INFORMATION
COLLECTION
REQUEST
FOR
LEVEL
ONE
OF
THE
EPA
PERFORMANCE
TRACK
PROGRAM:
THE
ENVIRONMENTAL
ACHIEVEMENT
TRACK
May
10,
2000
Prepared
by:

U.
S
Environmental
Protection
Agency
Office
of
Policy
Economics,
and
Innovation
1200
Pennsylvania
Avenue
NW
Washington
DC,
20003
2
TABLE
OF
CONTENTS
Table
of
Contents.............................................................................................................................
2
1.
Identification
Of
The
Information
Collection
.......................................................................
4
1(
a)
Title
Of
The
Information
Collection............................................................................
4
1(
b)
Short
Characterization/
Abstract...................................................................................
4
2.
Need
For
And
Use
Of
The
Collection.....................................................................................
6
2(
a)
Need/
Authority
For
The
Collection.............................................................................
6
2(
b)
Use/
Users
Of
The
Data................................................................................................
6
3.
Nonduplication,
Consultations,
And
Other
Collection
Criteria..........................................
6
3(
a)
Nonduplication.............................................................................................................
6
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB..........................................
7
3(
c)
Consultations................................................................................................................
7
3(
d)
Effects
Of
Less
Frequent
Collection............................................................................
7
3(
e)
General
Guidelines.......................................................................................................
7
3(
f)
Confidentiality..............................................................................................................
7
3(
g)
Sensitive
Questions......................................................................................................
8
4.
The
Respondents
And
The
Information
Requested..............................................................
8
4(
a)
Respondents/
SIC
Codes...............................................................................................
8
4(
b)
Information
Requested.................................................................................................
8
(
i)
Data
items,
including
recordkeeping
requirements............................................
8
(
ii)
Respondent
Activities.........................................................................................
9
5.
The
Information
Collected­­
Agency
Activities,
Collection
Methodology,
and
Information
Management.................................................................................................................................
10
5(
a)
Agency
Activities.......................................................................................................
10
5(
b)
Collection
Methodology
And
Management...............................................................
11
5(
c)
Small
Entity
Flexibility..............................................................................................
11
5(
d)
Collection
Schedule....................................................................................................
11
6.
Estimating
The
Burden
And
Cost
Of
The
Collection..........................................................
12
6(
a)
Estimating
Respondent
Burden..................................................................................
12
6(
b)
Estimating
Respondent
Costs.....................................................................................
12
(
i)
Estimating
Labor
Costs....................................................................................
12
(
ii)
Estimating
Capital
and
Operations
and
Maintenance
Costs............................
15
6(
c)
Estimating
Agency
Burden
And
Cost........................................................................
15
3
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs............................
16
6(
e)
Bottom
Line
Burden
Hours
And
Cost
Tables............................................................
16
(
i)
Respondent
Tally..............................................................................................
16
(
ii)
The
Agency
Tally.............................................................................................
17
(
iii)
Variations
In
The
Annual
Bottom
line............................................................
17
6(
f)
Reasons
For
Change
In
Burden..................................................................................
17
6(
g)
Burden
Statement.......................................................................................................
18
Appendix
A:
Application
to
the
Environmental
Achievement
Track
..........................................
19
Index
of
Tables
Table
1.1
Summary
of
Burden
Estimates........................................................................................
5
Table
5.1
Collection
Schedule.......................................................................................................
11
Table
6.1
Annual
Respondent
Burden
and
Cost
(
Industry)...........................................................
14
Table
6.2
Annual
Respondent
Burden
and
Cost
(
State
Regulatory
Agencies)..............................
15
Table
6.3
Annual
Agency
Burden
and
Cost..................................................................................
16
Table
6.4
Total
Estimated
Respondent
Burden
and
Cost
Summary..............................................
17
Table
6.5
Total
Estimated
Agency
Burden
and
Cost
Summary....................................................
17
4
SECTION
I:
PART
A
OF
THE
SUPPORTING
STATEMENT
1.
IDENTIFICATION
OF
INFORMATION
COLLECTION
1(
a)
Title
of
Information
Collection
Voluntary
Participation
in
Level
One
of
the
Performance
Track:
The
Environmental
Achievement
Track
1(
b)
Short
Characterization
The
Environmental
Protection
Agency
is
developing
a
national
Performance
Track
Program
to
motivate
and
reward
facilities
that
achieve
better
environmental
performance
than
is
required
under
existing
regulations.
The
Performance
Track
program
is
the
outcome
of
the
July
1999
report,
"
Aiming
for
Excellence:
Actions
to
Encourage
Stewardship
and
Accelerate
Environmental
Progress."
In
this
report,
the
EPA
committed
to
developing
a
Performance
Track
program
to
encourage
environmental
leaders
to
continue
striving
for
excellence
in
environmental
protection.
This
program
would
enhance
the
current
regulatory
system
by
offering
recognition
and
other
incentives
to
facilities
that
have
shown
a
commitment
to
doing
better
than
compliance
with
environmental
protection.
The
program
is
also
the
outgrowth
of
two
existing
EPA's
pilot
programs,
the
Environmental
Leadership
Program
(
ELP)
and
EPA
Region
I's
StarTrack
Program.

The
Performance
Track
is
a
two­
tiered,
voluntary
program
designed
to
promote
continued
environmental
protection
though
the
use
of
Environmental
Management
Systems
(
EMS),
Pollution
Prevention
Programs,
and
public
reporting.
Qualifying
program
participants
will
benefit
from
a
variety
of
incentives
expected
to
include,
but
not
limited
to,
public
recognition,
reduced
monitoring
and
reporting,
and
operational
flexibility.
EPA
plans
to
announce
and
begin
to
solicit
applications
for
level
one
of
the
Performance
Track,
the
Environmental
Achievement
Track,
at
the
end
of
June
2000.
Level
two,
the
Environmental
Stewardship
Track,
will
be
announced
in
May
of
2001.
Because
the
Environmental
Stewardship
Track
will
not
be
announced
until
2001,
the
scope
of
this
information
collection
request
will
be
limited
to
level
one
of
the
Performance
Track,
the
Environmental
Achievement
Track.

To
qualify
for
the
Environmental
Achievement
Track,
facilities
must
submit
to
an
application
documenting
specific
attributes
of
their
environmental
management
system
(
EMS),
their
record
of
sustained
compliance
with
environmental
regulations,
and
their
commitment
to
continuous
improvement
in
environmental
performance.
This
can
be
achieved
through
self
certification,
using
a
self
assessment
such
as
the
KEMP
or
GEMI
EMS
self
assessment
protocol.
As
participants
in
the
program,
facilities
will
be
required
to
retain
EMS
documentation
and
to
provide
a
summary
of
their
performance,
including
a
summary
of
the
results
of
compliance
and
5
EMS
audits,
in
their
annual
report.
EPA
will
use
this
information
to
determine
whether
a
facility
qualifies
for
the
Environmental
Achievement
Track,
and
once
in
the
program,
to
document
continuous
environmental
improvement.
The
annual
report
will
be
made
available
to
the
public.

The
submission
of
an
application
for
the
Environmental
Achievement
Track
is
voluntary,
but
required
to
be
accepted
into
the
program.
EPA
will
review
the
applications
and
notify
the
applicant
within
a
specified
time
frame
whether
they
qualify
for
the
program.
In
the
event
that
an
application
is
denied,
the
EPA
will
inform
the
applicant
of
the
basis
for
denial.
EPA
will
identify
"
open
seasons"
during
which
time
applications
will
be
accepted.
The
information
required
of
participants
upon
acceptance
to
the
Environmental
Achievement
Track,
annual
reporting,
is
mandatory
to
remain
in
the
program
and
receive
the
associated
benefits.

EPA
estimates
that
approximately
250
facilities
may
voluntarily
apply
to
the
Performance
Track
annually.
EPA
further
estimates
that
200
facilities
will
be
selected
to
participate
in
the
Environmental
Achievement
Track
(
Tier
1).
The
Agency
estimates
that
the
burden
required
by
this
action
for
facilities
will
range
from
120
hours
to
270
hours.
The
best
estimate
burden
is
230
hours.
Facilities
that
have
well
documented
and
established
environmental
management
systems
in
place
and
currently
share
some
environmental
performance
information
with
the
public
will
experience
burden
at
the
lower
end
of
the
range.
Other
facilities
may
require
more
burden
to
demonstrate
how
they
meet
the
entry
criteria.

The
following
table
summarizes
the
estimate
burden
for
the
Environmental
Achievement
Track.

Table
1.1
Summary
of
Burden
Estimate
Facility
Burden
Hours
Facility
Burden
Cost
Number
of
Facilities
Total
Burden
Hours
Total
Burden
Cost
Application
40
$
1,070
250
10,000
$
270,000
Compliance
Demonstration
80
$
2,375
200
15,550
$
475,000
EMS
Documentation
and
Reporting
40
$
1,110
200
8,100
$
220,000
Continuous
Performance
Demonstration
40
$
1,060
200
7,500
$
210,000
Reporting
&
Public
Outreach
30
$
860
200
6,400
$
175,000
6
Total
230
$
6,475
47,550
$
1,340,000
2.
NEED
FOR
AND
USE
OF
THE
COLLECTION
2.
(
a)
Need/
Authority
for
the
Collection
Since
1995
the
EPA
has
launched
a
number
of
reinvention
initiatives
which
emphasize
streamlining
the
regulatory
process
and
making
regulatory
programs
more
efficient.
The
July
1999
report,
Aiming
for
Excellence,
announced
EPA's
commitment
to
launching
a
national
Performance
Track
program
that
uses
incentives
and
promotes
environmental
management
systems
to
reward
and
encourage
environmental
leaders.

EPA
views
this
program
as
a
way
to
build
upon
and
integrate
a
range
of
innovative
programs
that
have
been
underway
for
some
time,
at
both
the
federal
and
state
level.
The
Performance
Track
program
will
increase
the
use
of
environmental
management
systems,
public
participation,
and
performance
reporting,
which
will
help
improve
the
environment,
while
shifting
EPA's
resources
from
the
oversight
of
good
performers..

2(
b)
Use/
Users
of
the
Data
The
applications
collected
for
the
Environmental
Achievement
Track
will
be
used
by
EPA
and
participating
regulatory
entities
to
determine
whether
the
applicant
qualifies
for
the
program.
Tthe
annual
performance
report
will
be
used
by
EPA
to
assess
the
participant's
progress
and
environmental
performance
while
in
the
program,
and
to
determine
whether
they
should
remain
in
the
program.
Both
components
protect
the
credibility
of
the
program
by
avoiding
erroneous
recognition
of
facilities
with
poor
environmental
performance.
The
public
reporting
element
of
the
program
will
also
provide
information
to
the
local
community.

3.
NONDUPLICATION,
CONSULATIONS,
AND
OTHER
COLLECTION
CRITERIA
3(
a)
Nonduplication
EPA
currently
does
not
have
sources
for
the
other
information
requested
by
the
Environmental
Achievement
Track.
The
information
requested
either
as
part
of
the
Environmental
Achievement
Track
application
or
in
the
required
reports
is
not
available
through
any
other
source
within
the
Agency.
Nor
is
it
available
outside
the
agency.

EPA
is
designing
the
Environmental
Achievement
Track
to
allow
facilities
to
select
a
limited
number
of
performance
measures
upon
which
to
report
past
performance
and
commit
to
future
performance.
EPA
will
encourage
facilities
to
use
the
results
and
goals
they
have
under
existing
local,
state
or
federal
programs
in
order
to
reduce
the
possibility
for
duplication
of
efforts.
For
example,
a
facility
participating
in
the
Agency's
Climatewise
program
could
use
the
achievements
documented
in
that
program
to
meet
their
Environmental
Achievement
Track.
7
3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
to
OMB
In
compliance
with
the
1995
Paperwork
Reduction
act,
EPA
has
begun
soliciting
public
comments
for
a
60
day
period
prior
to
submission
of
the
ICR
to
OMB.
EPA
issued
a
Federal
Register
Notice
announcing
the
ICR
and
providing
a
burden
estimate
on
March
2,
2000.
(
65
FRL
6545­
6).
EPA
received
no
comments
during
this
period.

3(
c)
Consultations
This
information
collection
was
developed
by
an
EPA
workgroup
consisting
of
Headquarters
and
Regional
Personnel.
Two
public
stakeholder
meetings
were
held
in
Washington,
DC
on
March
15th
,
and
March
21st,
2000.
Three
additional
meetings
were
held
on
April
4th
in
Boston,
MA
April
10th
in
San
Jose,
CA
and
April
27th
in
Chicago,
IL.
The
purpose
of
these
meetings
was
to
solicit
comments
and
questions
about
the
development
of
the
program,
including
elements
of
information
collection.
EPA
has
also
been
actively
seeking
the
input
of
state
representatives
through
periodic
teleconference
calls.
EPA
is
hosting
a
meeting
to
focus
on
the
role
of
the
states
in
the
Performance
Track
program
in
Denver,
CO
on
May
11­
12,
2000.

3(
d)
Effects
of
Less
Frequent
Collection
Environmental
Achievement
Track
participants
are
required
to
submit
an
annual
performance
report
documenting
their
environmental
performance
relative
to
the
commitments
they
made
upon
entry
into
the
program.
This
information
is
important
to
determine
whether
participants
are
meeting
their
commitments,
as
well
as
to
evaluate
the
effectiveness
of
the
program.
Less
frequent
reporting
could
jeopardize
the
credibility
and
success
of
the
program.

3(
e)
General
Guidelines
This
information
collection
adheres
to
the
general
guidelines
set
forth
by
the
Office
of
Management
and
Budget.

3(
f)
Confidentiality
Materials
involving
invasion
of
privacy
or
containing
a
trade
secret
should
not
be
included
in
the
application.
EPA
shall
treat
information
claimed
as
confidential
business
information
(
CBI)
in
accordance
with
the
requirements
of
40
CFR
Part
2.
If
the
participant
fails
to
claim
the
information
as
confidential
upon
submission,
it
may
be
made
available
to
the
public
without
further
notice.
EPA
cannot
guarantee
that
information
submitted
for
application
or
reporting
to
the
Environmental
Achievement
Track
and
claimed
as
confidential
will
be
protected
from
release
under
the
Freedom
of
Information
Act
(
FOIA).
State
participants
will
maintain
CBI
confidentiality
to
the
extent
allowed
by
relevant
state
law.
Note
that
some
state
laws
provide
for
a
greater
degree
of
access
to
and
narrower
protections
for
information
considered
confidential
under
federal
law.
8
3(
g)
Sensitive
Questions
Sensitive
questions
are
defined
in
the
ICR
instructions
as
"
questions
concerning
sexual
behavior
or
attitudes,
religious
beliefs,
or
other
matters
usually
considered
"
private."
The
reporting
requirements
addressed
in
this
information
collection
request
do
not
include
sensitive
questions.

4.
THE
RESPONDENTS
AND
THE
INFORMATION
REQUESTED
4(
a)
Respondent/
Standard
Industrial
Classification
(
SIC)
Codes
Potential
respondents
include
all
entities
regulated
by
EPA
pursuant
to
its
authority
under
the
various
environmental
statutes
(
who
wish
to
participate
in
the
Environmental
Achievement
Track).
Therefore
there
are
several
SIC
codes
for
potential
respondents.
EPA
has
also
been
approached
by
businesses
not
traditionally
regulated
by
EPA
(
e.
g.,
real
estate)
expressing
interest
in
the
Performance
Track
program.

4(
b)
Information
Requested
(
i)
Data
Items
Facilities
who
are
interested
in
the
Environmental
Achievement
Track
will
receive
an
application
packet,
including
a
guidance
document
to
assist
them
in
preparing
the
application.
A
copy
of
the
application
packet
is
attached
as
Appendix
A.
EPA
is
attempting
to
utilize
a
selfcertification
approach
to
the
extent
possible.
The
application
consists
of
four
sections:

Section
A
asks
for
general
information,
such
as
the
name,
address,
and
size
of
the
facility,
name
and
phone
number
of
a
contact
person,
the
number
of
employees,
the
nature
of
the
business,
and
the
facility's
SIC
code.

Section
B
requires
the
applicant
to
verify
that
the
facility's
environmental
management
system
(
EMS)
includes
the
required
attributes,
including
an
EMS
policy,
planning,
implementation
and
operation,
checking
and
corrective
action,
and
management
review.

Section
C
requires
the
applicant
to
choose
a
minimum
of
one
(
small
business)
or
two
(
large
business)
categories
and
document
improvements
that
have
been
made
with
respect
to
performance
during
the
current
year
and
the
previous
year.
Using
the
same
or
a
different
set
of
categories,
the
applicant
must
select
a
minimum
of
two
(
small
business)
or
four
(
large
business)
categories
for
which
the
facility
will
commit
to
report
on
it
performance
during
the
three
years
following
acceptance
into
the
program.
The
categories
include:
9
°
Energy
Use
°
Water
Use
°
Emissions
of
Key
Air
Pollutants
°
Chemical
Releases
°
Waste
Generated
°
Discharges
to
Water
°
Product
Performance
°
Restoration/
Preservation
Section
D
requires
that
the
applicant
answer
three
question
regarding
how
the
facility
responds
to
community
concerns
regarding
the
environmental
impacts
of
their
operations
and
how
often
the
facility
provides
information
to
the
local
community
about
their
environmental
performance.
In
addition,
this
section
requires
a
list
of
three
local
or
state
regulatory
officials,
and
community/
local
references
that
may
be
contacted
by
EPA
in
reviewing
the
application.

The
results
of
the
applicant's
response
to
section
C
of
the
application,
as
well
as
the
facility's
annual
report
will
be
submitted
to
EPA
and
made
generally
available
to
the
public.
For
small
businesses,
EPA
may
make
its
information
available
on
the
EPA
website
to
fulfill
the
generally
available
criteria.
The
annual
report
is
expected
to
summarize
the
following:

°
A
summary
of
the
results
of
compliance
and
EMS
audits
conducted
during
the
year
°
Progress
on
the
performance
measures
selected
for
continuous
improvement
°
Summary
of
public
outreach
activities
and
results
(
e.
g.,
agendas,
meeting
summaries,
etc.)

EPA
will
encourage
participants
to
utilize
existing
sources
of
information
(
e.
g.,
performance
elements
of
existing
local,
state
or
federal
voluntary
environmental
programs)
that
facilities
already
provide
whenever
possible
to
meet
the
Environmental
Achievement
Track
requirements.

(
ii)
Respondent
Activities
The
following
are
activities
a
respondent
must
perform
during
the
application
phase:

1.
Read
the
application
and
guidance
document
2.
Gather
information
to
complete
the
four
sections
of
the
application
3.
Complete
the
four
sections
of
the
application
4.
Submit
the
application
to
the
EPA
5.
Wait
for
notification
from
EPA
of
acceptance
or
rejection
The
following
are
activities
a
respondent
must
perform
while
participating
in
the
Environmental
Achievement
Track:
10
1.
Submit
annual
report
addressing
the
topics
listed
above
under
"
data
items."
2.
Make
the
annual
report
available
to
the
local
community
3.
Certify
that
the
facility
will
continue
to
meet
the
criteria
for
participation
in
the
Environmental
Achievement
Track.

EPA
and
States
participating
in
the
program
will
be
conducting
the
following
activities:

1.
Environmental
Compliance
Screen
2.
Possible
site
visit
3.
Evaluation
of
applicant
4.
Evaluation
of
Annual
Environmental
Performance
Report
The
activities
required
by
the
components
of
this
information
collection
request
are
not
customary
and
usual
business
practice,
except
for
the
submission
of
EMS
information.
For
facilities
that
have
a
well
documented
EMS
in
place,
compiling
and
maintaining
EMS
data
is
a
customary
business
practice.

5.
THE
INFORMATION
COLLECTED­
AGENCY
ACTIVITIES,
COLLECTION
METHODOLOGY,
AND
INFORMATION
MANAGEMENT
5(
a).
Agency
Activities
Environmental
Achievement
Track
participants
will
be
selected
by
a
review
team
consisting
of
EPA
representatives.
EPA
will
coordinate
with
the
relevant
state
environmental
agency
during
review
of
the
applicants.
Selection
decisions
will
be
based
on
whether
the
applicant
facility
meets
all
of
the
requirements
outlined
in
the
application,
including
a
compliance
screen.
The
compliance
screen
is
based
on
the
Agency's
Enformance
Screening
Guidance
for
Partnership
Programs.
If
the
applicant
does
not
meet
the
criteria,
the
facility
will
not
be
accepted
into
the
Environmental
Achievement
Track,
and
will
be
notified
in
writing.

EPA
will
respond
to
applicants
within
a
90
days
after
the
close
of
the
"
open
season"
period.
Facilities
will
be
notified
in
writing
whether
they
qualify
or
do
not
qualify.
Facilities
that
are
not
accepted
for
the
program
may
reapply
at
future
open
seasons.
11
The
following
is
a
list
of
itemized
Agency
activities
in
the
Environmental
Achievement
Track:
1.
Receive
applications
from
interested
facilities
2.
Perform
comprehensive
compliance
screen
3.
Evaluate
applications
4.
Notify
applicant
of
selection
or
rejection
5.
Perform
annual
compliance
screen
for
participating
companies
6.
Review
compliance
audit
work
plan
and
report
7.
Review
EMS
audit
work
plan
and
implementation
plan
8.
Evaluate
participant
facility
continuous
improvement
achievements
annually
according
to
annual
reports.
5(
b)
Collection
Methodology
and
Management
EPA
intends
to
set
up
a
Performance
Track
website,
which
will
provide
program
description
and
information,
including
application
materials,
documents
to
assist
the
facility
with
the
application,
and
contact
names
and
addresses.
Applicants
must
submit
four
copies
of
the
application
to
EPA.
The
application
will
be
evaluated
for
completeness.
EPA
will
also
conduct
a
compliance
screen
of
the
applicant
using
the
Agency's
Compliance
Screening
for
Partnership
Programs
Guidance.
EPA
may
also
conduct
limited
site
visits
to
evaluate
the
program
and
identify
opportunities
to
improve
program
operation
and
guidance.

Required
documents
and
reports
submitted
during
the
period
of
participation
will
be
sent
to
an
EPA
Environmental
Achievement
Track
contact.
The
annual
report
will
be
posted
on
the
Performance
Track
website.
To
the
extent
practicable,
the
Performance
Track
program
will
utilize
electronic
submissions
of
application
and
reporting.

5(
c)
Small
Entity
Flexibility
EPA
realizes
that
applicants
to
the
Environmental
Achievement
Track
will
vary
in
size.
The
burden
to
small
facilities
has
been
recognized
during
the
development
of
the
program,
its
application
and
reporting
requirements,
and
this
information
collection.
The
need
to
keep
the
program
requirements
flexible
enough
to
stimulate
interest
in
participation
by
small
facilities
was
considered
during
the
planning
of
the
program.
The
application
and
annual
report
do
not
include
any
elements
that
create
any
additional
burden
to
small
facilities
beyond
that
imposed
on
large
facilities.

5(
d)
Collection
Schedule
Please
see
Table
5.1
Collection
Schedule
12
Table
5.1
Environmental
Achievement
Track
Collection
Schedule
Activity
Schedule
EPA
solicits
applications
Open
Season
(
3
months,
at
least
once
annually)

EPA
reviews
applications,
performs
compliance
screen
During
open
season
and
up
to
90
days
from
close
of
open
season
EPA
selects
Environmental
Achievement
Track
Participants;
notifies
applicants
of
selection
status
Up
to
90
days
from
close
of
open
season
Participants
prepare
and
submit
annual
performance
report
Annually
6.
ESTIMATING
THE
BURDEN
AND
COST
OF
THE
COLLECTION
6(
a)
Respondent
Burden
This
section
presents
EPA's
estimates
of
the
respondent's
burden
hours
and
cost
to
complete
the
activities
associated
with
this
information
collection.
In
using
this
analysis,
it
should
be
noted
again
that
all
responses
to
this
information
collection
requires
are
voluntary
and
the
submissions
of
annual
reports
are
required
for
only
those
facilities
that
are
accepted
into
the
program.
There
are
expected
benefits
to
those
who
choose
to
participate
in
the
program.
EPA
does
not
expect
a
response
from
any
facility
where
the
burdens
associated
with
preparing
the
response
outweigh
the
expected
benefits
to
the
facility.

It
is
estimated
that
approximately
250
facilities
will
voluntarily
apply
to
the
Environmental
Achievement
Track
annually.
Of
the
250
facilities,
EPA
estimates
that
200
will
be
accepted
to
participate
in
the
program.

The
application
is
estimated
to
take
approximately
40
hours
to
complete.
Post
acceptance
activities
will
include
demonstration
of
compliance,
EMS
documentation
and
reporting,
demonstration
of
continuous
improvement,
reporting,
and
public
outreach.
It
is
estimated
that
these
activities
combined
will
require
approximately
190
hours
per
facility.

The
estimation
for
the
number
of
hours
to
complete
the
application
and
other
required
activities
for
the
Environmental
Achievement
Track
was
based
on
the
StarTrack
program
pilot
project.
During
the
pilot
project,
EPA
asked
seven
facilities
to
submit
an
approximation
of
the
number
of
hours
it
took
to
complete
similar
activities.
EPA
also
requested
information
on
typical
hourly
labor
rates
(
internal
and
external).
In
addition
to
the
StarTrack
pilot
project,
EPA
estimated
the
hourly
labor
rates
of
managerial,
legal,
technical,
and
administrative
professionals
according
to
the
Bureau
of
Labor
Statistics'
National
Occupational
Employment
and
Wage
Data.
The
hourly
labor
rate
estimate
for
EPA
activity
was
obtained
from
the
U.
S.
Office
of
Personnel
1
Based
on
the
2000
General
Schedule
Pay
Chart,
EPA
estimates
an
average
hourly
labor
cost
of
$
36.11
for
technical
staff
responsible
for
EPA
activities
in
the
Environmental
Achievement
Track.
To
derive
hourly
estimates,
EPA
divided
annual
compensation
estimates
by
2,080,
which
is
the
number
of
hours
in
the
federal
work
year.
EPA
then
multiplied
hourly
rates
by
the
standard
government
benefits
multiplication
factor
of
1.6.

13
Management
2000
General
Schedule
Pay
Chart1
6(
b)
Respondent
Costs
(
i)
Estimating
Labor
Costs
EPA
estimates
total
respondent
costs
for
the
number
of
expected
participants
to
be
$
267,000
for
the
application
phase
and
$
1,081,250.00
for
participation
in
the
program.
For
an
individual
facility,
the
application
phase
could
cost
$
1068.00
and
program
participation
could
cost
$
5406.25
(
See
Table
6.1).
Preparing
and
submitting
the
application
is
one­
time
event
and
program
participation
activities
occur
annually
for
the
three
year
program
period.

Table
6.1
uses
the
following
equation
to
obtain
labor
costs:
(
Clerical
Hours
x
$
17/
hour)+
(
Technical
Hours
x
$
54/
hour)+
(
Managerial
Hours
x
$
37/
hour)
=
Labor
Cost/
Year/
Respondent.

As
stated,
cost
estimates
were
derived
from
the
StarTrack
program
pilot
project
and
the
Bureau
of
Labor
Statistics
Data.

Table
6.2
contains
Annual
Respondent
Burden
and
Cost
(
State
Regulatory
Agencies).
It
is
estimated
that
participating
regulatory
agencies
will
spend
10
hours
per
facility
during
the
application
review
phase,
and
2
hours
per
respondent
reviewing
environmental
performance
reports.
This
translates
to
a
cost
to
the
state
of
$
361.10
per
applicant
during
the
application
phase,
and
$
72.22
per
participant
during
a
typical
program
year.
Table
6.2
uses
the
following
equation
to
obtain
labor
costs:
(
Technical
Hours
x
$
36.11/
hour
)=
Labor
Cost/
Year/
Repondent.

It
should
be
noted
that
Table
6.1
does
not
include
those
activities
considered
to
be
customary
business
practices
(
CBP)
14
Table
6.1
Annual
Respondent
Burden
and
Cost
(
Industry)

Information
Collection
Activity
Legal
$
54.00/

Hour
Mgr.

$
37.00/

Hour
Tech.

$
27.00/

Hour
Clerical
$
17.00/

Hour
Resp.
Hours/

Year
Labor
Cost/

year
#
Resp.
Total
Hours/

Year
Total
Cost/

Year
Subtotal
Facility
Hours
Subtotal
Facility
Costs
Subtotal
Total
Hours
Subtotal
Total
Costs
Application
(
Complete
Application
and
Submit
to
EPA)
4
4
16
16
40
$
1068
250
10,00
0
$
267,000
40
$
1068
10,000
$
267,000
Program
Participation
Compliance
Compliance
Audit
Workplan
Compliance
Audit
Report
Submit
Compliance
Letter
0
4
4
0.25
2
4
16
47
0
0.25
0.25
0
16.5
53.25
8
$
445.50
$
1563.25
$
364.00
200
200
200
217
253
208
$
89,100.00
$
312,650.00
$
72,800.00
78
$
2372.75
15,550
$
474,550.00
Document
EMS
Audit
Workplan
Complete
Audit
Implementation
Plan
0
0
0.5
0.25
0
0.5
8
13
18
0.25
0
0
8.5
13
19
$
229.50
$
351.00
$
531.50
200
200
200
209
213
219
$
45,900.00
$
70,200.00
$
106,300.00
41
$
1112.00
8100
$
220,400.00
Performance
Reporting
Selecting
Goals
Demonstration
0
0
4
1
16
16
0.25
0.25
20.25
17.25
$
584.25
$
473.25
200
200
220
217
$
116,850.00
$
94,650.00
38
$
1057.50
7500
$
211,500.00
Public
Outreach
and
Reporting
Outreach
Reporting
0
0
4
4
8
8
4
4
16
16
$
432.00
$
432.00
200
200
216
216
$
86,400.00
$
86,400.00
32
$
864.00
6400
$
172,800.00
Subtotal
8.5
20
150
9.25
187.7
5
$
5406.25
2188
$
1,081,250.00
188
$
5406.25
37,550
$
1,081,250.00
Total
12.5
24
166
25.25
227.7
5
$
6474.25
12,18
8
$
1,348,250.00
228
$
6474.25
47,550
$
1,348,250.00
15
(
ii)
Estimating
Capital
and
Operations
Maintenance
Costs.

Most
of
the
facilities
applying
to
the
Environmental
Achievement
Track
maintain
environmental
compliance
data
as
a
customary
business
practice.
EPA
does
not
expect
any
startup
or
capital
costs
to
affect
applicants
or
participants
in
the
Environmental
Achievement
Track
beyond
those
labor
costs
outlined
in
the
worksheets
in
this
section.

Table
6.2
Annual
Respondent
Burden
and
Cost
(
State
Regulatory
Agencies)

Tech.
$
36.11/
Hour
Respondent
Hours/
Year
Labor
Cost/
Year
Number
of
Respondents
Total
Hours/
Year
Total
Cost/
Year
Application
Environmental
Compliance
Screen
2
2
$
72.22
250
500
$
18,055
Site
visit,
if
necessary
4
4
$
144.44
250
1000
$
36,110
Evaluation
of
Application
4
4
$
144.44
250
1000
$
36,110
Subtotal
(
Application)
10
10
$
361.10
250
2500
$
90,275
Program
Activities
Review
Annual
Environmental
Performance
Report
2
2
$
72.22
200
400
$
14,444
Total
12
12
$
433.32
2900
$
104,719
6(
c)
Estimating
Agency
Burden
and
Cost
Table
6.3
provides
an
estimate
of
the
Annual
Agency
Burden
and
Cost
to
EPA
staff
during
the
application
phase
and
the
program.
The
burden
included
in
the
tables
is
based
primarily
on
EPA's
experience
with
developing,
gathering
information,
and
providing
oversight
and
coordination
for
the
StarTrack
Program.
The
labor
rate
was
developed
using
the
U.
S.
Office
of
Personnel
Management
information
on
general
schedule
pay.

EPA
estimates
it
will
expend
19
hours
per
facility
during
the
application
phase
(
11
without
site
visits),
and
11
hours
reviewing
participants'
annual
environmental
performance
reports.
The
cost
to
the
agency
is
$
686.09
per
applicant
during
the
application
phase
($
397.21
without
site
visits)
,
and
$
397.21
per
participant
during
a
typical
program
year.
16
Table
6.3
Annual
Agency
Burden
and
Cost
Tech.
$
36.11/
Hour
Respondent
Hours/
Year
Labor
Cost/
Year
Number
of
Respondents
Total
Hours/
Year
Total
Cost/
Year
Application
Environmental
Compliance
Screen
2
2
$
72.22
250
500
$
18,055
Site
visit,
if
necessary
8
8
$
288.88
250
2000
$
72,220
Evaluation
of
Application
8
8
$
288.88
250
2000
$
72,220
Notify
Applicant
of
Selection
Status
1
1
$
36.11
250
250
$
9027.50
Subtotal
(
Application)
19
19
$
686.09
250
4750
$
171,522.50
Program
Activities
Review
Annual
Environmental
Performance
Report
11
11
$
397.21
200
2200
$
79,442
Total
30
30
$
1083.30
6950
$
250,964.50
6(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
EPA
estimates
that
250
facilities
will
apply
to
the
Environmental
Achievement
Track
each
year
during
the
period
covered
by
this
ICR.
The
Agency
also
estimates
that
200
applicants
will
be
selected
for
participation
each
year.
EPA
requires
reports
listed
in
section
4(
b)(
I)
of
this
ECR
be
submitted
each
year
by
those
facilities
wishing
to
maintain
their
status
in
the
Environmental
Achievement
Track.
In
Tables
6.1
through
6.3,
the
following
equations
are
applied
using
this
estimated
universe
of
respondents
to
obtain
total
hourly
burden
and
total
cost
estimates:

Hours/
Respondent
x
Total
Number
of
Respondents=
Total
Hours/
Year
Cost/
Respondent
x
Total
Number
of
Respondents
=
Total
Cost/
Year
6(
e)
Bottom
Line
Burden
Hours
and
Cost
Tables
(
i)
Respondent
Tally
See
Table
6.4
below
for
the
total
estimated
respondent
burden
and
cost
summary.
17
Table
6.4
Total
Estimated
Respondent
Burden
and
Cost
Summary
Number
of
Respondents
Number
of
Activities
Total
Hours
Per
Year
Total
Labor
Cost
Per
Year
Application
(
facility)
250
1
10,000
$
267,000
Program
Participation
(
facility)
200
10
37,550
$
1,081,250.00
Application
(
State)
250
3
2500
$
90,275
Program
Activities
(
State)
200
1
400
$
14,444
Total
Burden
900
15
50,450
$
1,452,969.00
(
ii)
Agency
Tally
See
Table
6.5
below
for
the
estimated
Agency
burden
and
cost
summary.

Table
6.5
Total
Estimated
Agency
Burden
and
Cost
Summary
Number
of
Respondents
Number
of
Activities
Total
Hours
Per
Year
Total
Cost
Per
Year
Application
250
4
4750
$
171,522.50
Program
Activities
200
1
2200
$
79,442
Total
450
5
6950
$
250,964.50
(
iii)
Variations
in
the
Annual
Bottom
Line
EPA
does
not
anticipate
significant
variation
(
greater
than
25
percent)
in
the
annual
respondent
reporting
burden
over
the
course
of
the
requested
ICR
period.
The
activities
required
for
the
Environmental
Achievement
Track
will
be
the
same
for
each
respondent
during
each
year
of
participation.
The
only
expected
variation
will
be
that
respondents
who
are
not
accepted
during
the
application
phase
will
not
incur
the
burden
of
the
reporting
phase
since
they
will
not
be
participants
in
the
program.
In
addition,
those
who
are
not
accepted
and
reapply
will
experience
the
burden
of
application
more
than
once.
However,
subsequent
applications
will
not
likely
require
less
resources.

6(
f)
Reasons
for
Change
in
Burden
This
section
does
not
apply
to
this
ICR
since
EPA
is
not
renewing
or
modifying
an
existing
ICR
at
this
time.
18
6(
g)
Burden
Statement
EPA
expects
that
approximately
250
facilities
will
apply
to
the
Environmental
Achievement
Track
annually.
It
is
estimated
that
participating
facilities
will
spend
up
to
40
hours
preparing
the
application.
This
burden
hour
estimate
translates
to
a
cost
of
$
1068
per
facility
and
a
total
cost
to
industry
of
$
267,000
($
1068
x
250
facilities).
EPA
also
estimates
that
200
facilities
may
be
accepted
to
the
program
and
may
need
to
spend
187.75
hours
during
a
typical
year
of
participation
($
5406.25
per
facility
and
a
total
cost
to
industry
of
$
1,081,250.00).
The
burden
hour
estimate
of
the
total
collection
translates
to
a
total
cost
of
$
1,348,250.00.

The
state
regulatory
agencies
may
need
to
spend
up
to
10
hours
annually
reviewing
each
Environmental
Achievement
Track
application.
This
translates
to
a
cost
of
$
361.10
per
facility
and
a
total
cost
of
$
90,275
($
361.10
x
250
facilities).
EPA
also
estimates
that
the
state
may
need
to
spend
approximately
2
hours
per
facility
during
a
typical
year
of
participation.
($
72.22
per
facility
and
a
total
cost
of
$
14,444).
The
burden
hour
estimate
of
the
entire
collection
translates
to
a
total
cost
to
states
of
$
104,719)

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;
adjusting
the
existing
ways
to
comply
with
any
preciously
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.

Send
comments
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
to
Director,
Collection
Strategies
Division,
Information
Strategies
Branch,
U.
S.
Environmental
Protection
Agency
(
2822),
1200
Pennsylvania
Ave.,
N.
W.,
Washington
D.
C.
20460;
and
to
the
Office
of
Information
and
Regulatory
Affairs,
Office
of
Management
and
Budget,
725
17th
Street,
N.
W.
Washington,
D.
C.
20503,
Attention:
Desk
Office
for
EPA.
Include
the
EPA
ICR
number
1949.01
in
any
correspondence.
19
Environmental
Achievement
Track
Environmental
Achievement
Track
Self
Certification
Application
Form
A.
General
Information
1.
Name
of
Facility:

2.
Address:

3.
Contact
Person:

Phone:

Email:

4.
Nature
of
Business
5.
Size
of
Facility
6.
Number
of
Employees
at
Facility
B.
Environmental
Management
System
Every
participant
in
the
Environmental
Achievement
Track
must
have
an
Environmental
Management
System
(
EMS)
in
place
that
contains
the
elements
listed
below.
In
addition,
the
EMS
must
have
been
in
place
for
a
least
one
complete
planning,
implementation,
auditing
and
review,
and
correction
cycle.
The
typical
time
span
for
this
cycle
is
one
year.
Moreover,
applicant
facilities
are
expected
to
have
undergone
a
rigorous
and
objective
self­
assessment
or
a
third
party
assessment
of
their
EMS
to
ensure
that
all
of
the
elements
are
in
place
and
functioning.
Applicants
electing
to
undergo
self­
assessment
are
strongly
encouraged
to
use
an
established
self­
assessment
protocol
such
as
the
GEMI
Environmental
Self­
Assessment
Protocol
or
the
Code
of
Environmental
Management
Principles
Self­
Assessment
Matrix.

Please
indicate
the
method
of
EMS
assessment
that
you
employ.


Self­
Assessment.
Indicate
protocol
used:

GEMI,

CEMP,

other
______________.


Third­
Party
Assessment.
Indicate
type:

ISO
14001
certification,

other
_____________.

Please
verify
that
the
following
elements
are
included
in
your
environmental
management
system.
You
must
be
able
to
check
all
boxes
to
be
eligible
for
the
program.
20

Environmental
Policy
including
compliance
with
legal
requirements
and
commitment
to
pollution
prevention
and
continuous
improvement
in
environmental
performance,
including
areas
not
subject
to
regulation.


Identification
of
significant
environmental
aspects
and
legal
requirements

Active
programs
for
reducing
environmental
impacts,
including
areas
not
subject
to
regulation,
with
documented
results

Top
management
review
of
the
EMS

An
employee
environmental
training
program

Documentation
of
the
environmental
policy,
significant
environmental
aspects,
objectives
and
targets,
top
management
representatives,
and
overall
EMS
authority

Operation
and
maintenance
programs

An
emergency
preparedness
program

Compliance
audit
program

EMS
audit
program

Top
management
review
of
the
EMS
C.
Commitment
to
Continuous
Improvement
in
Environmental
Performance
Has
your
facility
made
improvements
in
three
or
more
of
the
following
categories
with
respect
to
environmental
performance
within
the
current
year
and
preceding
two
years?
Please
check
the
following
categories
that
apply:


Energy
Use

Water
Use

Emissions
of
Key
Air
Pollutants

Chemical
Releases

Waste
Generated

Discharges
to
Water
21

Product
Performance

Restoration/
Preservation
What
additional
categories
of
performance
improvement
is
your
facility
committing
to
report
on
during
the
next
three
years?


Energy
Use

Water
Use

Emissions
of
Key
Air
Pollutants

Chemical
Releases

Waste
Generated

Discharges
to
Water

Product
Performance

Restoration/
Preservation
D.
Public
Outreach
and
Performance
Reporting
Please
answer
yes
or
no
to
the
following
questions.

1.
Does
your
facility
have
a
mechanism
to
identify
and
respond
to
community
concerns
regarding
the
environmental
impacts
of
your
operations?

2.
Does
your
facility
inform
the
local
community
about
issues
related
to
environmental
performance?

3.
Do
you
provide
the
public
with
your
facility's
environmental
performance
information
at
least
annually?

Please
attach
a
short
list
of
community/
local
references
that
would
support
your
application
to
the
Environmental
Achievement
Track.

E.
Record
of
Sustained
Compliance
Every
applicant
to
the
Environmental
Achievement
Track
must
undergo
an
annual
compliance
screen
based
on
the
guidelines
presented
in
the
EPA's
Compliance
Screening
for
Partnership
Programs
Guidance.
