  SEQ CHAPTER \h \r 1 		

				

										

										

 

SUPPORTING STATEMENT FOR

INFORMATION COLLECTION REQUEST:

“INFORMATION COLLECTION ACTIVITIES ASSOCIATED WITH 

EPA’S ENERGY STAR® PRODUCT LABELING”

June 7, 2007

Prepared by:

U.S. Environmental Protection Agency

Office of Air and Radiation

Climate Protection Partnerships Division

Table of Contents

1	Identification of the Information Collection	2

	1.a  Title of the Information Collection	2

	1.b  Short Characterization/Abstract	2

2	Need for and Use of the Collection	3

2.a  Need/Authority for the Collection	3

2.b  Practical Utility/Users of the Data	4

3	Nonduplication, Consultations, and Other Collection Criteria	6

3.a  Nonduplication	6

3.b  Public Notice Required Prior to ICR Submission to OMB 	6

		3.c  Consultations	6

3.d  Effects of Less Frequent Collection	7

3.e  General Guidelines	7

3.f  Confidentiality	7

	3.g  Sensitive Questions	8

4	The Respondents and the Information Requested	8

	4.a  Respondents and SIC Codes	8

4.b  Information Requested	9

5	Information Collected:  Agency Activities, Collection Methodology, and
Information Management	12

5.a  Agency Activities	12

5.b  Collection Methodology and Management	13

5.c  Small Entity Flexibility	14

5.d  Collection Schedule	14

6	Estimating the Burden and Cost of the Collection	14

6.a  Estimating Respondent Burden	14

6.b  Estimating Respondent Costs	14

	6.c  Estimating Agency Burden and Costs	15

	6.d  Estimating the Respondent Universe and Total Burden and Costs	16

6.e  Bottom Line Burden Hours and Costs	17

	6.f  Reasons for Change in Burden	17

6.g  Burden Statement	19

EXHIBITS

Exhibit 1:	Estimated Annual Respondent Burden and Cost	23

Exhibit 2:	Estimated Annual Agency Burden and Cost	24

1	IDENTIFICATION OF THE INFORMATION COLLECTION

1.a	TITLE OF THE INFORMATION COLLECTION

	ENERGY STAR® Product Labeling (Renewal). EPA ICR No. 2078.02; OMB
Control No. 2060-0528.

		

1.b	SHORT CHARACTERIZATION/ABSTRACT

	In April 1993, President Clinton issued the Climate Change Action Plan,
which was designed to reduce U.S. emissions of greenhouse gases, while
guiding the U.S. economy toward environmentally sound economic growth
into the next century.  EPA’s ENERGY STAR product labeling is an
important part of the overall effort to reduce greenhouse gas emissions
from projected 2000 levels by 19.4 million metric tons of carbon
equivalent by 2010.  ENERGY STAR is aimed at preventing pollution rather
than controlling it after its creation.

	This voluntary program was designed to create self-sustaining markets
for energy-efficient products and services via a common labeling
strategy and awareness campaign and through strategic market
interventions designed to overcome barriers identified for designated
product markets. In the 13 years since it was first established, ENERGY
STAR has become a very successful program.  A 2006 market survey by the
Consortium for Energy Efficiency (CEE) reported that over 65% of US
households recognize the ENERGY STAR label.  Currently ENERGY STAR has
over 1,700 manufacturing Partners and 40,000 qualifying product models. 
Partners see the ENERGY STAR label as a very useful and effective
marketing tool for highlighting the energy efficiency of their products
to consumers and others.   In addition, ENERGY STAR provides Partners
with recognition as environmental leaders.  

	ENERGY STAR is a program jointly administered by EPA and the Department
of Energy.  Each agency leads work on different product categories. 
Within EPA, the program is administered by the Climate Protection
Partnerships Division (CPPD). This ICR covers only those activities
undertaken by CPPD.

	The program currently covers 47 products which fall into 33 broad
product categories including the following:

	

office equipment (computers, monitors, imaging equipment)

consumer electronics (TVs, VCRs, home audio equipment, DVD products,
set-top boxes, cordless telephones, cordless telephone/answering machine
combination units, external power adapters, battery charging systems,
digital-to-analog converter boxes)

heating and cooling equipment (central air conditioners, air-source heat
pumps, ground-source heat pumps, boilers, furnaces, programmable
thermostats, ceiling fans, commercial air conditioners, commercial heat
pumps, ventilating fans)

lighting (indoor and outdoor residential lighting fixtures, exit signs)

home envelope (roof products, insulation)

appliances (dehumidifiers, room air cleaners)

commercial foodservice (fryers, hot food holding cabinets, solid door
refrigerators and freezers, steam cookers)

water coolers

vending machines

A limited number of additional products are expected to be added to the
program in the future.

	For the information collections, EPA assembles data from ENERGY STAR
Partners.  Partners are product manufacturers who wish to use the ENERGY
STAR label to differentiate their product as having greater energy
efficiency than others found in the market.  Partners sign a new
Partnership Agreement (PA) with EPA in order to become a Partner.  In
order to use the ENERGY STAR label on a product, the Partner must first
determine if the product qualifies.  Each product category covered by
ENERGY STAR has a unique set of energy efficiency specifications that
are used to determine qualification.  In addition, a specific testing
method must be used to determine qualification.  All of this information
is contained in the PA.

	Partners are asked to submit qualifying product information to EPA so
that EPA can, in turn, provide this information to consumers in an
easy-to-use format so that they will know which products to purchase in
order to save energy.  In addition, Partners for roof product and
residential light fixtures are requested to submit testing reports used
to complete the qualifying product information in order to verify
qualification.  Partners may submit this information electronically or
in hard-copy form.  For some product categories (office equipment and
consumer electronics), Partners are able to submit qualifying product
information directly on-line via the On-line Products Submittal Tool
(OPS). At minimum Partners are requested to submit updates to qualifying
product information on an annual basis, so as to ensure that EPA
information is recent and accurate.  The information will be compiled
into a complete qualifying products list per product category, posted on
the ENERGY STAR Web site, and supplied to those purchasers who request
it via phone, fax, or e-mail. 	

	Partners are also asked to submit annual unit shipment data for their
ENERGY STAR qualifying products.  EPA is flexible as to the methods by
which Partners may submit unit shipment data.  For example, if Partners
already submit this type of information to a third party, such as a
trade association, they are given the option of arranging for shipment
data to be sent to EPA via this third party to avoid duplication of
efforts and to ensure confidentiality.

	Finally, Partners that wish to receive recognition for their efforts in
ENERGY STAR may submit an application for the Partner of the Year Award.

2	NEED FOR AND USE OF THE COLLECTION

2.a	NEED/AUTHORITY FOR THE COLLECTION

	Section 103(a) of the Clean Air Act authorizes EPA to establish “a
national research and development program for the prevention and control
of air pollution.” As part of such a program, EPA is to “conduct and
promote the coordination and acceleration of research, investigations,
experiments, demonstrations, surveys, and studies relating to the
causes, effects (including health and welfare effects), extent,
prevention and control of air pollution.” Section 103(a)(1). 

	In addition, as a component of the program, section 103(g) directs the
Administrator to “conduct a basic engineering research and technology
program to develop, evaluate, and demonstrate nonregulatory strategies
and technologies for air pollution prevention.” The section calls on
the Administrator to provide opportunities for industry, public interest
groups, scientists, and other interested persons to participate in
strategy development. Section 103(g) further directs EPA to include as
elements in the program “improvements in nonregulatory strategies and
technologies for preventing or reducing multiple air pollutants
including sulfur oxides, nitrogen oxides, heavy metals, PM-10
(particulate matter), carbon monoxide, and carbon dioxide...”  The
strategies and technologies are to improve various air pollutant
reduction and nonregulatory control strategies, including energy
conservation.

	The ENERGY STAR Labeling Program is one component of the
Administrator’s response. ENERGY STAR is a voluntary partnership
between the U.S. EPA, the U.S. Department of Energy, product
manufacturers, local utilities, and retailers.  Partners help promote
efficient products by labeling qualifying models with the ENERGY STAR
label and educating consumers about the benefits.  The label provides an
easy way for consumers to identify energy-efficient products that save
money on utility bills and help the environment. By using less energy,
these products help reduce the demand to create power, which is
typically generated by power plants that burn fossil fuels. As such,
they help reduce greenhouse gas emissions that are generated by these
stationary sources.  ENERGY STAR demonstrates how providing consumer
product information can be used as a nonregulatory strategy to reduce
greenhouse gas emissions.

	This information collection is designed to support and ensure the
success of ENERGY STAR as a nonregulatory strategy for reducing
greenhouse gas emissions.

	In addition, in 2005, Congress enacted the Energy Policy Act.  Section
131 of the Act amends Section 324 (42 USC 6294) of the Energy Policy and
Conservation Act and requires, among other provisions, that the
Administrator of the EPA and the Secretary of the Department of Energy
work jointly 1) to promote ENERGY STAR compliant technologies as the
preferred technologies in the marketplace for achieving energy
efficiency and reducing pollution; 2) to enhance public awareness of the
ENERGY STAR label; 3) to preserve the integrity of the ENERGY STAR
label; 4) to regularly update ENERGY STAR product criteria; and 5) to
solicit comments from interested parties prior to establishing or
revising an ENERGY STAR product category or criterion.

	This information collection is designed to support and ensure the
success of ENERGY STAR as a nonregulatory strategy for reducing
greenhouse gas emissions

2.b	PRACTICAL UTILITY/USERS OF THE DATA

	EPA uses information	 collected from ENERGY STAR Partners for a variety
of purposes.  These are described below:

Partnership Agreement

	EPA uses information submitted in the PA to officially establish
participation in ENERGY STAR.  Partner data from PAs are also entered
into the Integrated Strategic Tracking and Recruiting Database (iSTAR)
that serves as a source of general information and as a mailing list.	

Qualifying Product Information

	EPA uses qualifying product information submitted by Partners to
educate and build awareness among consumers as to which products meet
the qualification of ENERGY STAR.  Information submitted by Partners is
entered into iSTAR, aggregated into a list and posted in the ENERGY STAR
Web site.  Consumers and institutional purchasers are directed to the
ENERGY STAR Web site to locate model names and numbers of ENERGY STAR
qualifying products.

Testing Reports

	Submittal of testing reports is required by ENERGY STAR Partners for
residential light fixtures and roof products.  In the past,
manufacturers in these two industries expressed mistrust of their
competitors and questioned the integrity of the qualifying product
information submitted.  Partners asked that additional measures be taken
to verify that qualifying product information is accurate and credible. 
As such, EPA requires the submission of testing reports from Partners in
these two industries.

Unit Shipment Data

	EPA uses unit shipment data supplied by Partners to monitor the
progress of ENERGY STAR in stimulating the supply of and demand for
energy efficient products in the market.  This information is aggregated
and used to evaluate ENERGY STAR overall to ensure continued success and
benefits to Partners.  In particular, this data is used to determine
whether or not ENERGY STAR specifications need to be revised.  For
example, if the data shows that an overwhelming majority of the market
meets the current specification levels, it may be appropriate for EPA to
make the specification more stringent so that ENERGY STAR can continue
to be used by Partners to highlight their more efficient products.  On
the other hand, if the data shows that no portion of the current market
meets the current ENERGY STAR specification, it could indicate that the
specification should be revised in other ways.

Partner of the Year Applications

	EPA uses information in the Partner of the Year Application to provide
public recognition to ENERGY STAR Partners that have initiated exemplary
activities to educate the public and their employees about energy
efficiency and ENERGY STAR

3	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

						

	The following sections verify that this information collection
satisfies OMB's nonduplication and consultation guidelines, and does not
duplicate another collection.

3.a	NONDUPLICATION

	The information to be obtained under this ICR has not been collected by
EPA or any other federal agency.  In addition, the requested information
is based on a particular point in time; therefore, information that is
not up-to-date is not sufficient.  CPPD will ensure that information
collected will not duplicate any ongoing recordkeeping or reporting
functions required for participation in any of CPPD’s programs.

3.b	PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB

	To comply with the Paperwork Reduction Act requirement that any agency
developing a non-rule-related ICR solicit public comments for a 60-day
period, EPA published a Federal Register notice on July 13, 2007 (72 FR
38573).  No comments were received on this notice. 

3.c	CONSULTATIONS

	In preparing the respondent burden estimates for this ICR, EPA
consulted with the following individuals:

NAME	ORGANIZATION	PHONE NUMBER	E-MAIL	PRODUCT 

Mark Sharp	Panasonic	202-912-3800 x 116	sharpm@us.panaosnic.com	Home
Electronics

Julie Humes	Lennox	972-497-5306	  HYPERLINK
"mailto:JULIE.HUMES@LennoxIntl.com"  JULIE.HUMES@LennoxIntl.com 	Heating
and cooling equipment

John McGill	Victory Refrigeration	856-673-5185	  HYPERLINK
"mailto:j.mcgill@victory-refrig.com"  j.mcgill@victory-refrig.com 
Commercial refrigeration

Chris Primous	Progress Lighting	864-678-1000	  HYPERLINK
"mailto:cprimous@progresslighting.com"  cprimous@progresslighting.com 
Residential light fixtures

Kevin Foley	Sika Sarnafil	800-856-9938	  HYPERLINK
"mailto:Foley.kevin@us.sika.com"  Foley.kevin@us.sika.com 	Roof products

Robert White	Dell	512-728-6461	  HYPERLINK
"mailto:Robert_White@dell.com"  Robert_White@dell.com 	Office equipment

Marty Marzinelli	Hewlett-Packard	208-396-3081	marty.marzinelli@hp.com
Office equipment

Mario Rufino	Canon	516-328-5610	  HYPERLINK
"mailto:mrufino@cusa.canon.com"  mrufino@cusa.canon.com 	Office
equipment

				

3.d	EFFECTS OF LESS FREQUENT COLLECTION

	The development of a Partnership Agreement is a one-time information
submittal; less frequent collection is not possible.  Submission of
information for each qualifying product is required as a one-time
information submittal; less frequent collection is not possible. 
However, at minimum annual updates, notifying EPA of any changes in
qualifying product information, are required in order to ensure that EPA
records reflect the most up to date information.  Qualifying product
information is posted on EPA’s Web site and is provided to the public
as requested; therefore annual updates are necessary to ensure that
accurate information is disseminated.

	EPA requires the submission of unit shipment data on an annual basis in
order to monitor and evaluate the program annually to determine whether
program adjustments are required to ensure continued program success and
benefits to Partners. 

	Roof product and residential light fixture Partners are required to
submit testing reports as they submit qualifying product information. 
Submission of test reports will be a one-time information request.  New
test reports will not be required as long as no changes have been made
to the product that would affect its qualification with the ENERGY STAR
criteria.  It was determined that this additional information must be
submitted by Partners of only these two product categories because of
industry concerns regarding the validity of qualifying product
information submitted.  Submission of testing reports is seen as a way
to verify the accuracy product information submitted by individual
manufacturing Partners.

	ENERGY STAR Partners may submit a Partner of the Year Award application
annually.  EPA requires this information to provide public recognition
to Partners.  However, Partners are not required to submit an award
application.

3.e	GENERAL GUIDELINES

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

3.f	CONFIDENTIALITY

	Participation in the ENERGY STAR Program is voluntary and may be
terminated by Partners or EPA at any time.  EPA does not expect that
organizations will deem any information collected under the program to
be confidential.

	Any information submitted to EPA for which a claim of confidentiality
is made will be safeguarded according to the Agency policies set forth
in Title 40, chapter 1, part 1, subpart B – Confidentiality of
Business Information (see 40 CFR part 2; 41 FR 36902, September 1, 1976;
amended by 43 FR 40000, September 8, 1978; 43 FR 42251, September 20,
1978; 44 FR 17674, March 23, 1979).

				

3.g	SENSITIVE QUESTIONS

	The information collections do not ask sensitive questions, such as
those pertaining to sexual attitudes or behavior or religious beliefs.

4	THE RESPONDENTS AND THE INFORMATION REQUESTED

4.a	RESPONDENTS AND SIC CODES

	Respondents for this information collection request include Partners in
ENERGY STAR.  Partners are product manufacturers. The following is a
list of Standard Industrial Classification (SIC) codes for industry
segments which are respondents to the information collections.

SIC	Industries

2679	Insulation, cellulose-mfpm-mfg

2952	Roof coatings (various)-mfg

3069	Roofing, single ply membrane: rubber-mfg

3211	Window glass, clear and colored-mfg

3259	Roofing tile, clay-mfg

3296	Insulation: rock wool, fiberglass, slag, and silica minerals-mfg 

3433	Boilers, low-pressure heating: steam or hot water-mfg

3433	Furnaces, domestic: steam or hot water-mfg

3444	Roofing, sheet metal-mfg

3546	Power-Driven Handtools

3575	Computer terminals-mfg

3577	Optical scanning devices

3577	Printers, computer-mfg/Document entry conversion devices/Graphic
displays

3577	Computer output to microfilm units, computer peripheral
equipment-mfg

3579	Duplicating machines

3579	Mailing machines-mfg

3581	Vending machines for merchandise

3585	Dehumidifiers, except portable: electric-mfg

3585	Air-conditioning and heating combination units-mfg

3585	Air-conditioning and heating combination units-mfg/Air-conditioning
condensers and condensing units-mfg/Air-conditioning units, complete:
domestic and industrial-mfg/Heat pumps-mfg (ASHPs)

3585	Heat pumps, electric-mfg

3585	Water coolers, electric-mfg

3589	Fryers/Food warming equipment/Cookers, steam

3634	Dehumidifiers, electric: portable-mfg

3634	Fans, household; electric, except attic fans-mfg

3634	Ventilating fans, electric: household-kitchen-mfg

3641	Light bulbs, electric: complete-mfg/Lamp bulbs and tubes, electric:
incandescent filament, fluorescent, and vapor-mfg/Fluorescent lamps,
electric-mfg

3645	Lighting fixtures, residential, electric-mfg

3651	Audio recorders and players: automotive and household-mfg

3651	Television receiving sets-mfg

3651	Television receiving sets - mfg/Video cassette
recorders/players-mfg

3661	Facsimile equipment-mfg

3661	Telephone answering machines-mfg/Telephone central office
equipment, dial and manual-mfg/Telephone sets, except cellular radio
telephone-mfg

3663	Cable television equipment-mfg

3663	Television closed-circuit equipment/Television
monitors-mfg/Television transmitting antennas and ground equipment-mfg

3679	Power supplies, static, and variable frequency

3822	Thermostats: air-conditioning, refrigeration, comfort heating,
appliance-mfg

3861	Cameras

3861	Photocopy machines-mfg

3993	Electrical signs

4222	Storage, frozen or refrigerated goods

4939	Utilities, combination of

5078	Refrigerators, commercial: reach-in and walk-in wholesale 

5211	Roofing material, dealers-retail 

5722	AC units, self contained-retail

5731	Antennas/TV sets/VCRs-retail

5734	Computer/Printers, etc.-retail



4.b	INFORMATION REQUESTED

	Information is requested via the ENERGY STAR Partnership Agreement,
Qualifying Product Information, Testing Report (required only for roof
product and residential light fixture Partners), Unit Shipment Data, and
Partner of the Year Application.  

	

Partnership Agreement (PA)



Data Item



Partner name

Product for which they are partnering with EPA (checklist)

Information on main contact person

Information on marketing/PR contact person

Signature of company official

	Recordkeeping Item

	

	There are no recordkeeping data items required pertaining to the
Partnership Agreement.



ii	Respondent Activity

Review the instructions of the PA

Complete and review information requested by the PA

Submit the PA

Qualifying Product Information (QPI)



i	Data Item



Preparer’s name

Company name

Product brand name and model number

Product energy consumption information

Other product specific information according to the requirements of the
ENERGY STAR product specification

Information about how the Partner is using the ENERGY STAR label – on
products, packaging, Internet site, etc.



	Recordkeeping Items

	There are no recordkeeping data items required pertaining to QPI.

	

ii	Respondent Activity



Review instructions regarding QPI

Complete and review QPI via On-line Product Submittal Tool (OPS) or hard
copy/electronic form depending upon product category

Submit QPI



Testing Report

i	Data Item



Product name and model number

Results of testing according to ENERGY STAR product specification using
in-house or Third Party testing facility



	Recordkeeping Items



There are no recordkeeping data items required pertaining to testing
reports.



ii	Respondent Activity



Review the testing guidelines found in the Partnership Agreement

Determine which products to test

Decide whether in-house capabilities exist or Third Party testing is
required

Perform testing in-house or via Third Party

Compile testing results into testing report and review

Submit testing report.



Unit Shipment Data

i	Data Item

	



Product brand name and model number

Number of ENERGY STAR qualified units shipped that year

Total U.S. shipments that year (requested but not required)



	Recordkeeping item

	There are no recordkeeping data items required pertaining to unit
shipment data.

ii	Respondent Activity



Review instructions regarding unit shipment data

Gather annual unit shipment data

Compile data by product and review

Submit unit shipment data form 



Partner of the Year Application

i	Data Item



Name of the organization

Information on the primary contact person

Information on the communications contact

Information on the award category

Information on the number of products labeled

Information on communication and outreach efforts

Information on other special endeavors



	Recordkeeping Item

	There are no recordkeeping data items required pertaining to Partner of
the Year award applications.

ii	Respondent Activity



Review the eligibility requirements and instructions on the application

Gather data

Complete and review the information and narrative descriptions required
on the application

Submit the application

Submit original examples of communication materials



5	INFORMATION COLLECTED: AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND
INFORMATION MANAGEMENT

5.a	AGENCY ACTIVITIES

	

	ENERGY STAR requires EPA to perform activities associated with the
Partnership Agreement, Qualifying Product Information, Testing Reports,
Unit Shipment Data, and Partner of the Year Applications.  All of the
following activities will be conducted by Headquarters staff in EPA’s
Climate Protection Partnerships Division, within the Office of
Atmospheric Programs.

Partnership Agreement (PA)

EPA must perform the following activities related to the PA:



Develop the PA

Customize a PA for each company

Disseminate the PA

Review the completed PA

Enter the information contained in the PA into the iSTAR database

Develop and send a Welcome Aboard Pack (WAP) to the Partner



Qualifying Product Information (QPI)

EPA must perform the following activities related to QPI:



Develop QPI to be submitted by Partners using OPS or hard
copy/electronic form 

Disseminate QPI to Partners via the ENERGY STAR Web site and the WAP

Review completed QPI submitted by Partner

Enter QPI into the iSTAR database

Compile all QPIs into a list per product type

Post updated list on ENERGY STAR Web site

Disseminate updated list as requested



Testing Report

EPA must perform the following activities related to testing reports
submitted by roof product and residential light fixture Partners:



Review testing report

File for future review, as necessary



Unit Shipment Data

EPA must perform the following activities related to unit shipment data:



Review unit shipment data submitted

Compile information into aggregate data per product category



Evaluate aggregate data to determine ENERGY STAR success and/or need for
program adjustment



Partner of the Year Application

EPA must perform the following activities related to Partner of the Year
applications:

Develop the award criteria

Disseminate the application via the ENERGY STAR Web site

Review the submitted awards applications

Send a letter of award or loss to applicant

5.b	COLLECTION METHODOLOGY AND MANAGEMENT

	In collecting and analyzing the information associated with this ICR,
EPA will use a telephone system, personal computers, the Internet, and
applicable database software.  EPA will ensure accuracy and completeness
of collected information by reviewing each submittal.  EPA will enter
the information obtained into a database and will aggregate data
obtained in order to make that information available to the public and
monitor the progress of program implementation.  

5.c	SMALL ENTITY FLEXIBILITY

	

	EPA expects that small entities will participate in ENERGY STAR product
labeling.  EPA has designed information requirements to minimize
respondent burden while obtaining sufficient and accurate information.  
In addition, the initial agreement to participate in the program is
voluntary.

5.d	COLLECTION SCHEDULE

	EPA collects initial information in the Partnership Agreement, which is
completed and submitted by every Partner participating in ENERGY STAR. 
Every manufacturing Partner is required to submit information on each of
their qualifying products.  Annual updates, notifying EPA of any changes
in qualifying product information, are required as well.  ENERGY STAR
Partners for residential light fixtures and roof products are required
to submit testing reports for each product determined to by qualified
with the ENERGY STAR criteria.  EPA also requires that manufacturing
Partners submit information on their unit shipments of ENERGY STAR
labeled products annually.  Partners interested in receiving recognition
for their efforts on ENERGY STAR are required to submit a Partner of the
Year Award application.     

6	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6.a	ESTIMATING RESPONDENT BURDEN

	EPA conducted consultations with ENERGY STAR Partners to estimate
respondent burden hours for the activities covered by this ICR.  Exhibit
1 presents the estimated annual respondent burden for information
collection activities associated with ENERGY STAR product labeling.  

6.b	ESTIMATING RESPONDENT COSTS

	Exhibit 1 presents the estimated annual respondent costs for
information collection activities associated with ENERGY STAR product
labeling.  The estimated annual respondent costs are discussed below.

Estimating Labor Costs

	The labor rates used to determine the estimated costs to respondents
are consistent with the hourly wage rates published by the Bureau of
Labor Statistics publications on employment and earnings.  Rates reflect
a graded scale and include the cost of overhead and fringe benefits
where appropriate.  EPA estimates an average respondent hourly labor
rate (hourly plus overhead) of $119.35 for legal staff, $101.67 for
managerial staff, $70.94 for technical staff, and $40.67 for clerical
staff.

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

	EPA estimates that ENERGY STAR Partners may incur capital and
operations and maintenance costs associated with specific activities. 
Respondents may incur capital costs in the average amount of $2.14
associated with completing and reviewing the information requested in
the Partnership Agreement.  

	Respondents will incur an average amount of approximately $128 for
various operations and maintenance costs to meet the information
requirements of ENERGY STAR.  These costs are for expenses such as
photocopying, printing, creating binders, use of paper, and using
express mailing services.

6.c	ESTIMATING AGENCY BURDEN AND COSTS

	EPA conducted consultations with their staff who work on ENERGY STAR
product labeling to obtain agency burden hour estimates for all
activities required by the Agency.  The hourly labor rates used to
determine the estimated costs to the Agency are consistent with hourly
labor rates published in the Federal Register and are based on the 2007
GS pay schedule available from the Office of Personnel Management.  EPA
estimates an average hourly labor cost of $71.34 for legal staff; $66.72
for managerial staff; $48.91 for technical staff; and $19.65 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 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.  EPA multiplied hourly rates by the
standard government overhead factor of 1.6.  

	EPA anticipates several instances of Agency O&M costs associated with
ENERGY STAR product labeling information collection activities.  To
disseminate Partnership Agreements and Welcome Aboard Packs once signed
Partnership Agreement are received from Partners, EPA anticipates a cost
of $2.07.  This corresponds to the cost to mail a standard 9.5" x 12"
manila envelope containing 30 pieces of paper via first class mail.  In
addition, EPA anticipates a cost of $0.41 to mail a letter of award or
loss to Partners who submit Partner of the Year applications.

	Exhibit 2 shows the aggregate annual Agency burden and costs for the
information collection activities associated with ENERGY STAR product
labeling activities.  The annual burden to the Agency is approximately
11,932 hours, at a cost of approximately $468,724.   The three-year,
bottom-line burden for the life of this ICR is therefore 35,796 hours
and $1,406,172.

 				

6.d	ESTIMATING THE RESPONDENT UNIVERSE AND TOTAL BURDEN AND COSTS

Respondent Universe

	The universe of each respondent activity varies depending upon the
specific activity.  The respondent universe for each information
collection activity associated with ENERGY STAR product labeling is
presented and explained separately below.	

Partnership Agreement

	One overarching Partnership Agreement has been developed by EPA for
ENERGY STAR product labeling.  It is expected that 292 new Partners will
join each year for the three years of this ICR.

Qualifying Product Information

	Thirty-three different product categories are covered by EPA under
ENERGY STAR.  Each product category has specific qualifying product
information that must be submitted by each Partner for at least one
qualifying product.  Qualifying product information is expected for
9,986 qualifying products each year for the three years of this ICR. 
The qualifying product list for each product category is updated by the
Agency once each month, for a total of 396 times annually (33 qualified
product lists multiplied by 12 months in a year).  Approximately twice
each month the Agency receives a request for qualifying product
information that cannot be fulfilled by the ENERGY STAR Web site, for a
total of 792 requests.

Testing Reports

	Testing reports are required to be submitted for qualifying products by
roof product and residential light fixture Partners only.  It is
anticipated that qualifying product information for 4,464 new roof and
residential light fixture products will be received by EPA each year for
the three years of this ICR.

Unit Shipment Data 

	Each year, ENERGY STAR Partners are required to submit unit shipment
data for their ENERGY STAR labeled products.  There will be an average
of 692 total Partners each year for the three-years of this ICR. 
Therefore, 692 reports of unit shipment data are expected each year for
the three years of this ICR.  Unit shipment data will be aggregated for
each of the 33 product categories covered by EPA under ENERGY STAR.

Partner of the Year Award Application

	One set of Partner of the Year award criteria are developed by the
Agency each year and posted on the ENERGY STAR web site.  An average of
17 Partner of the Year Award applications are expected each year for the
three years of this ICR.

Total Burden and Costs

	Exhibit 1 shows the aggregate annual respondent burden and costs for
the information collection activities associates with ENERGY STAR
product labeling.  Estimated respondent burden hours are presented on a
per respondent basis for the information collected under the Partnership
Agreement, unit shipment data, and Partner of the Year application, and
on a per qualifying product basis for qualifying product information and
testing reports.  The annual burden to the universe of respondent is
approximately 89,150 hours, at a cost of approximately $7,056,533.  The
three-year, bottom-line burden for the life of this ICR is therefore
267,450 hours and $21,169,599. 

6.e	BOTTOM LINE BURDEN HOURS AND COSTS

	Table 1 summarizes the total estimated annual burden hours and costs
for respondents and for the Agency.  The total cost for respondents is
$7,056,533 and the hourly burden is approximately 89,150 hours.  The
total cost for the Agency is $468,724 and the hourly burden is
approximately 11,932 hours.  Table 1 displays these combined estimates,
as well as the grand total of $7,525,257 and the hourly burden of
approximately 101,082 hours for all information collection activities
under ENERGY STAR product labeling. 

Table 1

Total Estimated Burden Hours and Costs for Respondents and EPA

	Burden Hours	Total Labor Costs/Year	Total Capital Costs/Year	Total O&M
Costs/Year	Total Cost

Respondents	89,150	$6,817,702	$625	$238,206	$7,056,533

Agency	11,932	$467,508	$0	$1,216	$468,724

TOTAL	101,082	$7,285,210	$625	$239,422	$7,525,257



6.f	REASONS FOR CHANGE IN BURDEN

	EPA estimates a total annual respondent burden in this ICR, 2078.02 of
89,150 hours.  This is an increase of approximately 18,483 hours from
the previously approved ICR, 2078.01

	

	Table 2 explains this 18,483-hour increase.  Specifically the table
presents the total annual hours estimate in ICR 2078.01 and ICR 2078.02
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).  For example, there was an
increase in testing report collections of approximately 44,052 hours,
all of which resulted from an adjustment.  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 bottom row of the table).

	

	The table shows that, of the 18,483-hour increase, all 18,483 hours
resulted from adjustments.  No hour changes resulted from program
changes.

	The table shows that all of the burden hour changes resulted from
EPA’s analysis of the number of respondents that would be
participating in the information collection.  For example, the number of
residential light fixtures and roof products that are being qualified as
ENERGY STAR is far greater now than it was three years ago when the
original ICR was completed, 4,464 now versus 654 three-years ago.  For
all other information collections, the number of burden hours actually
decreased.  In some cases, this is because there are fewer respondents
for each collection, in other cases it is because respondents are more
familiar with the information collections and can perform them in a more
streamlined manner. 

 

 6.g	BURDEN STATEMENT

	The estimated average annual respondent reporting and recordkeeping
burden for this collection of information is 89.33 hours.  The
respondent reporting burden for each information collection activity for
ENERGY STAR product labeling is presented separately below.

Partnership Agreement

	The reporting burden for information collection requirements associated
with completing the PA for each respondent is estimated to be 4.20
hours.  This estimate includes times for reviewing the instructions on
the PA, completing and reviewing the information requested by the PA,
and submitting the PA.

Qualifying Product Information 

	The reporting burden for information collection requirements associated
with completing the QPI for each qualifying product submitted by a
respondent is estimated to be 4.85 hours.  This estimate includes time
for reviewing instructions regarding the QPI, completing and reviewing
the QPI requested, and submitting the QPI via OPS or hard
copy/electronic form.

Testing Report

	The reporting burden for information collection requirements associated
with testing reports by roof product and residential light fixture
Partners for each qualifying product submitted by a respondent is
estimated to be 14.30 hours.  This estimate includes performing testing
in house or by a Third Party, assembling the data into a report format,
reviewing it and submitting it.

Unit Shipment Data

	The reporting burden for information collection requirements associated
with unit shipment data for each respondent is estimated to be 6.69
hours.  This estimate includes reviewing instructions regarding unit
shipment data, gathering unit shipment data compiling and reviewing unit
shipment data by product category, and submitting unit shipment data.

Partner of the Year Application

	The reporting burden for information collection requirements associated
with the Partner of the Year Application for each respondent is
estimated to be 59.29 hours.  This estimate includes reviewing the
eligibility requirements and instruction on the application, gathering
data and information for submission, completing the application,
reviewing the information and narrative description required, and
submitting the application to EPA.

	The estimated average annual respondent reporting and recordkeeping
burden for this collection of information is 89.33 hours.  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; adjust
the existing ways to comply with any previously applicable instructions;
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. 

 

U.S. Department of Labor. Standard Industrial Classification (SIC)
System Search. Accessed on May 11, 2007
http://www.osha.gov/pls/imis/sicsearch.html.

 U.S.Department of Labor, Bureau of Labor Statistics. Employment Cost
Index Historical Listing: Table 4. May 7, 2007.

 U.S. Department of Labor. BLS Series Report. Accessed on May 11, 2007
http://data.bls.gov/cgi-bin/srgate.

 U.S. Office of Personnel Management.  2007 General Schedule (GS)
Locality Pay Tables. Accessed on May 11, 2007
http://www.opm.gov/oca/07tables/indexGS.asp.

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Exhibit 1: Estimated Annual Respondent Burden and Cost

Information Collection Activity

Legal     

Manager   

Technical    

Clerical      

Respond 

Hours/ Year

Labor Costs 

per Year

Annual 

Capital 

Startup 

Costs

Annual 

O&M Costs

Number of 

Respond./ 

Activities

Total 

Respond. 

Hours/Year

Total Cost/Year

Hourly rate

 $  119.35 

 $  101.67 

 $     70.94 

 $  40.67 

Partnership Agreement (PA)

Review the instructions of the PA

0.75

0.63

0.25

0.13

1.75

175.88

$         

 

-

$       

 

1.65

$       

 

292

511.00

          

 

51,837.30

$         

 

Complete and review the information requested by the PA

0.50

0.63

0.47

0.13

1.72

159.01

$         

 

-

$       

 

0.74

$       

 

292

501.88

          

 

46,648.83

$         

 

Submit the PA

0.25

0.20

0.22

0.06

0.73

68.23

$           

 

2.14

$      

 

0.37

$       

 

292

213.53

          

 

20,657.72

$         

 

Subtotal

1.50

1.45

0.94

0.31

4.20

            

 

403.12

$         

 

Varies

Varies

Varies

1,226.40

       

 

119,143.84

$       

 

Qualifying Products Information (QPI) via On-line system or hard 

copy/electronic form depending upon product category

Review instructions regarding QPI

0

0.75

1.25

1.01

3.01

206.11

$         

 

-

$       

 

0.74

$       

 

33

99.41

            

 

6,826.00

$           

 

Complete and review the QPI requested

0

0.45

0.81

0.19

1.45

111.02

$         

 

-

$       

 

3.71

$       

 

9,986

14,479.70

     

 

1,145,677.55

$    

 

Submit the QPI

0

0.14

0.06

0.19

0.39

26.04

$           

 

-

$       

 

0.37

$       

 

9,986

3,869.58

       

 

263,732.76

$       

 

Subtotal

-

         

 

1.34

2.13

1.39

4.85

            

 

343.16

$         

 

Varies

Varies

Varies

18,448.69

     

 

1,416,236.31

$    

 

Testing Report (as required)

Perform testing either in house or through third party

0

2.5

10

0.5

13

983.91

$         

 

-

$       

 

35.64

$     

 

4464

58,032.00

     

 

4,551,271.20

$    

 

Assemble testing data into report format and review

0

0.5

0.5

0

1

86.31

$           

 

-

$       

 

1.70

$       

 

4464

4,464.00

       

 

392,841.57

$       

 

Submit testing report

0

0.05

0.25

0

0.3

22.82

$           

 

-

$       

 

0.85

$       

 

4464

1,339.20

       

 

105,668.94

$       

 

Subtotal

0

3.05

10.75

0.5

14.30

          

 

1,093.03

$      

 

Varies

Varies

Varies

63,835.20

     

 

5,049,781.70

$    

 

Unit Shipment Data (USD) of ENERGY STAR Products

Review instructions regarding USD

0.13

0.97

0.38

0.06

1.53

142.56

$         

 

-

$       

 

0.41

$       

 

692

1059.63

98,934.16

$         

 

Gather unit shipment data

0

1.50

2.43

0.29

4.21

            

 

351.33

$         

 

-

$       

 

6.60

$       

 

692

2,916.29

       

 

247,685.21

$       

 

Compile and review USD by ENERGY STAR product category

0.25

        

 

0.89

0.43

0.43

2.00

            

 

168.45

$         

 

-

$       

 

3.30

$       

 

692

1,384.00

       

 

118,849.02

$       

 

Submit data 

0

0.34

0.11

0.04

0.48

            

 

43.19

$           

 

-

$       

 

0.41

$       

 

692

331.17

          

 

30,169.67

$         

 

Subtotal

0.38

2.73

2.96

0.75

6.69

            

 

562.96

$         

 

Varies

Varies

Varies

4,631.46

       

 

396,703.90

$       

 

Partner of the Year Application

Review the eligibility requirements and instructions on application

0.13

2.6

1.13

2.21

6.04

446.22

$         

 

-

$       

 

0.85

$       

 

17

102.61

7,600.14

$           

 

Gather data

0.25

        

 

2.6

10.88

9.57

23.27

1,452.02

$      

 

-

$       

 

33.94

$     

 

17

395.55

25,261.32

$         

 

Complete and review the information and narrative descriptions required

1.000

8.3

8.38

2.57

20.23

1,660.46

$      

 

-

$       

 

26.40

$     

 

17

343.95

28,676.64

$         

 

Submit the application

0

3.6

0.50

1.18

5.25

446.51

$         

 

-

$       

 

3.28

$       

 

17

89.25

7,646.45

$           

 

Submit original examples of communications materials

0

1.4

1.50

1.57

4.50

315.56

$         

 

-

$       

 

6.97

$       

 

17

76.50

5,482.99

$           

 

Subtotal

1.38

18.43

22.38

17.11

59.29

          

 

4,320.77

$      

 

Varies

Varies

Varies

1007.86

74,667.53

$         

 

TOTAL

3.25

26.99

39.15

20.06

89.33

          

 

6,723.04

$      

 

Varies

Varies

Varies

89,149.60

     

 

7,056,533.29

$    

 

Hours and Costs Per Respondent/Qualifying Product

Total Hours and Costs

Table 2 Comparison of Total Annual Hours Under ICR 2078.01 and ICR
2078.02

Program 

Change

Adjustment

Total

Partnership 

Agreement

1,269.68

        

 

1,226.40

        

 

0

(43.28)

         

 

(43.28)

          

 

EPA adjusted the number of 

respondents based on improved and 

updated data and analysis.  The burden 

estimates in ICR 2078.02 reflect EPA's 

program experience gained over the past 

three years, as well respondents' 

experience.

Qualifying 

Product 

Information

31,930.00

      

 

18,448.69

      

 

0

(13,481.31)

  

 

(13,481.31)

   

 

EPA adjusted the number of 

respondents based on improved and 

updated data and analysis.  The burden 

estimates in ICR 2078.02 reflect EPA's 

program experience gained over the past 

three years, as well respondents' 

experience.

Testing Reports

19,783.50

      

 

63,835.20

      

 

0

44,051.70

   

 

44,051.70

     

 

EPA adjusted the number of 

respondents based on improved and 

updated data and analysis.  The burden 

estimates in ICR 2078.02 reflect EPA's 

program experience gained over the past 

three years, as well respondents' 

experience.  The number also reflects 

that many more respondents have 

needed to fulfill this reporting 

requirement than was estimated under 

ICR 2078.01

Unit Shipment 

Data

16,573.50

      

 

4,631.46

        

 

0

(11,942.04)

  

 

(11,942.04)

   

 

EPA adjusted the number of 

respondents based on improved and 

updated data and analysis.  The burden 

estimates in ICR 2078.02 reflect EPA's 

program experience gained over the past 

three years, as well respondents' 

experience.

Partner of the 

Year

1,110.30

        

 

1,007.86

        

 

0

(102.44)

       

 

(102.44)

        

 

EPA adjusted the number of 

respondents based on improved and 

updated data and analysis.  The burden 

estimates in ICR 2078.02 reflect EPA's 

program experience gained over the past 

three years, as well respondents' 

experience.

Total

70,666.98

      

 

89,149.61

    

 

0

18,482.63

   

 

18,482.63

     

 

(5) Description of Program Change 

and/or Adjustment

(1) Information 

Collections

(4) Difference in Hour Burden Between 

ICR 2078.01 and 2078.02

(2) Annual 

Hour Burden 

in ICR 

2078.01

(3) Annual 

Hour Burden 

in ICR 

2078.02

