                                       
                                       
                                       
                                       
                                       
                                       
                           SUPPORTING STATEMENT FOR 
               EPA INFORMATION COLLECTION REQUEST NUMBER 2547.01
         EPA'S VOLUNTARY NATURAL GAS STAR METHANE CHALLENGE PROGRAM
                                       
                                       
                                       
                                       
                                       
	TABLE OF CONTENTS


      1.	IDENTIFICATION OF THE INFORMATION COLLECTION	  3
            1(a)	TITLE AND NUMBER OF THE INFORMATION COLLECTION	3
      1(b)	CHARACTERIZATION OF THE INFORMATION COLLECTION	  3

      2.	NEED FOR AND USE OF THE COLLECTION	 4
            2(a)	NEED AND AUTHORITY FOR THE COLLECTION	4
            2(b)	PRACTICAL UTILITY/USERS OF THE DATA	 5

      3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA	 5
            3(a)	NONDUPLICATION	 5
            3(b)	PUBLIC NOTICE	 6
            3(c)	CONSULTATIONS	 6
            3(d)	EFFECTS OF LESS FREQUENT COLLECTION	 7
            3(e)	GENERAL GUIDELINES	 7
            3(f)	CONFIDENTIALITY	 8
            3(g)	SENSITIVE QUESTIONS	8 
                                                                               
      4.	THE RESPONDENTS AND THE INFORMATION REQUESTED	 8
            4(a)	RESPONDENTS/NAICS CODES	 8
            4(b)	INFORMATION REQUESTED	 8
      
      5.	THE INFORMATION COLLECTED--AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT	 13
            5(a)	AGENCY ACTIVITIES	13
            5(b)	COLLECTION METHODOLOGY AND MANAGEMENT	 14
            5(c)	SMALL ENTITY FLEXIBILITY	 14
            5(d)	COLLECTION SCHEDULE	15

      6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION	 15
            6(a)	ESTIMATING RESPONDENT BURDEN	 15
            6(b)	ESTIMATING RESPONDENT COSTS	 15
      6(c)	ESTIMATING AGENCY BURDEN AND COST	 17
            6(d)	ESTIMATING THE RESPONDENT UNIVERSE AND TOTAL BURDEN	17
            6(e)	BOTTOM LINE BURDEN HOURS AND COSTS	 29
      6(f)	REASONS FOR CHANGE IN BURDEN	 30
            6(g)	BURDEN STATEMENT	 30
1.	IDENTIFICATION OF THE INFORMATION COLLECTION

      1(a)	Title of the Information Collection

      EPA's Voluntary Natural Gas STAR Methane Challenge Program," ICR number 2547.01, OMB Control No. 2060-NEW.

      1(b)	Short Characterization/Abstract

      Methane is the pri - mary component of natural gas and a potent greenhouse gas, and the oil and natural gas industry is the largest source of methane emissions in the U.S., according to the Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2016. The Natural Gas STAR Methane Challenge (Methane Challenge) Program is a new voluntary program sponsored by the U.S. Environmental Protection Agency (EPA) that expands the current Natural Gas STAR Program to provide an innovative voluntary mechanism through which oil and natural gas companies can make ambitious commitments to reduce methane emissions. The Program's ongoing commitment to address methane emissions was developed through extensive stakeholder engagement and support from companies and trade organizations in the oil and gas industry. The Program works with oil and natural gas companies in the production, gathering and boosting, processing, transmission and underground storage, and distribution segments to make specific commitments to implement either best management practices or technologies company-wide to reduce methane emissions. Companies participating in the Methane Challenge would have the opportunity to choose from two options to reduce methane emissions from their operations:  the Best Management Practice (BMP) Commitment Option and the ONE Future Emissions Intensity (ONE Future) Commitment Option. By signing up to either or both of these commitments, companies would become recognized partners in the Methane Challenge Program. This program has the capability to comprehensively and transparently reduce emissions and realize significant voluntary reductions in a quick, flexible, cost-effective way.
      
      Companies become partners by completing and submitting a Partnership Agreement that outlines responsibilities of the Methane Challenge partner company and EPA. By signing the Partnership Agreement, BMP Commitment partners commit to select at least one methane emissions source, specify an implementation start date, and document a target achievement year not to exceed five [5] years from the commitment start date. ONE Future Commitment partners commit to a segment-specific intensity target by a certain year. Collectively, the ONE Future partners commit to a goal of reducing methane emissions across the natural gas value chain to 1% or less by 2025. 
      
      Methane Challenge Partners also agree to submit an Implementation Plan within six [6] months of signing the Partnership Agreement and to report annually on their methane emissions, voluntary actions, and resulting emission reductions. Transparency through annual reporting is a key component of the Program, and a requirement for participation. 
      
      Program Partners will report annually to the EPA through the electronic Greenhouse Gas Reporting Tool (e-GGRT) system or other electronic submission. The EPA will leverage the data reported to the Greenhouse Gas Reporting Program (GHGRP) through the Petroleum and Natural Gas Systems source category (Subpart W) to track Program activities. Partners will also report supplemental data to comprehensively track progress towards their source-specific commitments, including data that enables Partners to highlight emission reductions achieved through voluntary action. Data elements to be reported are provided in detailed Supplementary Technical Information documents. Program reporting will be due annually each spring (on a date to be specified by the EPA), following their first full calendar year of participation in the Program. The EPA will compile the data collected and publicly release (on the EPA website) all non-confidential data submitted either to the Methane Challenge Program or through the GHGRP to track the progress of individual Partner companies in meeting their Program commitments. 
      
      The voluntary agreement can be terminated by the Methane Challenge Partner or EPA with no notice or penalties and no further obligation.	
									
2.	NEED FOR AND USE OF THE COLLECTION

      2(a)	Need/Authority for the Collection

      EPA has developed this ICR to obtain authorization to collect voluntarily-submitted information from Methane Challenge Program partners. EPA needs to collect initial information as outlined in the Partnership Agreement. The Partnership Agreement provides general information on the Methane Challenge partner company, their commitment(s), and includes relevant points of contact. 
      
      The Implementation Plan and annual reporting are necessary to understand a partner's plans for implementing the program, evaluate their progress in achieving their commitments, and assess overall Program results. The information provided in the Implementation Plan and submitted through the annual reporting process also allows EPA to track partner progress in meeting commitments and to provide technical and other assistance to partners. 
      
      2(b)	Practical Utility/Users of the Data

      EPA will use the information provided in the Partnership Agreement's to populate its contacts database/tracking system. This information also serves as a source of specific commitment information, as well as general information and a mailing list. 
      
      EPA will use the information submitted in the Implementation Plans and through annual reports to document progress on partner company commitments and methane emission reductions achieved. EPA will evaluate annual data submissions from partners, post non-confidential data on the EPA website, and on an annual basis will aggregate these data and provide updated accomplishment information on its website. 
      
      The two hallmarks of the Methane Challenge Program - ambitious commitments and transparency  -  will facilitate information sharing about accomplishments and progress made. Thus, the program can serve as a catalyst for broad industry adoption of best practices to reduce emissions.
      
      The information collected through the Methane Challenge Program will help companies reduce methane emissions, thereby improving the efficiency of their operations and delivering more natural gas to markets. 

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

      3(a)	Nonduplication

      EPA finalized Subpart W of the Greenhouse Gas Reporting Program (GHGRP; a regulatory program) that requires companies to begin collecting methane emissions data as of January 1, 2011. The first year of mandatory greenhouse gas data collection for the oil and natural gas industry was 2011. The GHGRP collects emissions and activity data for facilities that emit 25,000 metric tons or more of CO2 equivalent per year. The voluntary Methane Challenge Program was designed to leverage the data already submitted to EPA, and will complement, but not duplicate GHGRP data. Select data elements submitted to GHGRP and used in Methane Challenge reporting will be drawn from that system automatically. Information collected through the Methane Challenge Program that is not already collected by GHGRP will be focused on methane emission reductions achieved through voluntary actions taken by the companies, in order to track their Methane Challenge commitments (data elements focused on voluntary actions and the associated estimated emissions reductions, will be collected). These elements are not collected by the GHGRP, since the GHGRP only focuses on annual emissions from specific emission sources (and not on reductions from actions taken). Additionally, the Methane Challenge Program will include oil/gas facilities of partner companies that are not required to report to GHGRP (i.e. "below threshold" facilities; those facilities that emit less than 25,000 tons CO2-equivalent per year). The GHGRP has increased EPA's understanding of the location and magnitude of significant methane emissions sources in the petroleum and natural gas industry, and in large part informed the Methane Challenge Program framework. The GHGRP rule complements, but does not replace the information reported to EPA under this Methane Challenge Program ICR. 
      
      Likewise, the Methane Challenge Program differs significantly from the longstanding Natural Gas STAR Program, which was established in 1993. The Methane Challenge Program expands on Natural Gas STAR by creating a structure through which companies can make specific, ambitious voluntary commitments and annually submit data and information through Subpart W of the GHGRP (as well as some supplemental voluntary reporting) that will be made publicly available on a company-specific basis to transparently track progress. This is a significant departure from the original Natural Gas STAR program, in which partner companies make a general commitment, participate at a range of levels (e.g., company-wide to facility or regional level), and only report information on emission reduction actions. In this way, the Methane Challenge Program provides a platform for companies that truly want to excel and differentiate themselves. 

      3(b)       Public Notice Required Prior to ICR Submission to OMB
      
      In compliance with the Paperwork Reduction Act of 1995, EPA solicited public comments on the ICR through an announcement in the Federal Register on December 14, 2016 (81 FR 90355). No comments were received.
      
      3(c)	Consultations

      EPA conducted a total of three consultations with representatives of the BMP Commitment Option from Xcel Energy, Washington Gas, and DTE, and one representative of the ONE Future Commitment Option from National Grid. 
      
      Respondent burden estimates for the annual reporting process for both commitment options were developed using feedback received from respondent consultations. EPA received no objections from these company representatives to this information request. Contact information for the companies consulted are as follows: 

      Steve Martz
      Manager, Gas Capacity Planning
      Xcel Energy
      Denver, CO 80202
      Stephen.Martz@xcelenergy.com
      303-294-2676
	
	Hillery Kelly
	Sr. Environmental Specialist
	Washington Gas
	Springfield, VA 22151
	hkelly@washgas.com
	703-750-5846
      
      Darrell Grassmyer
      Environmental Management and Resources Operations Manager
      DTE Energy
      Detroit, MI 48226
      grassmyerd@dteenergy.com
      313-235-6396
      
	Donald Chahbazpour
	Director, Climate Change Compliance
	Brooklyn, NY 11201
	Donald.Chahbazpour@nationalgrid.com
	929-324-4848
        
      3(d)	Effects of Less Frequent Collection

      The completion and submittal of the Partnership Agreement will be conducted once the partner joins the program, and may be updated again if a partner wishes to revise their commitments. Partners agree to also prepare and submit an Implementation Plan, to be revised upon achievement of a commitment or due to changes in operations. Partners agree to report annually while participating in the Program. The transparency of progress towards achieving commitments made by partner companies provides a benefit to both the company and the public. EPA believes that a reduction in the frequency of the information collection and submission of annual reporting data would impede efforts by EPA to evaluate results of the Program.
                        
      3(e)	General Guidelines
            
      None of these reporting or record keeping requirements violate any of the regulations established by OMB in 5 CFR 1320.5.

      3(f)	Confidentiality

      Participation in the Natural Gas STAR Methane Challenge Program is voluntary. It is clearly stated in Methane Challenge Program documents, such as the Partnership Agreement, that partners are to only report non-confidential business information supplementary data relevant to achieving their Methane Challenge commitments in annual reporting. Some information collected in the Partnership Agreement and Implementation Plan forms may be considered Personally Identifiable Information (PII).  Per the Privacy Act, and as stated in the Methane Challenge Program Framework document, EPA will not share such information publicly. EPA will publicly release only non-confidential data on the EPA website that is submitted either through the Methane Challenge Program or through the GHGRP.

      3(g)	Sensitive Questions
      
      No sensitive questions are asked in the Partnership Agreement, Implementation Plan, or in the annual reporting process.

4. 	THE RESPONDENTS AND THE INFORMATION REQUESTED

      4(a)	Respondents/NAICS Codes

      The following is a list of North American Industry Classification System (NAICS) Codes and associated industries that may be affected by information collection requirements covered under this ICR:

      21111		Oil and Gas Extraction
      221210	Natural Gas Distribution
      486210	Pipeline Transportation of Natural Gas

      4(b)	Information Requested

      EPA's Methane Challenge Program specifies guidelines for partners. The following identifies the partnership forms contained in this ICR. A detailed justification for each reporting component immediately follows. Burden estimates are summarized in Exhibits 1 through 4.
      
	Partnership Agreement

      Methane Challenge Program partners agree to sign and submit to EPA a Partnership Agreement that describes the terms of participation in the Program. This Partnership Agreement identifies company commitments and points of contact and initiates the partnership in the Program. The Partnership Agreement forms covered under this ICR include:
      
          Methane Challenge Program Partnership Agreement - Best Management Practice Commitment; and
          Methane Challenge Program Partnership Agreement - ONE Future Commitment.
      
      (i)	Data items:

      Partners agree to provide the following information in the Partnership Agreement:

 The name, title, address, telephone and facsimile number, and email address of a Methane Challenge Program Implementation Manager;
 BMP Commitment Partners: The segment(s), source(s), start date, achievement year, and any additional applicable commitment information specific to the emission source; 
 ONE Future Commitment Partners: The segment(s), segment-specific target intensity, and target year; and
 The name and signature of the partners' Authorized Company Representative.

      (ii)	Respondent activities:

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

 Download (from the Methane Challenge Program website) and review the Partnership Agreement; 
 Gather requested information and complete the Partnership Agreement; and
 Sign the Partnership Agreement and submit it to EPA.
         
      Implementation Plan

      Partners agree to complete and submit a Methane Challenge Program Implementation Plan within six months of signing the Partnership Agreement. The Implementation Plan facilitates development of a strategy for a partner company's planned participation, such as anticipated rate of progress, key milestones, and context for their Implementation Plans (e.g., referencing work to be done during the next planned shutdown of a facility). Partners can also include information on historic actions to reduce methane emissions that informs their Methane Challenge commitments. An Implementation Plan is a living document that can change over time as each partner's goals and commitments evolve, and can be updated at any time by contacting an EPA Methane Challenge program manager at GasSTAR@epa.gov. EPA will accept requests from partners for extension on the six-month timeline for submitting Implementation Plans. The Implementation Plan forms covered under this ICR include:
      
          Methane Challenge Program Implementation Plan Template  -  BMP Commitment; and
          Methane Challenge Program Implementation Plan Template  -  ONE Future Commitment.
      
      (i)	Data items:

      The Implementation Plan form requests the following information:

 General company information (e.g., company name and contact, title, mail and e-mail addresses, telephone and facsimile numbers, etc.);
 Commitment(s) and projected timeframe for meeting commitments, as specified in the Partnership Agreement;
 Milestones and associated timeframes;
 Plans (if any) for future expansion of Methane Challenge commitments; and,
 Any other relevant information to provide context for the Partner's participation (e.g., background on progress the Partner company has already made on methane mitigation, including past actions and results on reducing emissions from target sources).  

      (ii)	Respondent activities:

	Partners agree to conduct the following activities in preparing the Implementation Plan:

 Review the instructions;
 Gather the requested information and develop the Implementation Plan;
 Complete the form;
 Submit the plan to EPA; and
 Update the plan as goals and commitments change over time. The Plan is revised or updated by submitting a new form to EPA. 

	Annual Reporting

      Annual reporting is a key element for partners in the Methane Challenge Program. After one full calendar year of participation in the Program, partners agree to submit a specific set of data documenting the previous year's methane emissions, activity data, and reduction activities. The report documents voluntary (non-regulatory driven) methane emission reduction activities that partner companies have implemented in the previous year. The annual reporting forms covered under this ICR include:
      
      BMP Commitment 
          Best Management Practice Commitment Reporting Forms.
            
      ONE Future Commitment
 ONE Future Commitment Option Reporting Forms (under development) will follow the requirements set forth in the Supplemental Technical Information for ONE Future Commitment Option (available on the Methane Challenge Program website). 

      (i)	Data items:

      The annual reporting forms request the following information:

 General company and facility information (e.g., company name, facility name and ID number, reporting year, etc.);
 Specific data elements for the applicable company commitment, as listed in the Supplementary Technical Information documents and/or on each reporting form; and
 annual reports will also provide an opportunity for reporting optional, qualitative information to provide context for commitment progress each year.

      (ii)	Respondent activities:

      Partners agree to conduct the following activities in preparing the annual report:

 Review the instructions;
 Gather the requested information for the reporting form(s);
 Complete the reporting form(s); and
 Submit the reporting form(s) to EPA electronically.
         
      Historical Actions Fact Sheet

      Methane Challenge partners are given an opportunity to submit a Historical Actions Fact Sheet, which provides information on historical methane reduction actions taken prior to joining Methane Challenge. A two-page fact sheet template is made available to partner companies and allows entry of up to five key methane mitigation activities, including text, photos, and graphics. This document is not a core element of the Methane Challenge Program partnership. The fact sheet covered under this ICR is:
      
 Historical Actions Fact Sheet Template.

      (i)	 Data items:

      Partners that choose to submit Historical Actions Fact Sheets may provide descriptions of up to five methane mitigation activities, which may include background information on actions taken, a timeframe and any significant outcomes of actions, relevant technologies and/or practices employed that resulted in reduced emissions, methane emission reductions achieved, links to more information, etc. There is also a section on the form dedicated to provide relevant company-specific background and contextual information (e.g. general company information, overview of historical activities, overarching corporate policies, links to more information on company website, etc.).

      (ii) 	Respondent activities (if partner chooses to submit this document):
      
 Review the instructions;
 Complete the Historical Actions Fact Sheet; and
 Submit the document to EPA via email.

	Other Activities
      	
      	During participation in the Program, partners are requested to notify EPA program managers via the GasSTAR@epa.gov email address within two weeks if there is a change to the Methane Challenge Program Implementation Manager responsibility.

      (i)	 Data items:

      Partners with changes to the Methane Challenge Program Implementation Manager are requested to provide EPA with the name of the new contact and relevant contact information.

      (ii) 	Respondent activities:
      
      Notify EPA within two weeks of any change in Implementation Manager responsibility.	

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

      5(a)	Agency Activities

      The Methane Challenge Program performs various activities after a partner submits a Partnership Agreement, Implementation Plan, or annual report. 
      
      Partnership Agreement
      
      EPA performs the following activities upon receipt of a Partnership Agreement:
      
 Review the Partnership Agreement to ensure completeness and accuracy, and conduct follow-up, if necessary;
       Countersign the Partnership Agreement;
       Develop a cover letter and welcome packet with relevant program information;
       Send cover letter, countersigned Partnership Agreement and welcome packet to partner;
       File electronic copy of cover letters and Partnership Agreement's; and
       Enter Partnership Agreement information into tracking database.
      
      Implementation Plan
      
      EPA performs the following activities upon receipt of an Implementation Plan:
      
 Review the plan to ensure completeness and accuracy, and conduct follow-up, if necessary;
       File electronic copy of the plan; and
       Enter information into a tracking database.
      
      Annual Report
      
      EPA performs the following activities upon receipt of an Annual Report:
      
 Review the report to ensure completeness and accuracy, and conduct follow-up, if necessary;
       File electronic copy of the report; and
 Publish all non-Confidential Business Information (CBI) data on the EPA website.
      
      Historical Actions Fact Sheet
      
      EPA performs the following activities upon receipt of a Historical Actions Fact Sheet:
      
 Review the document and follow up, if necessary;
 File electronic copy of the fact sheet; and 
 Publish the document on EPA website.
      
      Additional Activities
      
      EPA performs the following activities upon receipt of updated Implementation Manager information: 
 Enter information into a tracking database.

      5(b)	Collection Methodology and Management
      
      In collecting and analyzing the information associated with this ICR, EPA uses typical office equipment such as telephones, computers, and database and word processing software systems.
        
      For the collection of Program information, the Methane Challenge Program has developed various templates and tools to assist partners. The Methane Challenge Program Partnership Agreement, Historical Actions Fact Sheet, Implementation Plan, and reporting forms are available on the Program website in PDF, PowerPoint, MS Word, and MS Excel (for the reporting forms) formats. Partners can submit completed reporting forms to EPA electronically. 
      
      EPA ensures the accuracy and completeness of collected information by reviewing each submission. EPA uses the information obtained from the Partnership Agreements, Implementation Plans, and annual reports to track the progress of partners in their commitments and in reducing methane emissions.

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

      5(d)	Collection Schedule

      EPA collects initial partner information in the Partnership Agreement, which is completed and submitted by each partner upon their decision to participate in the Program. The Implementation Plan is submitted by partners within six months of signing the Partnership Agreement. Each year, EPA collects information in the annual reporting forms to monitor partner progress in achieving their commitments. EPA may also collect other Program information as the information is submitted, such as notification of a change in Implementation Manager, changes to a partner's operating circumstances (change in ownership, assets, etc.), or an optional Historical Actions Fact Sheet.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

      6(a)	Estimating Respondent Burden

      Exhibits 1 and 3 present the estimated annual respondent burden for information collection activities associated with this ICR for the Methane Challenge Program BMP and ONE Future Commitments, respectively. Table 1 below presents the estimated annual burden for a single partner, depending on which year of participation they are in (i.e., if it is their first year in the program, or a subsequent year).
      
              TABLE 1. Average Methane Challenge Burden for a Partner, 
                              by Year of Participation

                      Partner Average Annual Burden Hours

First Year
Subsequent Years
BMP Partner
51
 64 
ONE Future Partner
51
125
      
      
      6(b)	Estimating Respondent Costs
      
      Exhibits 1 and 3 present the estimated annual respondent cost for information collection activities associated with this ICR for the Methane Challenge Program BMP and ONE Future Commitments, respectively. 
      
      Table 2 below presents the estimated annual cost for a single partner, depending on which year of participation they are in (i.e., if it is their first year in the program, or a subsequent year).
                                          
               TABLE 2. Average Methane Challenge Cost for a Partner, 
                              by Year of Participation

                          Partner Average Annual Cost

First Year
Subsequent Years
BMP Partner
 $ 4,775 
 $ 5,918 
ONE Future Partner
 $ 4,775 
 $11,314 
      
      (i) Estimating Labor Costs
      
      EPA estimates an average hourly labor cost (labor plus overhead) of $113.81 for legal staff, $109.06 for managerial staff, $84.88 for technical staff, and $46.38 for clerical staff. The most recently available average national hourly wages were obtained from the Bureau of Labor and Statistics. Legal Services industry-specific wage estimates were used for legal staff and Natural Gas Distribution industry-specific wage estimates were used for managerial, technical, and clerical staff. A standard overhead factor of 60% of the hourly wage was added to the hourly wages to determine the final average hourly labor cost used in the burden estimate calculations.
      
      (ii) Estimating Capital and Operations and Maintenance Costs
      
      EPA consulted with members of the oil and gas industry and believes that the capital or operations and maintenance costs of this Program are zero. All partners will use the e-GRRT online reporting system to submit Annual Reports. Also, all partners submit Partnership Agreements, Historical Action Fact Sheets, and Implementation Plans via e-mail as scanned PDFs or other electronic format.
      
      (iii) Capital/Start-up vs. Operating and Maintenance (O&M) Costs
      
      There are no capital/start-up costs or O&M costs associated with this information collection.
      
      (iv) Annualizing Capital Costs
      
      There are no capital costs associated with this information collection.

      6(c)	Estimating Agency Burden and Costs

      Exhibit 2 and 4 presents the estimated Agency burden hours and costs for the information collection activities associated with this ICR for the Methane Challenge Program BMP and ONE Future Commitment options, respectively. EPA estimates an average hourly labor cost (labor plus overhead) of $103.34 for legal staff, $96.64 for managerial staff, $70.85 for technical staff, and $28.45 for clerical staff. To derive these estimates, EPA used the "Hourly Rates by Grade and Step 2018" from the Department of Personnel Management. For purposes of this ICR, EPA assigned staff the following government service levels:
      
       Legal Staff				GS-15, Step 1
       Managerial Staff		GS-14, Step 4
       Technical Staff			GS-12, Step 5
       Clerical Staff			GS-05, Step 1
      
      To derive the loaded hourly estimates, EPA multiplied hourly rates by the standard government overhead factor of 1.6.
      
      6(d)       Estimating the Respondent Universe and Total Burden and Costs

      BMP Commitment 
      As of 2017, there were 52 BMP Commitment option partners nationally; the majority of these partners are distribution companies. EPA anticipates that an average of four new partners will commit to this option annually. 
      
      We assume the following number of new BMP partners joining the program in the next 3 years:
 Year 1: 52
 Year 2: 4
 Year 3: 4
         
      This averages out to 20 new BMP partners each year over the 3-year period of the ICR. New partners complete Partnership Agreements, Implementation Plans, and optional Historical Action Fact Sheets in their first year in the program. EPA thus assumes an average of 20 responses for these components in the average annual cost and burden estimates in Exhibit 1.

      ONE Future Commitment
      As of 2017, there were four ONE Future Commitment option partners nationally. EPA anticipates that one new partner will join in 2018 and 2019. Accordingly, EPA anticipates that an average of one new partner will commit to this option annually, moving forward. 
      
      We assume the following number of new ONE Future partners joining the program in the next 3 years:
 Year 1: 4
 Year 2: 1
 Year 3: 1
      
      This averages out to two new ONE Future partners each year over the 3-year period of the ICR. New partners complete Partnership Agreements, Implementation Plans, and optional Historical Action Fact Sheets in their first year in the program. EPA thus assumes an average of two responses for these components in the average annual cost and burden estimates in Exhibit 3.

      Partnership Agreement
      
      Each prospective Methane Challenge partner agrees to complete and submit a Partnership Agreement (Partnership Agreement) to join the Program. The expected number of partners that will join Methane Challenge each year and an average per year is shown in Table 1. 
      
      BMP Commitment 
      Over the course of this ICR, EPA expects that 60 (an average of 20 per year) new partners will complete and submit a Partnership Agreement for the BMP Commitment. 
      
      ONE Future Commitment
      Over the course of this ICR, EPA expects that six (an average of two per year) new partners will complete and submit a Partnership Agreement for the ONE Future Commitment. 
      
      Historical Actions Fact Sheet
      
      All new partners are given the option to complete and submit a Historical Actions Fact Sheet. 
      
      BMP Commitment 
      Over the course of this ICR, EPA estimates that 24 (an average of eight per year) BMP Commitment partners might submit a Historical Actions Fact Sheet. 
      
      ONE Future Commitment
      Over the course of this ICR, EPA estimates that six (an average of two per year) ONE Future Commitment partners might submit a Historical Actions Fact Sheet. 
      
      Implementation Plan
      
      All new partners agree to complete and submit an Implementation Plan within six months of signing and submitting the Partnership Agreement. 
      
      BMP Commitment 
      Over the course of this ICR, EPA estimates that 60 (an average of 20 per year) BMP Commitment partners will submit an Implementation Plan. Further, over the course of this ICR, EPA estimates that 30 (an average of 10 per year) BMP partners might update an Implementation Plan. 
      
      
      ONE Future Commitment
      Over the course of this ICR, EPA estimates that six (an average of two per year) ONE Future Commitment partners will submit an Implementation Plan. Further, over the course of this ICR, EPA estimates that three (an average of one per year) ONE Future Commitment partners might update an Implementation Plan. 

      Annual Report
      
      All partners agree to compile and submit data after the first full (calendar) year of joining the Program, and annually in the subsequent years of participation. 
      
      BMP Commitment Partners
      EPA expects that approximately 52 partners will review the instructions for annual reporting, complete, sign and submit annual reports in 2018. 
      
      EPA expects that approximately 56 partners will review the instructions for annual reporting, complete, sign and submit annual reports in 2019 to include four partners reporting for the first time. 
      
      ONE Future Commitment Partners
      Over the course of this ICR, EPA estimates that four partners will review the instructions for annual reporting, complete, sign and submit annual reports in 2018, and five partners will report in 2019.
      
      Additional Activities
      
      Partners are requested to notify EPA of changes in Implementation Manager responsibilities or relevant administrative information each year. Based on past experience managing voluntary programs, EPA estimates that approximately 10 percent of all partners experience changes in their Implementation Manager responsibilities each year. 
      
      BMP Commitment 
      Over the course of this ICR, EPA estimates that approximately five BMP Commitment partners will notify EPA of changes in Implementation Manager responsibilities or relevant administrative information each year.
      
      ONE Future Commitment
      Over the course of this ICR, EPA estimates that one ONE Future Commitment partner will notify EPA of changes in Implementation Manager responsibilities or relevant administrative information each year.
      
      

EXHIBIT 1
 
 
 
 
 
 
 
 
 
 
 
ESTIMATED ANNUAL BMP RESPONDENT BURDEN AND COST










                    Hours and Costs Per Respondent/Activity
                             Total Hours and Costs
 
 




                                       

 
 
                                   Number of
 
 
                                     Leg.
                                     Mgr.
                                     Tech.
                                     Cler.
                                   Respond.
                                     Labor
                                   Capital/
                                       
                                   Estimated
                                     Total
                                     Total
 
                                   $ 113.81 
                                   $ 109.06 
                                   $  84.88 
                                   $  46.38 
                                    Hours/
                                     Cost/
                                    Startup
                                   O & M
                                  Responses/
                                    Hours/
                                     Cost/
INFORMATION COLLECTION ACTIVITY
                                     /Hour
                                     /Hour
                                     /Hour
                                     /Hour
                                   Activity
                                   Activity
                                     Cost
                                    Cost[1]
                                     Year
                                     Year
                                     Year
Partnership Agreement
  Receive and review the PA
                                                                              1
                                                                              3
                                                                              0
                                                                              0
                                                                              4
                                                             $             441 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                             80
                                                          $              8,820 
  Gather information and fill out PA data sheet
                                                                              1
                                                                              3
                                                                              0
                                                                              1
                                                                              5
                                                             $             487 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                            100
                                                          $              9,747 
  Sign and submit PA to EPA
                                                                              0
                                                                            0.5
                                                                              0
                                                                            0.5
                                                                              1
                                                            $               78 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                             20
                                                          $              1,554 
SUBTOTAL
                                        
                                        
                                        
 
                                                                             10
                                        
                                        
                                        
                                                                              
                                                                            200
                                                           $            20,121 
Historical Fact Sheet
Review instructions
                                                                              0
                                                                            0.5
                                                                              1
                                                                              0
                                                                            1.5
                                                             $             139 
                                                                            $0 
                                                                            $0 
                                                                              8
                                                                             12
                                                          $              1,115 
Gather information 
                                                                              0
                                                                              2
                                                                              6
                                                                              0
                                                                              8
                                                             $             727 
                                                                            $0 
                                                                            $0 
                                                                              8
                                                                             64
                                                          $              5,819 
Complete template
                                                                              0
                                                                              1
                                                                              2
                                                                              1
                                                                              4
                                                             $             325 
                                                                            $0 
                                                                            $0 
                                                                              8
                                                                             32
                                                          $              2,602 
Submit template to EPA 
                                                                              0
                                                                            0.5
                                                                              0
                                                                              0
                                                                            0.5
                                                            $               55 
                                                                            $0 
                                                                            $0 
                                                                              8
                                                                              4
                                                         $                 436 
SUBTOTAL
                                        
                                        
                                        
 
                                                                             14
                                        
                                        
                                        
                                                                              
                                                                            112
                                                          $              9,972 
Implementation Plan
 
 
 
 
 
 
 
 
 
 
 
  Review instructions
                                                                              0
                                                                              2
                                                                              0
                                                                              0
                                                                              2
                                                             $             218 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                             40
                                                          $              4,362 
  Gather information and develop the Implementation Plan
                                                                              0
                                                                             10
                                                                             10
                                                                              0
                                                                             20
                                                              $          1,939 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                            400
                                                           $            38,787 
  Complete the form(s)
                                                                              0
                                                                              1
                                                                              0
                                                                              1
                                                                              2
                                                             $             155 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                             40
                                                          $              3,109 
  Sign and submit plan to EPA
                                                                              0
                                                                            0.5
                                                                              0
                                                                            0.5
                                                                              1
                                                            $               78 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                             20
                                                          $              1,554 
  Update Implementation Plan, as necessary and Submit to EPA
                                                                              0
                                                                            6.5
                                                                              4
                                                                            1.5
                                                                             12
                                                              $          1,118 
                                                                            $0 
                                                                            $0 
                                                                             10
                                                                            120
                                                           $            11,180 
SUBTOTAL
                                        
                                        
                                        
 
                                                                             37
                                        
                                        
                                        
                                                                              
                                                                            620
                                                           $            58,992 
Annual Report
 
 
 
 
 
 
 
 
 
 
 
  Review instructions and complete registration in e-GGRT
                                                                              0
                                                                             10
                                                                              0
                                                                              0
                                                                             10
                                                              $          1,091 
                                                                            $0 
                                                                            $0 
                                                                             36
                                                                            360
                                                                       $39,260 
  Gather the requested information 
                                                                              0
                                                                             10
                                                                             18
                                                                              1
                                                                             29
                                                              $          2,665 
                                                                            $0 
                                                                            $0 
                                                                             36
                                                                           1044
                                                                       $95,932 
  Prepare, sign, and submit the report to EPA
                                                                              0
                                                                            1.5
                                                                              8
                                                                            1.5
                                                                             11
                                                             $             912 
                                                                            $0 
                                                                            $0 
                                                                             36
                                                                            396
                                                                       $32,839 
SUBTOTAL
                                        
                                        
                                        
 
                                                                             50
                                        
                                        
                                        
                                                                              
                                                                          1,800
                                                                      $168,032 
Additional Activities
 
 
 
 
 
 
 
 
 
 
 
  Notify EPA within two weeks of any change in Natural
 
 
 
 
 
 
 

 
 
 
  Gas Star Implementation Manager responsibility
                                                                              0
                                                                              1
                                                                              0
                                                                            0.5
                                                                            1.5
                                                             $             132 
                                                                            $0 
                                                                            $0 
                                                                              5
                                                                            7.5
                                                                          $661 
SUBTOTAL
                                        
                                        
                                        
 
                                                                            1.5
                                        
                                        
                                        
                                                                              
                                                                            7.5
                                                                          $661 
TOTAL
                                        
                                        
                                        
 
                                        
                                        
                                        
                                        
                                                                              
                                                                          2,740
                                                                       $257,778
[1] EPA did not include O&M costs for postage for respondents. The majority of the BMP Commitment partners will use the e-GRRT online reporting system to submit Annual Reports. Also, partners submit Partnership Agreements, Historical Fact Sheets, and Implementation Plans via e-mail as scanned PDFs or some other type of electronic format. Therefore, costs associated with postage are negligible.

      


      

EXHIBIT 2
 
 
 
 
 
 
 
 
 
 
 
ESTIMATED ANNUAL BMP AGENCY BURDEN AND COST











                    Hours and Costs Per Respondent/Activity
                             Total Hours and Costs
 
 






 
 
                                   Number of
 
 
                                     Leg.
                                     Mgr.
                                     Tech.
                                     Cler.
                                    Agency
                                     Labor
                                   Capital/
                                       
                                   Estimated
                                     Total
                                     Total
 
                                   $ 103.34 
                                   $  96.64 
                                   $  70.85 
                                   $  28.45 
                                    Hours/
                                     Cost/
                                    Startup
                                   O & M
                                  Responses/
                                    Hours/
                                     Cost/
INFORMATION COLLECTION ACTIVITY
                                     /Hour
                                     /Hour
                                     /Hour
                                     /Hour
                                   Activity
                                   Activity
                                     Cost
                                     Cost
                                     Year
                                     Year
                                     Year
Partnership Agreement
  Review PA and follow up, if necessary
                                                                              0
                                                                              0
                                                                              1
                                                                              0
                                                                              1
                                                                $           71 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                             20
                                                             $           1,417 
  Sign the PA
                                                                              0
                                                                           0.05
                                                                              0
                                                                              0
                                                                           0.05
                                                               $             5 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                              1
                                                           $                97 
  Develop a cover letter
                                                                              0
                                                                              0
                                                                              0
                                                                            0.1
                                                                            0.1
                                                               $             3 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                              2
                                                           $                57 
  Send cover letter and original, signed MOU back to partner
                                                                              0
                                                                              0
                                                                              0
                                                                            0.1
                                                                            0.1
                                                               $             3 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                              2
                                                           $                57 
  File cover letter and MOU
                                                                              0
                                                                              0
                                                                              0
                                                                            0.1
                                                                            0.1
                                                               $             3 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                              2
                                                           $                57 
  Enter information into database
                                                                              0
                                                                              0
                                                                              0
                                                                           0.25
                                                                           0.25
                                                               $             7 
                                                                            $0 
                                                                            $0 
                                                                             20
                                                                              5
                                                            $              142 
SUBTOTAL
                                        
                                        
                                        
 
                                                                            1.6
                                        
                                        
                                        
 
                                                                             32
                                                             $           1,827 
Historical Fact Sheet
  Review plan and follow up, if necessary
                                                                              0
                                                                              0
                                                                            1.5
                                                                              0
                                                                            1.5
                                                                 $         106 
                                                                            $0 
                                                                            $0 
                                                                              8
                                                                             12
                                                            $              850 
  File plan
                                                                              0
                                                                              0
                                                                              0
                                                                           0.25
                                                                           0.25
                                                               $             7 
                                                                            $0 
                                                                            $0 
                                                                              8
                                                                              2
                                                           $                57 
  Enter information into database
                                                                              0
                                                                              0
                                                                              0
                                                                           0.25
                                                                           0.25
                                                               $             7 
                                                                            $0 
                                                                            $0 
                                                                              8
                                                                              2
                                                           $                57 
SUBTOTAL
                                        
                                        
                                        
 
                                                                              2
                                        
                                        
                                        
                                                                              
                                                                             16
                                                            $              964 
Implementation Plan
  Review plan and follow up, if necessary
                                                                              0
                                                                              0
                                                                              2
                                                                              0
                                                                              2
                                                                 $         142 
                                                                            $0 
                                                                            $0 
                                                                             30
                                                                             60
                                                             $           4,251 
  File plan
                                                                              0
                                                                              0
                                                                              0
                                                                            0.1
                                                                            0.1
                                                               $             3 
                                                                            $0 
                                                                            $0 
                                                                             30
                                                                              3
                                                           $                85 
  Enter information into database
                                                                              0
                                                                              0
                                                                              0
                                                                           0.25
                                                                           0.25
                                                               $             7 
                                                                            $0 
                                                                            $0 
                                                                             30
                                                                            7.5
                                                            $              213 
SUBTOTAL
                                        
                                        
                                        
 
                                                                           2.35
                                        
                                        
                                        
                                                                              
                                                                           70.5
                                                             $           4,550 
Annual Report
  Review report and follow up, if necessary
                                                                              0
                                                                              0
                                                                              4
                                                                              0
                                                                              4
                                                                 $         283 
                                                                            $0 
                                                                            $0 
                                                                             36
                                                                            144
                                                                       $10,202 
  File report
                                                                              0
                                                                              0
                                                                              0
                                                                            0.1
                                                                            0.1
                                                               $             3 
                                                                            $0 
                                                                            $0 
                                                                             36
                                                                            3.6
                                                                          $102 
  Enter information into database
                                                                              0
                                                                              0
                                                                              0
                                                                            0.5
                                                                            0.5
                                                                $           14 
                                                                            $0 
                                                                            $0 
                                                                             36
                                                                             18
                                                                          $512 
SUBTOTAL
                                        
                                        
                                        
 
                                                                            4.6
                                        
                                        
                                        
                                                                              
                                                                            166
                                                                       $10,817 
Additional Activities
  Enter updated information into database
                                                                              0
                                                                              0
                                                                              0
                                                                           0.25
                                                                           0.25
                                                               $             7 
                                                                            $0 
                                                                            $0 
                                                                              5
                                                                           1.25
                                                                           $36 
SUBTOTAL
                                        
                                        
                                        
 
                                                                           0.25
                                        
                                        
                                        
                                                                              
                                                                           1.25
                                                                           $36 
TOTAL
                                        
                                        
                                        
 
                                        
                                        
                                        
                                        
                                                                              
                                                                            285
                                                              $         18,192 


EXHIBIT 3
 
 
 
 
 
 
 
 
 
 
 
ESTIMATED ANNUAL ONE FUTURE RESPONDENT BURDEN AND COST











                    Hours and Costs Per Respondent/Activity
                             Total Hours and Costs
 
 




                                       

 
 
                                   Number of
 
 
                                     Leg.
                                     Mgr.
                                     Tech.
                                     Cler.
                                   Respond.
                                     Labor
                                   Capital/
                                       
                                   Estimated
                                     Total
                                     Total
 
                                   $ 113.81 
                                   $ 109.06 
                                   $  84.88 
                                   $  46.38 
                                    Hours/
                                     Cost/
                                    Startup
                                   O & M
                                  Responses/
                                    Hours/
                                     Cost/
INFORMATION COLLECTION ACTIVITY
                                     /Hour
                                     /Hour
                                     /Hour
                                     /Hour
                                   Activity
                                   Activity
                                     Cost
                                    Cost[1]
                                     Year
                                     Year
                                     Year
Partnership Agreement 
  Receive and review the PA
                                                                              1
                                                                              3
                                                                              0
                                                                              0
                                                                              4
                                                             $             441 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                              8
                                                         $                 882 
  Gather information and fill out PA data sheet
                                                                              1
                                                                              3
                                                                              0
                                                                              1
                                                                              5
                                                             $             487 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                             10
                                                         $                 975 
  Sign and submit PA to EPA
                                                                              0
                                                                            0.5
                                                                              0
                                                                            0.5
                                                                              1
                                                            $               78 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                              2
                                                         $                 155 
SUBTOTAL
                                        
                                        
                                        
 
                                                                             10
                                        
                                        
                                        
                                                                              
                                                                             20
                                                          $              2,012 
Historical Fact Sheet
Review instructions
                                                                              0
                                                                            0.5
                                                                              1
                                                                              0
                                                                            1.5
                                                             $             139 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                              3
                                                         $                 279 
Gather information 
                                                                              0
                                                                              2
                                                                              6
                                                                              0
                                                                              8
                                                             $             727 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                             16
                                                          $              1,455 
Complete template
                                                                              0
                                                                              1
                                                                              2
                                                                              1
                                                                              4
                                                             $             325 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                              8
                                                         $                 650 
Submit template to EPA 
                                                                              0
                                                                            0.5
                                                                              0
                                                                              0
                                                                            0.5
                                                            $               55 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                              1
                                                         $                 109 
SUBTOTAL
                                        
                                        
                                        
 
                                                                             14
                                        
                                        
                                        
                                                                              
                                                                             28
                                                          $              2,493 
Implementation Plan
  Review instructions
                                                                              0
                                                                              2
                                                                              0
                                                                              0
                                                                              2
                                                             $             218 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                              4
                                                         $                 436 
  Gather information and develop the Implementation Plan
                                                                              0
                                                                             10
                                                                             10
                                                                              0
                                                                             20
                                                              $          1,939 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                             40
                                                          $              3,879 
  Complete the form(s)
                                                                              0
                                                                              1
                                                                              0
                                                                              1
                                                                              2
                                                             $             155 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                              4
                                                         $                 311 
  Sign and submit plan to EPA
                                                                              0
                                                                            0.5
                                                                              0
                                                                            0.5
                                                                              1
                                                            $               78 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                              2
                                                         $                 155 
  Update Implementation Plan, as necessary and Submit to EPA
                                                                              0
                                                                            6.5
                                                                              4
                                                                            1.5
                                                                             12
                                                              $          1,118 
                                                                            $0 
                                                                            $0 
                                                                              1
                                                                             12
                                                          $              1,118 
SUBTOTAL
                                        
                                        
                                        
 
                                                                             37
                                        
                                        
                                        
                                                                              
                                                                             62
                                                          $              5,899 
Annual Report
  Review instructions and complete registration in e-GGRT
                                                                              0
                                                                             10
                                                                              0
                                                                              0
                                                                             10
                                                              $          1,091 
                                                                            $0 
                                                                            $0 
                                                                              3
                                                                             30
                                                                        $3,272 
  Gather the requested information 
                                                                              0
                                                                             18
                                                                             50
                                                                              2
                                                                             70
                                                              $          6,300 
                                                                            $0 
                                                                            $0 
                                                                              3
                                                                            210
                                                                       $18,899 
  Prepare, sign, and submit the report to EPA
                                                                              0
                                                                           10.5
                                                                             15
                                                                            5.5
                                                                             31
                                                              $          2,673 
                                                                            $0 
                                                                            $0 
                                                                              3
                                                                             93
                                                                        $8,020 
SUBTOTAL
                                        
                                        
                                        
 
                                                                            111
                                        
                                        
                                        
                                                                              
                                                                            333
                                                                       $30,191 
Additional Activities
  Notify EPA within two weeks of any change in Natural
 
 
 
 
 
 
 

 
 
 
  Gas Star Implementation Manager responsibility
                                                                              0
                                                                              1
                                                                              0
                                                                            0.5
                                                                            1.5
                                                             $             132 
                                                                            $0 
                                                                            $0 
                                                                              1
                                                                            1.5
                                                                          $132 
SUBTOTAL
                                        
                                        
                                        
 
                                                                            1.5
                                        
                                        
                                        
                                                                              
                                                                            1.5
                                                                          $132 
TOTAL
                                        
                                        
                                        
 
                                        
                                        
                                        
                                        
                                                                              
                                                                            445
                                                                        $40,728
1 EPA did not include O&M costs for postage for respondents. The majority of the ONE Future Commitment partners will submit reports via e-mail as Excel spreadsheets. Also, partners submit Partnership Agreements, Historical Fact Sheets, and Implementation Plans via e-mail as scanned PDFs or some other type of electronic format. Therefore, costs associated with postage are negligible. 



EXHIBIT 4
 
 
 
 
 
 
 
 
 
 
 
ESTIMATED ANNUAL ONE FUTURE AGENCY BURDEN AND COST 











                    Hours and Costs Per Respondent/Activity
                             Total Hours and Costs
 
 






 
 
                                   Number of
 
 
                                     Leg.
                                     Mgr.
                                     Tech.
                                     Cler.
                                    Agency
                                     Labor
                                   Capital/
                                       
                                   Estimated
                                     Total
                                     Total
 
                                   $ 103.34 
                                   $  96.64 
                                   $  70.85 
                                   $  28.45 
                                    Hours/
                                     Cost/
                                    Startup
                                   O & M
                                  Responses/
                                    Hours/
                                     Cost/
INFORMATION COLLECTION ACTIVITY
                                     /Hour
                                     /Hour
                                     /Hour
                                     /Hour
                                   Activity
                                   Activity
                                     Cost
                                     Cost
                                     Year
                                     Year
                                     Year
Partnership Agreement
  Review PA and follow up, if necessary
                                                                              0
                                                                              0
                                                                              1
                                                                              0
                                                                              1
                                                                $           71 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                              2
                                                            $              142 
  Sign the PA
                                                                              0
                                                                           0.05
                                                                              0
                                                                              0
                                                                           0.05
                                                               $             5 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                            0.1
                                                           $                10 
  Develop a cover letter
                                                                              0
                                                                              0
                                                                              0
                                                                            0.1
                                                                            0.1
                                                               $             3 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                            0.2
                                                          $                  6 
  Send cover letter and original, signed MOU back to partner
                                                                              0
                                                                              0
                                                                              0
                                                                            0.1
                                                                            0.1
                                                               $             3 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                            0.2
                                                          $                  6 
  File cover letter and MOU
                                                                              0
                                                                              0
                                                                              0
                                                                            0.1
                                                                            0.1
                                                               $             3 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                            0.2
                                                          $                  6 
  Enter information into database
                                                                              0
                                                                              0
                                                                              0
                                                                           0.25
                                                                           0.25
                                                               $             7 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                            0.5
                                                           $                14 
SUBTOTAL
                                        
                                        
                                        
 
                                                                            1.6
                                        
                                        
                                        
                                                                              
                                                                            3.2
                                                            $              183 
Historical Fact Sheet
  Review plan and follow up, if necessary
                                                                              0
                                                                              0
                                                                            1.5
                                                                              0
                                                                            1.5
                                                                 $         106 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                              3
                                                            $              213 
  File plan
                                                                              0
                                                                              0
                                                                              0
                                                                           0.25
                                                                           0.25
                                                               $             7 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                            0.5
                                                           $                14 
  Enter information into database
                                                                              0
                                                                              0
                                                                              0
                                                                           0.25
                                                                           0.25
                                                               $             7 
                                                                            $0 
                                                                            $0 
                                                                              2
                                                                            0.5
                                                           $                14 
SUBTOTAL
                                        
                                        
                                        
 
                                                                              2
                                        
                                        
                                        
                                                                              
                                                                              4
                                                            $              241 
Implementation Plan
  Review plan and follow up, if necessary
                                                                              0
                                                                              0
                                                                              2
                                                                              0
                                                                              2
                                                                 $         142 
                                                                            $0 
                                                                            $0 
                                                                              3
                                                                              6
                                                            $              425 
  File plan
                                                                              0
                                                                              0
                                                                              0
                                                                            0.1
                                                                            0.1
                                                               $             3 
                                                                            $0 
                                                                            $0 
                                                                              3
                                                                            0.3
                                                          $                  9 
  Enter information into database
                                                                              0
                                                                              0
                                                                              0
                                                                           0.25
                                                                           0.25
                                                               $             7 
                                                                            $0 
                                                                            $0 
                                                                              3
                                                                           0.75
                                                           $                21 
SUBTOTAL
                                        
                                        
                                        
 
                                                                           2.35
                                        
                                        
                                        
                                                                              
                                                                           7.05
                                                            $              455 
Annual Report
  Review report and follow up, if necessary
                                                                              0
                                                                              0
                                                                              4
                                                                              0
                                                                              4
                                                                 $         283 
                                                                            $0 
                                                                            $0 
                                                                              3
                                                                             12
                                                                          $850 
  File report
                                                                              0
                                                                              0
                                                                              0
                                                                            0.1
                                                                            0.1
                                                               $             3 
                                                                            $0 
                                                                            $0 
                                                                              3
                                                                            0.3
                                                                            $9 
  Enter information into database
                                                                              0
                                                                              0
                                                                              0
                                                                            0.5
                                                                            0.5
                                                                $           14 
                                                                            $0 
                                                                            $0 
                                                                              3
                                                                            1.5
                                                                           $43 
SUBTOTAL
                                        
                                        
                                        
 
                                                                            4.6
                                        
                                        
                                        
                                                                              
                                                                             14
                                                                          $901 
Additional Activities
  Enter updated information into database
                                                                              0
                                                                              0
                                                                              0
                                                                           0.25
                                                                           0.25
                                                               $             7 
                                                                            $0 
                                                                            $0 
                                                                              1
                                                                           0.25
                                                                            $7 
SUBTOTAL
                                        
                                        
                                        
 
                                                                           0.25
                                        
                                        
                                        
                                                                              
                                                                           0.25
                                                                            $7 
TOTAL
                                        
                                        
                                        
 
                                        
                                        
                                        
                                        
                                                                              
                                                                             28
                                                             $           1,787 


      
      6(e)	Bottom Line Burden Hours and Costs
      
      Exhibits 1, 2, 3, and 4 show the aggregate estimated annual burden and cost to respondents and the government, respectively, for the information collection activities covered under this ICR. 
      
      (i)  Respondent Tally
      EPA estimates an annual respondent burden of 3,184 hours, equivalent to $298,506, across both the BMP and ONE Future commitment options. Over the three-year period covered by this ICR, EPA estimates the burden of the Program to be 9,552 hours, equivalent to $895,519. EPA projects a total of 66 respondents by the third year of this ICR. 
      
      BMP Commitment Partners
      The total burden for BMP Commitment respondents is approximately 2,740 hours per year, equivalent to an annual cost of approximately $257,778. Over the three-year period covered by this ICR, EPA estimates the burden of the Program to be 8,219 hours and $773,335 for respondents.
      
      ONE Future Commitment Partners 
      The total burden for ONE Future Commitment respondents is approximately 445 hours per year with an annual cost of approximately $40,728. Over the three-year period covered by this ICR, EPA estimates the burden of the Program to be 1,334 hours and $122,184 for respondents.
      
      (ii)  The Agency Tally
      The total annual burden to the Agency is approximately 314 hours, equivalent to $19,979, across both the BMP and ONE Future commitment options. Over the three-year period covered by this ICR, EPA estimates the burden to the Agency to be 941 hours and $59,938.
      
      BMP Commitment Partners
      The total annual burden to the Agency is approximately 285 hours with a cost of approximately $18,192 per year. Over the three-year period covered by this ICR, EPA estimates the burden of the Program to be 856 hours and $54,577 for EPA.
      
      ONE Future Commitment Partners 
      The total annual burden to the Agency is approximately 28 hours with a cost of approximately $1,787 per year. Over the three-year period covered by this ICR, EPA estimates the burden of the Program to be 85 hours and $5,361 for EPA.
      
      (iii)  Variations In The Annual Bottom Line
      EPA anticipates some variation in the annual respondent reporting/recordkeeping burden over the three-year period covered by this ICR, with subsequent years of participation in the program being more burdensome than the first year. This variation is due to the majority of program materials requested (Partnership Agreement, Implementation Plan, the optional Historical Actions Fact Sheet), being submitted during the first year of partnership, however with no annual reporting. Subsequent years in the program will include annual reporting and periodic updates to program materials (as needed).

      6(f)	Reasons for Change in Burden

      This is a new program. Therefore, this is an initial burden estimate. 
      
      6(g)	Burden Statement

      BMP Commitment Partners
      The average overall annual burden for information collection requirements associated with this ICR is estimated to be 49 hours per respondent (this was calculated using the annual average burden hours for BMP respondents divided by the annual average number of expected BMP respondents).
      
      For new partners, the average reporting burden per partner for information collection requirements associated with completing the Partnership Agreement is estimated to be 10 hours. The burden estimate includes time to receive and review the Partnership Agreement; gather information and fill out the Partnership Agreement data sheet; and sign and submit the Partnership Agreement to EPA.
      
      The average reporting burden per partner for information collection requirements associated with completing the optional Historical Actions Fact Sheet is 14 hours. The burden estimate includes time to review instructions; gather information and fill out the template; and submit the template to EPA.
      
      The average reporting burden per partner for information collection requirements associated with completing and periodically updating the Implementation Plan is estimated to be 37 hours. The burden estimate includes time to review the plan form; gather the requested information; complete the plan; and submit to EPA.  
      
      The average per partner reporting burden for information collection requirements associated with completing the annual report is estimated to be 50 hours. The burden estimate includes time to review the reporting package (instructions, forms and any Program updates); gather the requested information; complete the form; sign and date the form; and submit to EPA. 
      
      For BMP Commitment partners, the average per partner reporting burden for information collection requirements associated with additional activities is estimated to be 1.5 hours. The reporting burden includes time to notify EPA of changes in Methane Challenge Implementation Manager responsibility. 
      
      ONE Future Commitment Partners 
      The average overall annual burden for information collection requirements associated with this ICR is estimated to be 89 hours per respondent (this was calculated using the annual average burden hours for ONE Future respondents divided by the annual average number of expected ONE Future respondents). 
      
      For new partners, the average reporting burden per partner for information collection requirements associated with completing the Partnership Agreement is estimated to be 10 hours. The burden estimate includes time to receive and review the Partnership Agreement; gather information and fill out the Partnership Agreement data sheet; and sign and submit the Partnership Agreement to EPA.
      
      The average reporting burden per partner for information collection requirements associated with completing the optional Historical Actions Fact Sheet is 14 hours. The burden estimate includes time to review instructions; gather information and fill out the template; and submit the template to EPA.
      
      The average reporting burden per partner for information collection requirements associated with completing and periodically updating the Implementation Plan is estimated to be 37 hours. The burden estimate includes time to review the plan form; gather the requested information; complete the plan; and submit to EPA.  
      
      The average per partner reporting burden for information collection requirements associated with completing the annual report is estimated to be 111 hours. The burden estimate includes time to review the reporting package (instructions, forms and any Program updates); gather the requested information; complete the form; sign and date the form; and submit to EPA. 
      
      For ONE Future Commitment partners, the average per partner reporting burden for information collection requirements associated with additional activities is estimated to be 1.5 hours. The reporting burden includes time to notify EPA of changes in Methane Challenge Implementation Manager responsibility. 
      
      Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR part 9 and 48 CFR chapter 15.    
      
      To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID Number EPA-HQ-OAR-2016-0731, which is available for online viewing at www.regulations.gov, or in person viewing at the Air and Radiation Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Air and Radiation Docket is 202-566-1742. An electronic version of the public docket is available at www.regulations.gov. This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically. When in the system, select "search," then key in the Docket ID Number identified above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2016-0731 and OMB Control Number 2060-NEW in any correspondence.
      
      


