gases
and a net $7.7 billion (2013$). The efforts of industry helped to
prevent another 39.7 MMTCO2 e of greenhouse gases and achieve a net
savings of $2.2 billion (2013$).  Typically, ENERGY STAR buildings use
35% less energy and emit 35% less greenhouse gases than average
buildings.  By the end of 2013, more than 22,000 buildings and plants
representing more than three billion square feet of space had earned
ENERGY STAR certification.

This ICR examines the information collections under the ENERGY STAR
Program in the commercial and industrial sectors.  Sections 1 through 5
of this document describe the collections (e.g., from the standpoint of
need and use/utility of the information collected).  The sections also
describe respondent and Agency activities.  In Section 6, EPA estimates
the total annual hour and cost burden to respondents and the Agency
under the collections.

2.	NEED FOR AND USE OF THE COLLECTION

2(a)	Need and Authority for the Collection

ENERGY STAR is authorized under section 103(g) of the Clean Air Act. 
The Energy Policy Act of 2005 further provides authorization to EPA and
the U.S. Department of Energy (DOE) to establish a voluntary program to
identify and promote energy-efficient products and buildings in order to
reduce energy consumption, improve energy security, and reduce pollution
through voluntary certification of, or other forms of communication
about, products and buildings that meet the highest energy conservation
standards.  ENERGY STAR is a voluntary program aimed at preventing
pollution rather than controlling it after its creation.  Information is
needed from organizations joining the program for identification
purposes (e.g., contact information) and for establishing their
partnership.  Further, ENERGY STAR’s online tools (e.g., Portfolio
Manger) are needed for users to benchmark facility energy performance,
assess energy management goals over time, and identify strategic
opportunities for savings and recognition opportunities.  Finally,
information is needed from organizations seeking ENERGY STAR recognition
so that EPA can evaluate and verify their accomplishments and share
their lessons learned with the public.

2(b)	Practical Utility and Users of the Data

EPA uses information from organizations joining the program to ascertain
basic identification information about them and verify their commitment
to the program.  EPA may also use partnership information for program
implementation purposes, such as maintaining up-to-date listings of
products and services available to the public.  Further, ENERGY STAR’s
online tools (e.g., Portfolio Manager, Energy Performance Indicator) are
used by the public to benchmark facility energy performance and identify
opportunities for improvements.  Finally, EPA uses information from
organizations seeking recognition to evaluate and verify their energy
performance and accomplishments.  For example, EPA offers the public an
opportunity to display the ENERGY STAR on their buildings if they meet
certain energy performance criteria defined by EPA.  To be approved to
receive the ENERGY STAR, buildings must demonstrate that they meet
specific eligibility requirements as well as industry standards for
comfort and indoor air quality.  EPA recognition enhances the image of
organizations as national leaders in energy performance.

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a)	Nonduplication

The information collected under this ICR is not collected by any other
EPA office or by any other federal agency.  Therefore, there is not a
potential for duplication with other federal collections.

3(b)	Public Notice Required Prior to ICR Submission to OMB

In compliance with the Paperwork Reduction Act of 1995, EPA solicited
public comments on this ICR through an announcement in the Federal
Register on July 23, 2015 (80 FR 43770).  No comments were received.

3(c)	Consultations

In December 2015, EPA contacted three Partners to request their comments
on key burden estimates and statements in this ICR.  The purpose of the
consultations was to determine if the burden estimates (e.g., for use of
Portfolio Manager) should be updated or revised in preparing ICR
1772.07.  EPA selected one commercial real estate, one retail and one
K-12 schools Partner, as they represent the three most active sectors in
the program. The table identifies the points of contact (POCs) and their
organizations.

POC Name	Organization Name	Phone Number	Email

Katie Ross	Cushman & Wakefield	--	katie.ross@cushwake.com

Thomas Schneider	North Penn School District	215-853-1140  
schneit@npenn.org

Andrew Thorsen	Kohl's Department Stores	262-703-1077
andrew.thorsen@kohls.com



3(d)	Effects of Less Frequent Collection

	EPA has carefully considered the information collection burden under
the ENERGY STAR Program.  EPA is confident that those activities
requested of respondents are necessary, and to the extent possible, the
Agency has minimized the burden. A number of the requested activities,
for example, will be performed once (e.g., one-time submittal of a
Partnership Agreement).  In addition, respondents can satisfy many of
the collections in this ICR by submitting readily available information.
 For example, users of Portfolio Manager are asked to enter energy use
data (e.g., data from their energy bills).  EPA believes strongly that,
if the information collections in this ICR are not performed at the
requested frequency, EPA’s ability to implement the ENERGY STAR
Program and the public’s ability to benefit from the program’s tools
and resources could be hampered significantly.

3(e)	General Guidelines

Information collections performed under this clearance will follow all
of OMB’s General Guidelines regarding federal data collection.

EPA intends to omit the expiration date from all forms being submitted
for OMB review in this ICR.  The information collected on the forms is
modified infrequently.  Since inclusion of the expiration date on the
forms in these circumstances provides little to no value for the public,
EPA intends to omit it from the forms. 

3(f)	Confidentiality

Participation in the ENERGY STAR Program is voluntary and may be
terminated by participants or EPA at any time.  If a claim of
confidential business information (CBI) is asserted, EPA will manage
that information in accordance with EPA’s provisions on
confidentiality.  40 CFR Part 2, Subpart B establishes EPA’s general
policy on the public disclosure of information and procedures for
handling CBI claims.

3(g)	Sensitive Questions

No questions of a sensitive nature are asked of participants with ENERGY
STAR. 

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a)	Respondents and NAICS Codes

Following are the North American Industry Classification System (NAICS)
codes of respondents most likely carrying out the information
collections under this ICR.

Industry Sectors	NAICS Code(s)

Agriculture, Forestry, Fishing and Hunting	11

Mining, Quarrying, and Oil and Gas Extraction	21

Utilities	22

Construction	23

Manufacturing	31-33

Wholesale Trade	42

Retail Trade	44-45

Transportation and Warehousing	48-49

Information	51

Finance and Insurance	52

Real Estate and Rental and Leasing	53

Professional, Scientific, and Technical Services	54

Management of Companies and Enterprises	55

Administrative and Support and Waste Management and Remediation Services
56

Educational Services	61

Health Care and Social Assistance	62

Arts, Entertainment, and Recreation	71

Accommodation and Food Services	72

Other Services (except Public Administration)	81

Public Administration	92

4(b)	Information Requested

	This section describes the information collections under this ICR,
including data items and respondent activities.  The section also
identifies the sector (i.e., private and/or public sector) that is
expected to carry out each collection (see the heading introducing each
collection).

.

JOINING THE ENERGY STAR PROGRAM AND RELATED ACTIVITIES

Organizations interested in joining the ENERGY STAR Program may be asked
to submit a Partnership Letter or Agreement.  They also may be asked to
undertake related activities, as described below.

Commercial and Industrial Sector Partners (Private and Public Sector)

	In order to join ENERGY STAR, organizations in the commercial and
industrial sectors are asked to complete and submit a Partnership
Agreement to EPA.  These Partners agree to measure and track the energy
performance of their organization’s facilities where possible by using
tools such as those offered through ENERGY STAR; develop and implement a
plan consistent with the ENERGY STAR Energy Management Guidelines to
achieve energy savings; help spread the word about the importance of
energy efficiency to their staff and community; and highlight their
achievements with recognition offered through ENERGY STAR.

(i)	Data items

A Partnership Agreement that includes the following information:

-	Organization’s name;

-	Contact information on organization’s Chief Executive;

-	Contact information on organization’s Energy Manager;

-	Contact information on organization’s Communications Contact (if
applicable);

-	Description of organization’s primary business or function (i.e., a
checklist);

-	Total amount of building/facility square footage owned, leased, and/or
managed; and

-	Brief explanation of how organization learned about ENERGY STAR.

Energy Management Plan.

(ii)	Respondent activities

To join ENERGY STAR, organizations are asked to:

Complete and submit the Partnership Agreement online; and

Respond to EPA follow-up questions, if any.

Partners may prepare and follow an energy management plan.

Service and Product Providers (Private Sector)

	An organization must meet certain eligibility requirements before
applying to become a Service and Product Provider (SPP) Partner. 
Applicants must demonstrate that they have actively used the ENERGY STAR
approach to help clients achieve their energy management goals as
specified. 

SPPs serving the existing commercial buildings market must benchmark at
least 10 client commercial buildings in the last 12 months using
Portfolio Manager and/or earn the ENERGY STAR certification for at least
one client commercial building using Portfolio Manager and meet other
program requirements.  [Note that this ICR addresses benchmarking
activities in the section, “Benchmarking,” under the heading,
“Portfolio Manager.” This ICR addresses earning the ENERGY STAR in
the section, “Recognition,” under the heading, “ENERGY STAR
Certification.”]  

SPPs serving the commercial new construction market must submit
commercial building design projects that achieve Designed to Earn the
ENERGY STAR. Eligible design projects are determined by using Target
Finder and require approval from EPA.  [Note that this ICR addresses
applying for the Designed to Earn the ENERGY STAR in the section,
“Recognition,” under the heading, “Designed to Earn the ENERGY
STAR.”] 

SPPs serving the industrial market must work with an ENERGY STAR
industrial Partner on at least one energy efficiency project in the last
two years and submit a Teaming Profile to EPA outlining the project
scope and resulting savings for that project.  

	SPPs interested in joining ENERGY STAR complete and submit a
Partnership Agreement to EPA using an online system.  The Partnership
Agreement requests SPP company information, contact information, and
select pieces of information to enable automated verification that
Partnership requirements have been met. The Partnership Agreement also
lays out Partner commitments, disclaimers, procedures for dispute
resolution, and other issues.  

	On an annual basis, SPPs may be asked to update contact information
(i.e. contact name, phone, email) displayed on select Service and
Product Provider listings on the Web site and to maintain quality of
contact mailing lists.

	

	(i)	Data items

A Partnership Agreement to be completed and submitted online that
includes the following information:

-		Applicant company name; 

-		Information about the company, such as Web address and
markets/sectors that the organization serves; 

-		Name, title, and contact information of the primary contact,
communications contact, and signatory of the Partnership Agreement; and

-		For Existing Commercial Buildings SPPs only, information about SPP
activities over the past 12 months (i.e., Portfolio Manager building ID
numbers to complete automated verification of activity); or

-		For architecture firms only, information about Commercial New
Construction SPP activities (i.e., Designed to Earn the ENERGY STAR of
project achieving Designed to Earn the ENERGY STAR); or

-		For Industrial SPP only, information about SPP activities (i.e.,
Teaming Profile outlining the project scope and resulting savings for
that project).

Additional communications items that SPP Partner may elect to submit: 

-	One-page success story for Web site posting to demonstrate successful
projects or relationships with commercial and institutional clients, or
exemplary use of ENERGY STAR tools.

-	Communications about SPP efforts for feature in quarterly newsletters
or other medium, at EPA discretion.

	(ii)	 Respondent activities

To join ENERGY STAR, organizations are asked to:

Complete and submit the Partnership Agreement online; and

Complete and submit requested materials for the appropriate Partnership
category (e.g., Statement of Energy Design Intent, Teaming Profile),
online.

SPP Partners are asked to:

Update contact information as needed by notifying program account
manager of any changes and/or using the “My ENERGY STAR Account”
tool; and

Communicate efforts and successes to ENERGY STAR and the broader market
through success stories and other communications.

Energy Efficiency Program Sponsors (Private and Public Sector)

	Energy Efficiency Program Sponsors (EEPS) interested in joining ENERGY
STAR are asked to complete and submit a Partnership Agreement.,   They
commit to promote and use ENERGY STAR in a manner consistent with the
national ENERGY STAR efforts and specifically agree to follow all
applicable terms and conditions governing the use of the ENERGY STAR
logos, which are registered trade and service marks.  Some Partners will
be asked on an annual basis to update organization and contact
information displayed on the ENERGY STAR Web site and the Directory of
Energy Efficiency Programs (DEEP).  The Partners also agree to promote
energy efficiency as an easy and desirable option for organizations and
consumers to prevent pollution, protect the global environment, and save
on energy bills.  

(i)	Data items

A Partnership Agreement.

	

Updates to organization and contact information displayed on the ENERGY
STAR Web site and the Directory of Energy Efficiency Programs (DEEP).

Information to promote energy efficiency as an easy and desirable option
for organizations and consumers to prevent pollution, protect the global
environment, and save on energy bills.

(ii)	Respondent activities

To join ENERGY STAR, organizations are asked to complete and submit a
Partnership Agreement.

EEPS also agree to:

	

-	Update organization and contact information displayed on the ENERGY
STAR Web site and the Directory of Energy Efficiency Programs (DEEP)
annually; and

-	Provide information to promote energy efficiency as an easy and
desirable option for organizations and consumers to prevent pollution,
protect the global environment, and save on energy bills.

Small Business Network (Private Sector)

	A small business may join the Network of small businesses working with
ENERGY STAR.  To join, they would provide requested information at
EPA’s ENERGY STAR Web site.  They would pledge to buy ENERGY STAR
equipment and upgrade the energy efficiency of their facilities whenever
financially viable.  As part of the Network, they may use the ENERGY
STAR promotional mark in accordance with the ENERGY STAR identity
guidelines.

	In addition, EPA may contact a small number of businesses to request
input for the development of success stories. 

(i)	Data items

Information requested at EPA’s ENERGY STAR Web site:

-	Information on type of small business (e.g., auto dealership,
grocery);

-	Contact information;

-	Size of facility (in square feet) and number of employees/members;

-	Indication of whether the facility is owned or rented; and

-	Indication of how the small business heard about ENERGY STAR.

Input for success stories.

(ii)	Respondent activities

Small businesses perform the following activities:

Provide requested information at EPA’s Web site; and 

Provide input to EPA for success stories, if requested.

BENCHMARKING

Assessing energy use is a critical component of the ENERGY STAR Program
and guidance provided by EPA to Partners.  EPA provides tools to track,
measure and compare energy use for a range of building types and
facilities.  Portfolio Manager is the primary tool for undertaking these
activities and is available online, although for specific industry
types, spreadsheet calculators may be provided. 

Portfolio Manager (Private and Public Sector)

	Portfolio Manager is an interactive energy management tool that allows
users to track and assess energy and water consumption across their
entire portfolio of facilities in a secure online environment.  Users
enter energy consumption and cost data into their Portfolio Manager
account to benchmark facility energy performance, assess energy
management goals over time and identify strategic opportunities for
savings and recognition opportunities.  A “benchmark” is defined as
a measurement of a facility’s energy performance resulting from
entering facility information and at least 12 consecutive months of
facility energy data into EPA’s Portfolio Manager.  Portfolio Manager
offers multiple types of benchmarks: the 1-100 ENERGY STAR energy
performance score for select commercial facility types, site and source
Energy Use Intensity (EUI) for all commercial facility types, weather
normalized energy values, greenhouse gas emissions, water consumption,
and annual energy and water costs. 

The ENERGY STAR scale accounts for the impacts of year-to-year weather
variations, as well as facility size, location, and several operating
characteristics.  Portfolio Manager helps the user update and track data
over time to continuously monitor performance.  The user can use both
short and long term trends in energy performance to make budget and
management decisions regarding investments in energy-related projects.

In addition, EPA intends to collect information from Portfolio Manager
users on its usability as a Web-based tool and on the effectiveness of
Portfolio Manager guidance.  Based on this information, EPA will
identify and make needed improvements.

(i) 	Data items

Information entered into Portfolio Manager:

-	Contact information;

Facility data (e.g., name, address, year constructed);

-	Facility operating characteristics (e.g., gross facility area, number
of occupants, operating hours, number of PCs);

-	Energy use information (e.g., meter name, usage data); 

-	Water use information (e.g., meter name, usage data); and

-	Solid waste management/disposal (e.g. meter/waste type name, disposal
quantity).

Information provided to EPA on the usability of Portfolio Manager and
effectiveness of guidance.

(ii)	 Respondent activities

Organizations using the benchmarking feature of the Portfolio Manager
system perform the following activities:

-	Review the instructions of Portfolio Manager and set up account;

-	Gather facility and energy data; and

-	Enter the data into Portfolio Manager.

[Note:  Users have several options for entering facility and energy data
into Portfolio Manager.  These options and associated burden are
described in Section 6(d) of this document.]

Organizations may be asked to respond to EPA questions on the usability
of Portfolio Manager.

Organizations may be asked to respond to EPA questions about guidance or
trainings on benchmarking.

	

ENERGY STAR Energy Performance Indicator and Related Systems (Private
Sector)

	EPA gives industrial companies the opportunity to measure the energy
efficiency of their plants and earn recognition for superior energy
performance.  To measure efficiency and improve energy use in the
company, a company enters basic information about its plant (e.g.,
energy consumption data) into a spreadsheet tool called the Energy
Performance Indicator (EPI), which can be downloaded from EPA’s ENERGY
STAR Web site.  The EPI produces a plant percentile score between 1 and
100 and compares that score to the most energy-efficient plants in the
industry and to the previous performance for the plant.  

	In addition, EPA has established a tool, the ENERGY STAR Challenge for
Industry, which encourages companies to track their energy performance
using a tracking system, such as Portfolio Manager, a spreadsheet-based
tracking tool that can be downloaded from the ENERGY STAR Web site
called the ENERGY STAR Energy Tracking Tool (ETT), or a company’s
in-house tracking system.  

	Companies can enter basic information into the system to track their
performance to advance energy management efforts. Only companies seeking
recognition submit outputs from using the EPI or other tracking system
to EPA.

(i)	Data items

Information entered into the EPI or alternative tracking system:

-	Plant characteristics; and

Energy consumption.

	(ii)	Respondent activities						

Organizations enter information into the EPI or alternative system.

Data Collection for Model Development and Beta Testing (Private and
Public Sector)

	Occasionally during the development or testing of a score, EPA may
collect information about annual energy use (one year’s worth of
energy data), along with basic information about facility operations,
such as the operating hours or number of workers.    

	(i)	Data items

				

Information collected from participating organizations:

-	Contact information;

-	Facility data (e.g., name, address, year constructed);

-	Facility operating characteristics (e.g., gross facility area, number
of occupants, operating hours, number of PCs); 

-	Energy use information (e.g., meter name, usage data); and

-	Water use information (e.g. meter name, usage data).

	(ii)	Respondent activities

Organizations may be asked to:

- 	Review the instructions of Portfolio Manager or spreadsheet;

-	Gather facility and energy data; and

Enter the data into Portfolio Manager or spreadsheet.

RECOGNITION

ENERGY STAR Certification (Private and Public Sector)

Buildings (Private and Public Sector)

	EPA offers the public an opportunity to display the ENERGY STAR on
their buildings if they meet certain energy performance criteria defined
by EPA.  The online application for the ENERGY STAR is submitted through
EPA’s benchmarking tool, Portfolio Manager.  To be approved to receive
the ENERGY STAR, buildings must meet specific eligibility requirements
as well as industry standards for comfort and indoor air quality.  A
Professional Engineer or Registered Architect must verify that these
requirements have been met and complete a Data Checklist
(stamped/embossed and signed).  [Note that this ICR addresses applicant
benchmarking activities in the section, “Benchmarking,” under the
heading, “Portfolio Manager.”]  

	EPA encourages certified buildings to submit building profiles for
publication on the ENERGY STAR Web site to educate the public and
promote their achievements. These profiles are not needed for
certification, but are pursued voluntarily by about 5% of certified
buildings. 

	In addition, EPA conducts audits on a small percentage of applications
for quality control purposes.  EPA confirms, for example, the accuracy
of the information provided in the application for the ENERGY STAR, and
may request facility documentation.

	EPA also expects to periodically contact representatives of buildings
that have earned the ENERGY STAR to collect information about the
characteristics of buildings that lead to top energy performance.  This
includes information on the buildings’ construction, equipment used in
the buildings, building management, and involvement in ENERGY STAR.  EPA
will use this information to better understand the specific design,
construction, and operating characteristics of ENERGY STAR certified
buildings and how these characteristics contributed to the buildings’
top energy performance.  In addition, EPA intends to collect information
about the qualification process to measure how easy it is for
organizations to use.  EPA needs this information to identify and make
improvements to the process that buildings use to qualify for the ENERGY
STAR. 

(i)	Data items

Application for ENERGY STAR certification consisting of a Data
Checklist.

Information requested by EPA as part of its application review or
quality control audit.

Profile of certified building for publication on the ENERGY STAR Web
site (optional).

Information provided to EPA for analysis of ENERGY STAR certified
buildings.

		(ii)	Respondent activities

Organizations applying for the ENERGY STAR perform the following:

-	Engage a Professional Engineer or Registered Architect to conduct a
facility data review, complete and stamp the application; 

-	Submit the online application consisting of a Data Checklist to EPA
and respond to EPA questions if any; and

-	Prepare and submit certified building profile (optional).

Some organizations may be asked to provide information as part of a
quality control audit performed by EPA on a small percentage of
applications.

ENERGY STAR certified buildings may be asked to respond to EPA questions
for analysis of ENERGY STAR certified buildings.

Plants (Private Sector)

	Industrial companies have an opportunity to earn the ENERGY STAR
certification for specific types of plants that meet EPA’s energy
efficiency criteria.  If the plant’s Energy Performance Indicator
(EPI) score is in the top quartile of the industry’s energy
performance scale, the company can choose to apply for the ENERGY STAR
certification by inputting the necessary data into the EPI and printing
out a Statement of Energy Performance (SEP).  A Professional Engineer
(PE) verifies, signs, and stamps the SEP, and completes the PE
Verification Checklist.  The EPI, certified SEP, PE Verification
Checklist, Plant Award Specification Sheet, and Plant Award Application
Letter are sent to EPA.  If the submittal contains confidential business
information (CBI), the company sends the information to EPA’s
contractor to verify energy performance results.  If approved by EPA,
the plant receives the ENERGY STAR certification. [Note that this ICR
addresses participants’ entering data into the EPI in the section,
“Benchmarking,” under the heading, “ENERGY STAR Energy Performance
Indicator and Related Systems.”]

	EPA also asks these companies to submit a profile of their certified
plant that describes how the plant improved its energy performance and
obtained recognition.  This submission is optional.

	(i)	Data items

Energy Performance Indicator (EPI).

Statement of Energy Performance.

PE Verification Checklist.

Plant Award Specification Sheet.

Plant Award Application Letter.

Profile of certified plant. This is optional.

	(ii)	Respondent activities						

Organizations using the EPI complete and submit the materials to EPA. 

These organizations may also prepare and submit a profile of certified
plant. This is optional.

ENERGY STAR Challenge for Industry (Private Sector)

	EPA has established a tool, the ENERGY STAR Challenge for Industry,
which encourages companies to pledge to reduce the energy intensity of
their sites by 10% within five years and track their progress towards
this goal using a tracking system (e.g., company in-house tracking
systems, Portfolio Manager, ETT).  Sites that achieve a 10% reduction in
energy intensity within five years of their baseline have the
opportunity to apply for recognition from EPA.  The company must
register the site’s baseline with EPA using an online registration
form. The site can then complete an online recognition application and
print out a Statement of Energy Improvement (SEI). A Professional
Engineer (PE) verifies, signs, and stamps the SEI, and completes a PE
Verification Checklist, which are both then sent via email to EPA.  If
approved by EPA, the site receives recognition (e.g., a certificate,
congratulatory letter to the CEO).   [Note that this ICR addresses
participants’ entering data into their tracking systems in the
section, “Benchmarking,” under the heading, “ENERGY STAR Energy
Performance Indicator and Related Systems.”]

	In addition, EPA may ask companies that achieve the ENERGY STAR
Challenge for Industry to submit a plant profile that describes how they
reduced their energy intensity and obtained recognition, which the EPA
posts on its Web site to educate the public. This submission is
optional.

(i)	Data items

Industry Registration Form.

Industry Recognition Application.

Statement of Energy Improvement.

PE Verification Checklist.

Plant profile. This is optional.

(ii)	Respondent activities						

Organizations seeking recognition under the ENERGY STAR Challenge for
Industry perform the following:

-	Prepare and submit the registration form; and

-	Prepare and submit the recognition application, SEI and PE
Verification Checklist to EPA.

Organizations may also prepare and submit profiles of plants that
achieve the Challenge for Industry. This is optional.

Designed to Earn the ENERGY STAR (Private Sector)

	

	To seek Designed to Earn the ENERGY STAR (DEES) recognition, an
organization is asked to become an ENERGY STAR Partner as an initial
step.  [Note that this ICR addresses organizations’ becoming a Partner
in the section, “Joining the ENERGY STAR Program and Related
Activities,” under the heading, “Commercial and Industrial Sector
Partners.”]  Then, an organization can enter information into EPA’s
online tool, Portfolio Manager, and follow simple user prompts to save
and generate information needed for the application. The tools can be
used to obtain an ENERGY STAR score of 1 – 100 to determine if the
design project’s estimated annual energy use meets criteria for DEES
recognition. 

	The organization can generate a Statement of Energy Design Intent
(SEDI). The SEDI is printed, stamped and signed by a Registered
Architect or Professional Engineer (licensed professional).  In
addition, Letters of Intent are prepared by the Architect of Record
(AOR) and building owner (for commercial new construction). 

	The SEDI, Letters of Intent from the AOR and building owner (for
commercial new construction), and an optional Design Profile are
submitted to EPA as the DEES application. Once the application is
approved, EPA will email instructions to organizations meeting the DEES
recognition criteria so they can download the DEES graphic.

	(i)	Data items

Data entered into Portfolio Manager (e.g., property use data).  

Statement of Energy Design Intent.

Letters of Intent from AOR and Building Owner (for commercial new
construction).	

Design Profile (optional).

[Note:  Organizations seeking recognition for commercial new
construction design projects are asked to submit all of the data items
above.  Organizations seeking recognition for multifamily high rise new
construction design projects are asked to submit the data items above,
except for the Letters of Intent from the AOR and building owner; they
also are asked to submit additional documents.  These additional
documents are addressed in EPA ICR 2060-0586, “EPA’s ENERGY STAR
Program in the Residential Sector.”]

	(ii)	Respondent activities

Organizations submitting a DEES application perform the following
activities:

Review application instructions and create account in Portfolio Manager,
if needed;

Gather design data and estimated annual energy use data;

Enter the data into Portfolio Manager;

Complete and submit DEES application consisting of SEDI and, for
commercial design projects, Letters of Intent from the Architect of
Record (AOR) and building owner to EPA; and

Complete and submit a Design Profile (optional).

 

ENERGY STAR Awards (Private and Public Sector)

	Organizations interested in receiving recognition for their efforts in
improving their energy performance may apply for an ENERGY STAR Award. 
EPA currently issues awards to Commercial and Industrial (C&I) Sector
Partners, Service and Product Providers (SPPs), and Energy Efficiency
Program Sponsors (EEPS).  

	(i)	Data items		

Information provided by C&I Partners:

-	General information (e.g., contact information, address,
signed/dated); and

-	Description of the following:

Management practices (e.g., best practices for managing energy).

Organization-wide improvements in energy performance.

Efforts in promoting and communicating success.

Information provided by SPPs:

-	General information (e.g., contact information, address, and
signed/dated certification); and

-	Description of the following:

Organization and Business Practices.

Benchmarking and Certification (Existing Buildings).

Benchmarking and Certification (Design Projects).

Marketing and Recognition.

Information provided by EEPS:

-	General information (e.g., contact information, address, and
signed/dated certification); and

-	Description of the following:

Category(-ies) that the EEPS program is designed to address (e.g.,
energy improvements in the C&I sector).

Program design (e.g., in terms of goals).

How ENERGY STAR has been incorporated into the Partner’s initiative.

Market effects resulting from Partner’s efforts.

Data sources used to support market claims.

(ii)	Respondent activities

Organizations that apply for an award are asked to:

-	Review the instructions; and

Complete and submit the information online.

National Building Competition (Private and Public Sector)

	Through the ENERGY STAR National Building Competition, EPA provides an
opportunity for commercial building owners and managers to earn
recognition for improving energy and water efficiency over a 12-month
period.  To participate, owners and managers must first establish a
baseline of energy (and optionally, water) use based on 12-months of
utility consumption data for each competing building.  [Note that this
ICR addresses all participant benchmarking activities in the section,
“Benchmarking,” under the heading, “Portfolio Manager.”] Teams
of commercial buildings may participate to be recognized at the team
level, and are by default also entered to compete individually.  

	Participants commit to tracking the energy (and optionally, water) use
of competing buildings for another 12 months and submit data again at a
midpoint, and at the end of the 12-month competition period.  EPA
reviews each data submission and contacts participants, if needed, as
part of a quality assessment/quality control process.  Building owners
or managers of prospective winning buildings are asked to submit an
Energy (or Water) Data Verification Form as well as an optional
questionnaire to EPA.  EPA formally recognizes prospective winners at
the end of the competition once a Professional Engineer or Registered
Architect has signed off on their Data Verification Form.    

Data items

Team Registration Form, if applicable.

Data in Portfolio Manager that is submitted to EPA for
competitor-selected buildings.

Responses to EPA questions, if any.

Questionnaire on Energy or Water Usage (e.g., requesting feedback on how
energy was saved).  This is optional.

Energy or Water Data Verification Form.

Respondent activities

Participants are asked to perform the following activities:

-	Prepare and submit a Team Registration Form, if applicable; 

-	Submit Portfolio Manager data at the beginning, midpoint, and end of
the competition; and

-	  	Respond to EPA questions, if any.

Prospective winners are asked to prepare and submit a questionnaire and
Energy or Water Data Verification Form.

Tenant Recognition Program (Private and Public Sector)

In April 2015, Congress passed the Energy Efficiency Improvement Act of
2015.  This legislation mandates EPA to develop a voluntary recognition
program for tenants in buildings.  Tenants will be encouraged to design
and build their spaces to be energy efficient.  EPA will recognize
tenants who meet EPA’s energy efficiency criteria for the design and
build-out of energy efficient tenant spaces.  The information obtained
from participants is needed by the Agency to identify participants and
determine whether their information is accurate and recognition is
warranted.  Third-party verification of each submission will be
requested.   In addition, some participants may be contacted by EPA to
answer questions about their submission, if needed.

(i)	Data Items

Contact information for tenants intending to participate.

Notification of energy efficiency accomplishments meeting EPA
requirements.

Responses to EPA questions about the submission, if needed.

(ii) 	Respondent Activities

Participants will perform the following:

-	Prepare and submit documentation to EPA indicating that their design
and build-out meets EPA requirements for recognition; and 

-	Respond to EPA questions, if needed.

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

5(a)	Agency Activities

This section describes EPA’s activities under ENERGY STAR.

JOINING THE ENERGY STAR PROGRAM AND RELATED ACTIVITIES

Partnership Letter or Agreement/Related Activities

EPA performs the following activities in regard to Partnership Letters,
Partnership Agreements, and related materials for all Partners:

Review the completed Partnership Letters, Partnership Agreements and
related materials (C&I, SPP and EEPS Partners);

Follow up with Partners, if needed;

-	Send emails, passwords, and welcome aboard kits; and

-	Update and maintain the ENERGY STAR Web site.

EPA performs the following additional activities in regard to SPPs:

Request updated contact information annually;

Receive and enter updated contact information into database;

Receive and process efforts and successes; and

Receive and process other requested materials for appropriate
Partnership category.

EPA receives annual updates from EEPS and updates the Directory of
Energy Efficiency Programs.

Small Business Network

EPA performs the following activities in regard to small businesses:

Provide email updates and conduct related activities; and

Review, complete and post success stories on the Web site.

BENCHMARKING 

Portfolio Manager

EPA performs the following activities related to the benchmarking
process:

-	Upgrade Portfolio Manager to enhance functionality (easier data entry,
more sharing options, more reporting metrics, etc);

-	Maintain secure database infrastructure, including maintaining a
firewall and monitoring system activity;

-	Perform system maintenance activities, such as deploying software
patches, correcting defects, etc.; and

-	Collect data submitted through Excel spreadsheets and enter data into
Portfolio Manager.

EPA performs the following activities in evaluating the usability of
Portfolio Manager and the effectiveness of guidance and trainings on
benchmarking in the tool:

-	Solicit feedback from respondents;

-	Review answers to questions; and

-	Design and develop Portfolio Manager software changes, as applicable,
to make the tool more effective.

ENERGY STAR Energy Performance Indicator and Related Systems

EPA enhances the functionality of and maintains the EPI and other tools
and information on the Web site.

Data Collection for Model Development and Beta Testing

EPA conducts the data collections.

RECOGNITION

ENERGY STAR Certification

Buildings

EPA performs the following activities for buildings applying for the
ENERGY STAR:

-	Review applications and follow up with organization if questions; and

-	Send a letter of denial or acceptance.

EPA receives, processes and posts profiles of certified buildings.

EPA collects information from ENERGY STAR certified buildings in
performing periodic quality control audits.

EPA performs the following activities in evaluating ENERGY STAR
certified buildings:

-	Solicit feedback from respondents;

-	Review answers to questions; and

-	Take follow-up action.

Plants

EPA performs the following activities for companies seeking the ENERGY
STAR certification for their plants:

-	Review and evaluate the submissions;

Give permission to display the ENERGY STAR certification logo; and

Review and post profiles of certified plants on the Web site.

	ENERGY STAR Challenge for Industry 

EPA performs the following activities under the ENERGY STAR Challenge
for Industry:

Review registration and application materials from companies and provide
recognition; and

Review and post profiles of plants that achieve the Challenge for
Industry on the Web site.

Designed to Earn the ENERGY STAR

EPA performs the following activities for the graphic:

-	Evaluate the DEES applications;

-	Review the Design Profiles; and

-	Update the ENERGY STAR Web site to reflect the information collected.

ENERGY STAR Awards

EPA performs the following activities to administer the awards process:

-	Develop the awards criteria;

-	Receive and review the information submitted and select winners; and

-	Take follow-up action (e.g., send letters of award or loss). 

	National Building Competition

EPA performs the following activities in regard to the National Building
Competition:

- 	Review, manage and file Team Registration Forms; 	

-	Review submittals at beginning, middle and end of competition; 

-	Conduct quality assurance during the competition and ask questions of
participants if needed;

-	Distribute, collect and review questionnaires and Energy or Water Data
Verification Forms; and

-	Prepare wrap-up report.

Tenant Recognition Program

EPA will perform the following activities in regard to the Tenant
Recognition Program:

Review and file notifications of participants' notification of
accomplishments; and

Contact participants to ask questions, if needed.

5(b)	Collection Methodology and Management

EPA gives respondents the ability to fill out forms (e.g., Partnership
Agreements) and tools electronically.  In addition, most of the
collections enable respondents to submit the information electronically
(e.g., via Web forms, email), without the use of postal mail.  EPA
reviews the submittals to ensure their accuracy and completeness. 

5(c)	Small Entity Flexibility

EPA expects that small businesses will participate in the ENERGY STAR
Program.  EPA has designed its information collections to minimize
respondent burden while obtaining sufficient and accurate information. 
For example, EPA has tailored the Small Business Network so that it
requests only the minimum information needed to establish contact with
the small business. 

5(d)	Collection Schedule

No information collection in this ICR requires collection more
frequently than quarterly. Many collections are implemented on a
one-time or annual basis. Respondents may voluntarily submit information
more frequently.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a)	Estimating Respondent Burden

Exhibits 1 through 3 estimate the annual respondent burden hours for
information collection activities associated with the ENERGY STAR
Program in the commercial and industrial sectors.  Table 1 presents the
total annual hours to respondents under all activities.

6(b)	Estimating Respondent Costs

Exhibits 1 through 3 present the annual respondent costs for information
collection activities associated with the ENERGY STAR Program in the
commercial and industrial sectors. Table 1 presents the total annual
respondent costs under all activities.  Specific cost assumptions are
discussed below.

(i)	Estimating Labor Costs

EPA estimates an average hourly respondent labor cost (2015) of
$104.83/hr for legal staff, $92.05/hr for managerial staff, $43.57/hr
for technical staff, and $27.10/hr for clerical staff.  To derive these
hourly estimates, EPA referred to the May 2014 National Occupational
Employment and Wage Estimates published by the U.S. Bureau of Labor
Statistics.  This publication summarizes the unloaded (base) hourly rate
for major occupational groups.  EPA then applied the standard government
overhead factor of 1.6 to the unloaded rate to derive loaded hourly
rates. Finally, EPA updated the loaded hourly rates to June 2015 levels
using Employment Cost Indexes developed by the U.S. Bureau of Labor
Statistics.

(ii)	Estimating Capital and Operations and Maintenance (O&M) Costs

Operation and maintenance (O&M) costs are those costs associated with a
paperwork requirement incurred continually over the life of the ICR. 
They are defined by the Paperwork Reduction Act of 1995 as “the
recurring dollar amount of costs associated with O&M or purchasing
services.”   Most of the collections in this ICR can be done online. 
If a collection involves submittal by postal mail, this ICR includes O&M
costs for postage (i.e., $0.49).  

In addition, this ICR includes costs respondents pay for contractor
support in the completion of various collections, as listed below
(2015). EPA developed these estimates based on the best judgment of
Agency and contractor personnel who implement the program.

$3,330 for a petroleum company to obtain support from a consulting
service to generate energy-efficiency results of its plant.

$1,665 for a respondent to obtain support from an external Professional
Engineer or Registered Architect to conduct a facility data review in
applying for ENERGY STAR certification for a building.

$120 for a respondent to obtain support from an external Registered
Architect or Professional Engineer in completing (e.g., reviewing,
signing) the Statement of Energy Design Intent (SEDI).

$515 for a respondent to obtain support from an external Professional
Engineer or Registered Architect under the National Building Competition
to complete the Energy or Water Data Verification Form.

$999 for a respondent to obtain third-party verification of the
submittal for recognition under the Tenant Recognition Program.

There are no capital costs associated with any activities related to the
ENERGY STAR Program in the commercial and industrial sectors.

6(c)	Estimating Agency Burden and Costs

The hourly Agency labor rates used in this ICR were obtained from the
2015 Salary Tables for federal civilian employees, which are published
by the Office of Personnel Management.  EPA estimates an average hourly
labor cost of $77.92/hr for legal staff, $72.86/hr for managerial staff,
$53.42/hr for technical staff, and $21.46/hr for clerical staff.  The
labor costs are based on the following GS levels and steps:  legal labor
rates were based on GS Level 15, Step 1, managerial labor rates were
based on GS Level 14, Step 4, technical labor rates were based on GS
Level 12, Step 5, and clerical labor rates were based on GS Level 5,
Step 1.  To derive hourly estimates, EPA multiplied hourly rates by the
standard government overhead factor of 1.6.  Agency burden and costs are
estimated in Exhibits 4 through 6 and Table 2.

6(d)	Estimating the Respondent Universe

In this section, EPA describes its estimates of the number of
respondents carrying out the information collections under the ENERGY
STAR Program in the commercial and industrial (C&I) sectors.  In
developing its estimates, EPA referred to its databases (e.g., iStar)
and other documentation in order to understand historical trends in the
number of new and existing respondents.  Based on this understanding,
EPA has estimated the average number of respondents associated with each
of the information collections under the program.

In total, EPA estimates that 51,515 organizations participate under the
ENERGY STAR Program in the commercial and industrial sectors annually. 
In deriving this estimate, EPA ascertained the annual number of users of
its online tool, Portfolio Manager (49,300 organizations).  EPA notes
that most respondents in this ICR use the tool during the year and are
therefore captured in this estimate.  For example, organizations seeking
recognition (e.g., under the National Building Competition or ENERGY
STAR certification for buildings) benchmark their buildings in Portfolio
Manager as part of the recognition program and are therefore reflected
in the estimate.  Therefore, to avoid double-counting, EPA next
identified respondents not captured in the 49,300-organization estimate.
 This includes organizations joining the program each year and
organizations carrying out other collections that do not involve the
tool (2,215 organizations). EPA estimates that 51,515 respondents total
will participate in the ENERGY STAR Program.

These organizations are discussed further below.

JOINING THE ENERGY STAR PROGRAM AND RELATED ACTIVITIES (EXHIBIT 1)

Commercial and Industrial Sector Partners

	EPA estimates that, on average, 150 organizations in the commercial and
industrial sectors will submit a Partnership Agreement to EPA each year.
 EPA may ask Partners follow-up questions.  In addition, EPA estimates
that five Partners will prepare and follow an energy management plan
each year.  

Service and Product Providers

	EPA estimates that, on average, 70 Service and Product Providers (SPPs)
will submit a Partnership Agreement to EPA each year through an online
system.  These SPPs will also submit requested materials for their
appropriate category (e.g., Teaming Profiles from Industrial SPPs).  In
addition, EPA estimates that, on average, 200 existing SPPs will update
their contact information and 125 existing SPPs will communicate their
efforts and successes to EPA annually.  

Energy Efficiency Program Sponsors

	EPA estimates that, on average, 10 Energy Efficiency Program Sponsors
(EEPS) will submit a Partnership Agreement each year. EPA estimates that
an additional three EEPS will already have joined the ENERGY STAR
Program and need only submit a Participation Form online to expand their
Partnership from one EEPS program to another (e.g., from Products to
C&I).  In addition, EPA estimates that, on average, 60 existing EEPS
will actively participate in the program, update contact information on
the ENERGY STAR Web site and DEEP, and provide information to promote
energy efficiency.

Small Business Network

	EPA estimates that 1,650 small businesses will provide the requested
information to EPA each year to join the Network.  In addition, EPA
expects to collect input from 12 small businesses each year for the
development of success stories.  

BENCHMARKING (EXHIBIT 2)

Portfolio Manager

	The table below summarizes Portfolio Manager data used in this
analysis.  It reflects that EPA provides three alternative methods for
organizations to enter information into Portfolio Manager and benchmark
their buildings: manual data entry; data entry with Excel spreadsheet,
and data entry using Electronic Web Services.  

	For each method, the table shows the total annual number of new
accounts established in the tool along with the annual number of
buildings benchmarked.  It also shows the annual number of active
accounts.  For purposes of this ICR, the number of active accounts
represents the total number of organizations using the tool to benchmark
their buildings annually.   EPA developed these estimates by compiling
data over the past three years and extrapolating over the next three
years.  

Annual Number of New Accounts, Benchmarked Buildings and Active Accounts

in Portfolio Manager1

Benchmarking Method	Annual No. of New Accounts	Annual No. of Buildings
Benchmarked – Total	Annual Number of Active Accounts

1. Manual Data Entry	23,800	31,000	42,800

2. Data Entry with Excel Spreadsheet	700	71,000	1,100

3. Data Entry using Electronic Web Services

    Provider Accounts	26	144,000	5,400

    Customer Accounts	1,300



Total	25,826	246,000	49,300

1 These estimates are based on reviewing actual data over the past three
years (2012-2014) from standard reports (e.g., benchmarking reports,
quarterly data import reports) and extrapolating over the next three
years (2016-2018). This analysis was performed in the fall of 2015.

	Each method is discussed in greater detail below:

Manual Data Entry. EPA estimates that, each year, 23,800 users will read
the instructions and set up an account in Portfolio Manager to benchmark
their buildings manually.  In addition, EPA estimates that 31,000
buildings will be manually benchmarked annually, on average.  Of these,
EPA estimates that users will benchmark 65% (20,150) by gathering
facility and energy data for their buildings not using standard industry
practices.  EPA estimates that users will benchmark 35% (10,850) by
gathering facility and energy data for their buildings using standard
industry practices (i.e., usual and customary business practices that
would be conducted even in the absence of ENERGY STAR).  These practices
could include, for example, compiling and keeping readily available,
centralized paper and/or electronic records (e.g., invoices, facility
data) for their portfolio of buildings.  Users who employ such standard
industry practices would generally incur a lower incremental burden than
others to gather data for Portfolio Manager.  Finally, all users will
enter the data into Portfolio Manager to benchmark their buildings. 

Exhibit 2 includes weighted-average burden estimates for gathering and
entering data into Portfolio Manager to account for standard business
practices as well as new and repeat benchmarks.  See the table below for
the inputs used in these weighted-average calculations.

Manual Data Entry

Activity	No. of Buildings 	Burden per New Benchmark	Burden per Repeat
Benchmark

Gathering data for benchmarks not using standard business practices
20,150	4 hrs	0.5 hr

Gathering data for benchmarks using standard business practices	10,850 
2 hrs	0.25 hr

Entering data into Portfolio Manager	31,000 	0.75 hr	0.25 hr



Data Entry with Excel Spreadsheet. EPA estimates that, each year, 700
organizations will set up an account to provide their data via Excel
spreadsheet to EPA.  The data will be uploaded into Portfolio Manager. 
In addition, EPA estimates that 71,000 buildings will be benchmarked
annually using this method.  Exhibit 2 includes weighted-average burden
estimates for gathering and entering data into Portfolio Manager to
account for new and repeat benchmarks.  See the table below for the
inputs used in these weighted-average calculations.  

Data Entry with Excel Spreadsheet

Activity	No. of Buildings 	Burden per New Benchmark	Burden per Repeat
Benchmark

Gathering data for benchmarks 	71,000	2 hrs	0.25 hr

Entering data into Portfolio Manager	71,000	0.25 hr	0.10 hr



Data Entry using Electronic Web Services.  EPA expects that 26 new
providers will use this benchmarking method each year.  EPA estimates
that accounts also will be established for 1,300 customers each year. 
In addition, EPA estimates that information will be gathered and entered
into Portfolio Manager for 144,000 buildings annually. Exhibit 2
includes weighted-average burden estimates for gathering and entering
data into Portfolio Manager to account for new and repeat benchmarks. 
See the table below for the inputs used in these weighted-average
calculations.  

Data Entry using Electronic Web Services

Activity	No. of Buildings 	Burden per New Benchmark	Burden per Repeat
Benchmark

Gathering data for benchmarks 	144,000	1 hr	0 hr

Entering data into Portfolio Manager	144,000	0.1 hr	0.1 hr

	

	Further, EPA estimates that, each year, it will ask 50 users of
Portfolio Manager about the usability of the tool.  It will also ask 50
users for feedback about the guidance or training on the tool each year.

ENERGY STAR Energy Performance Indicator and Related Systems 

	ENERGY STAR Energy Performance Indicator

	EPA gives industrial companies the opportunity to measure the energy
efficiency of their plants and earn recognition for superior energy
performance. EPA estimates that it takes a company 20 minutes per plant
to read the instructions and enter information into the EPI.

	Companies use the EPI to produce plant scores, except for petroleum
companies.  Petroleum companies use a third-party consulting service to
measure the energy efficiency of their plants.  To request a plant score
from the consulting service, a petroleum company is estimated to spend
10 minutes and $3,330 as a flat fee per plant.

	As shown in the table below, EPA estimates that industrial companies
will enter information/generate scores for 177 plants annually, on
average, during the 3-year life of this ICR (i.e., (156 + 177 + 199) / 3
years).  This includes 167 non-petroleum plants and 10 petroleum plants
on average each year.  

Annual Number of Plants During 3-Year Life of ICR

Type of Plant

	

	Annual Number of Plants

	Year 1	Year 2	Year 3	3-Year Average

Non-Petroleum	147	167	188	167

Petroleum	9	10	11	10

Total	156	177	199	177



	ENERGY STAR Challenge for Industry

	EPA has established a tool, the ENERGY STAR Challenge for Industry,
which encourages companies to track their energy performance using a
tracking system.  EPA estimates that 70 companies (annually) currently
use their existing in-house system to track their energy performance as
a standard industry practice (i.e., usual and customary business
practices that would be conducted even in the absence of ENERGY STAR). 
EPA does not expect these companies to incur any incremental burden in
tracking their energy performance under the ENERGY STAR Challenge for
Industry.  EPA estimates that another five companies will spend 2.5
hours to use an alternative ENERGY STAR tracking system (e.g., ETT). 
Unlike companies that use their existing in-house systems as a standard
industry practice, companies using alternative ENERGY STAR systems will
incur incremental time to set up and use the system.   

Data Collection for Model Development and Beta Testing

	EPA expects to expand Portfolio Manager or the Energy Performance
Indicator (EPI) downloadable spreadsheet tools by adding new facility
types and revising existing types.  In doing so, the Agency may need to
gather information for model development and/or beta testing to make
sure the tool produces relevant results.  EPA expects that organizations
will submit information on 950 properties annually.  

RECOGNITION (EXHIBIT 3)

ENERGY STAR Certification

Buildings

	EPA estimates that organizations will submit 8,000 applications for the
ENERGY STAR each year.  These organizations must benchmark the building,
engage a Professional Engineer or Registered Architect to conduct a
facility data review, and submit an online application consisting of a
Data Checklist to EPA.  EPA estimates that 80% (6,400) will contract a
Professional Engineer or Registered Architect and 20% (1,600) will use
an in-house Professional Engineer or Registered Architect.  [Note that
this ICR burdens participants for benchmarking in the section,
“Benchmarking,” under the heading, “Portfolio Manager.” See
Exhibit 2.]

	EPA estimates that 400 profiles of certified buildings will be
submitted annually. In addition, EPA estimates that it will ask for
additional information on 120 ENERGY STAR certified building
applications annually as part of its quality control audits.  

	EPA also expects to contact representatives of buildings that have
earned the ENERGY STAR to collect information about the characteristics
of buildings that lead to top energy performance.  EPA also intends to
collect information about the qualification process to measure how easy
it is for organizations to use.  EPA intends to contact no more than 66
representatives annually.

Plants

	Industrial companies have an opportunity to apply to EPA to display the
ENERGY STAR certification for specific types of plants that meet EPA’s
energy efficiency criteria.  If the plant’s EPI score is in the top
quartile of the industry’s performance scale, the company can choose
to apply for the ENERGY STAR certification by inputting the necessary
data into the EPI and printing out the corresponding  Statement of
Energy Performance (SEP).  

	EPA estimates that industrial companies will seek recognition for 177
plants annually, on average, during the 3-year life of this ICR.  This
includes 167 non-petroleum plants and 10 petroleum plants each year.  

	In addition, EPA estimates that 30 profiles of certified plants will be
submitted annually. Submission of plant profiles is optional. [Note that
this ICR burdens participants for tracking their energy performance in
the section, “Benchmarking,” under the heading, “ENERGY STAR
Energy Performance Indicator and Related Systems.”  See Exhibit 2.]

	ENERGY STAR Challenge for Industry 

EPA estimates that 75 sites will register with EPA annually and 50 sites
will seek recognition annually by preparing/submitting the application
materials.  [Note that this ICR burdens participants for tracking their
energy performance in the section, “Benchmarking,” under the
heading, “ENERGY STAR Energy Performance Indicator and Related
Systems.”  See Exhibit 2.]  Further, EPA estimates 10 companies will
submit a plant profile annually for sites that achieve the Challenge for
Industry.  

  

	Designed to Earn the ENERGY STAR

	EPA estimates that 80 Designed to Earn the ENERGY STAR (DEES)
applications will be submitted to EPA each year by organizations seeking
recognition for commercial or multifamily high rise (MFHR) new
construction design projects.  The application process involves
reviewing the DEES application instructions and setting up a new account
in Portfolio Manager if needed.  EPA estimates 20 first-time applicants
will need to perform these activities.  Finally, EPA estimates that 25
Design Profiles, which are optional, will be submitted annually.  [Note:
 In addition to these documents, organizations with MFHR projects are
asked to submit additional documents which are not addressed in this
ICR.  Rather, they are addressed in 2060-0586, “EPA’s ENERGY STAR
Program in the Residential Sector.”]  

ENERGY STAR Awards

	EPA estimates that 75 C&I Partners, 15 SPPs, and 15 EEPS will apply for
an ENERGY STAR Award each year.  

National Building Competition

	EPA estimates that, on average, 150 Team Registration Forms will be
submitted by respondents annually.  EPA further estimates that 175
respondents will commit to tracking the energy (and optionally, water)
use of competing buildings and submit Portfolio Manager data to EPA
three times annually to participate in the competition (i.e., 175
respondents x 3 submittals/yr = 525 submittals/yr).  [Note that this ICR
addresses all participant benchmarking activities in the section,
“Benchmarking,” under the heading, “Portfolio Manager.”]  EPA
expects to contact 40% of these respondents for clarification of their
first submission, 25% for their mid-point submission, and 30% for their
final submission (i.e., 175 respondents x 95% = 166 emails/yr).

	Further, EPA estimates that it will contact prospective winners to
request completion of an optional questionnaire and an Energy or Water
Data Verification Form for each of their prospective winner properties
(i.e., 185 properties in total).  EPA estimates that, for 30% of these
properties (56 properties), an external Professional Engineer or
Registered Architect will be contracted to complete the form.  For the
remaining 70% of properties (129 properties), an in-house Professional
Engineer or Registered Architect will be used to complete it.

	Tenant Recognition Program

EPA estimates that 100 organizations will participate in the ENERGY STAR
Tenant Recognition Program each year.  These organizations will design
and build their tenant spaces to be energy efficient and notify EPA of
their accomplishments in meeting EPA requirements.  Third-party
verification of their submission will be requested.  In addition, some
participants may be contacted by EPA to answer questions about their
submission, if needed.









6(e)	Bottom Line Burden Hours and Cost Tables

(i)	Respondent Tally

As shown in Table 1, EPA estimates the total annual hour and cost burden
to respondents to be 254,084 hours and $21,784,161.  The burden to
respondents over the three years of this ICR is estimated to be 762,252
hours and $65,352,483.

(ii)	Agency Tally

As shown in Table 2, EPA estimates the total annual hour and cost burden
to the Agency to be 17,840 hours and $884,051.  The bottom-line burden
to the Agency over the three years of this ICR is estimated to be 53,520
hours and $2,652,153.

6(f)	Reasons for Change in Burden 

EPA estimates a total annual respondent burden in this ICR, 1772.07, of
254,084 hours.  This is an increase of 59,575 hours from the currently
approved burden of 194,509 hours in ICR 1772.06.  

Table 3 explains this increase.  Specifically, the table presents the
total annual hours estimated in ICR 1772.06 and ICR 1772.07 for each
information collection (see columns 1-3).  The table then compares their
respective hours for each collection to derive the change in hours, and
indicates whether this hour-change resulted from a program change and/or
adjustment (see column 4).  The table also briefly describes the program
change and/or adjustment (see column 5).  Finally, the table sums up all
hour-changes to derive the total annual change in hours for all
collections (see the bottom row of the table).

The table shows that there was a 291-hour decrease due to program
changes and a 59,866-hour increase due to adjustments resulting from
program growth.  This resulted in a total net increase of 59,575 hours
in ICR 1772.07.  

The table shows that the vast majority of the increase in ICR 1772.07
resulted from EPA’s adjustments to its estimates of the public’s use
of Portfolio Manager, EPA’s voluntary online tool for energy
management.  Based on the previous three years, EPA expects the number
of participants using Portfolio Manager to increase significantly over
the next three years.  For example, from the currently approved ICR to
this one, the number of buildings being benchmarked in Portfolio Manager
is estimated to increase from 184,000 to 246,000 buildings annually.    

There are a number of reasons for this projected increase.  A primary
reason is that state and local governments are increasingly leveraging
ENERGY STAR as a way for the public to respond to rising energy costs
and global warming.  In addition, associations, utilities, and
third-party providers are voluntarily communicating ENERGY STAR messages
and promoting the use of ENERGY STAR tools and strategies in an effort
to help companies reduce their energy consumption and find more
environmentally friendly ways to conduct business.   

6(g)	Burden Statement  

	The public reporting and recordkeeping burden for this collection of
information is estimated to average 53 minutes per response.

Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a federal agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.  An agency may not
conduct or sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB
control number.  The OMB control numbers for EPA's regulations are
listed in 40 CFR Part 9 and 48 CFR Chapter 15.     

To comment on the Agency’s need for this information, the accuracy of
the provided burden estimates, and any suggested methods for minimizing
respondent burden, including the use of automated collection techniques,
EPA has established a public docket for this ICR under Docket ID Number
EPA-HQ-OAR-2006-0407, which is available for online viewing at
www.regulations.gov, or in person viewing at the Air and Radiation
Docket in the EPA Docket Center (EPA/DC), WJC West Building, Room 3334,
1301 Constitution Avenue, NW, Washington, D.C.  The EPA Docket Center
Public Reading Room is open from 8:00 a.m. to 4:30 p.m., Monday through
Friday, excluding legal holidays.  The telephone number for the Reading
Room is (202) 566-1744, and the telephone number for the Air and
Radiation Docket is 202-566-1742.  An electronic version of the public
docket is available at www.regulations.gov.  This site can be used to
submit or view public comments, access the index listing of the contents
of the public docket, and to access those documents in the public docket
that are available electronically.  When in the system, select
“search,” then key in the Docket ID Number identified above.  Also,
you can send comments to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, D.C. 20503, Attention:  Desk Officer for EPA.  Please
include the EPA Docket ID Number EPA-HQ-OAR-2006-0407 in any
correspondence.

 Whereas it takes up to five hours to perform a new benchmark using
manual data entry, it takes about one hour using Web Services.  

 The economic benefits for the ENERGY STAR Program represent the present
value of the estimated net energy bill savings for consumers and
businesses. Net energy bill savings are the difference between total
consumer energy bill savings and the incremental additional investment
in energy-efficient technologies and services.

 For additional information on the ENERGY STAR Program, refer to the
document, “Climate Protection Partnerships 2013 Annual Report.” It
can be found at: http://www.energystar.gov/about/history/annual-reports.

  This participant group includes businesses and other organizations in
such fields as commercial and corporate real estate, education,
entertainment, government, healthcare and senior care facilities,
hospitality, manufacturing and industry, multifamily housing, retail,
wastewater and drinking water treatment, and associations.  

 This participant group includes companies that provide energy
efficiency services and/or products in the commercial and industrial
markets.  

 This participant group includes regulated utilities, publicly owned
utilities, and energy delivery companies; national, regional, state, or
local government entities; and other organizations involved in
coordinating and/or administering energy-efficiency or environmental
education programs that promote ENERGY STAR, including ENERGY STAR
certified commercial and industrial buildings.

 EEPS are given the opportunity to join one or more programs within
ENERGY STAR when they complete and submit their Partnership Agreement
(e.g., C&I, Products).  This ICR (No. 1772) consolidates the burden for
all EEPS Partnership Agreements across all programs.  When this ICR is
renewed three years from now, EPA intends to move this consolidated
burden to the Products ICR (No. 2078) because the Products program sees
the greatest amount of EEPS partnering activity.

 These documents include the following: Multifamily High Rise Developer
Participation Agreement (5900-267), Multifamily High Rise Project
Application (5900-266), Multifamily High Rise Testing & Verification
Worksheet (5900-269), Multifamily High Rise Submittal Validation Form
(5900-270), and Multifamily High Rise Performance Path Calculator
(5900-268).

 U.S. Bureau of Labor Statistics (BLS), Occupational Employment
Statistics (OES), May 2014 National Occupational Employment and Wage
Estimates.  Available online at:  HYPERLINK
"http://www.bls.gov/oes/current/oes_nat.htm"
http://www.bls.gov/oes/current/oes_nat.htm .

  For purposes of this analysis, the following occupational groups of
the U.S. Bureau of Labor Statistics (BLS) were used:  Legal staff, SOC
23-1011, Lawyers; managerial staff, BLS SOC Code 11-1021, General and
Operations Managers; technical staff, BLS SOC Code 17-3027, Mechanical
Engineering Technicians; and clerical staff, BLS SOC Code 43-6014,
Secretaries and Administrative Assistants, Except Legal, Medical, and
Executive.

 Bureau of Labor Statistics, Economic News Release, “Table 2.
Seasonally Adjusted: Employment Cost Index for wages and salaries, by
ownership, occupational group, and industry.” Available online at:  
HYPERLINK "http://www.bls.gov/news.release/eci.t02.htm" 
http://www.bls.gov/news.release/eci.t02.htm .

 See “Salary Table 2015-GS Incorporating the 1% General Schedule
Increase Effective January 2015” available at   HYPERLINK
"https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/sala
ry-tables/pdf/2015/GS_h.pdf" 
https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salar
y-tables/pdf/2015/GS_h.pdf .

 EEPS are given the opportunity to join one or more programs within
ENERGY STAR when they complete and submit their Partnership Agreement
(e.g., C&I, Products).  This ICR (No. 1772) consolidates the burden for
all EEPS Partnership Agreements across all programs.  When this ICR is
renewed three years from now, EPA intends to move this consolidated
burden to the Products ICR (No. 2078) because the Products program sees
the greatest amount of EEPS partnering activity.

 Note that this ICR estimates burden based on the total annual number of
buildings benchmarked (246,000), not the number of organizations using
the tool. EPA believes the annual number of buildings benchmarked is
more directly correlated to total burden.  See Exhibit 2.

 These documents include the following: Multifamily High Rise Developer
Participation Agreement (5900-267), Multifamily High Rise Project
Application (5900-266), Multifamily High Rise Testing & Verification
Worksheet (5900-269), Multifamily High Rise Submittal Validation Form
(5900-270), and Multifamily High Rise Performance Path Calculator
(5900-268).

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