Date:               April 20, 2015 

From:            	Brian Clapp/DC/USEPA/US 

To (bcc):        	Mark Rossolo, UL                                          mark.rossolo@ul.com
                       	Jessica Evans, NSF                                        jevans@nsf.org
                       	Mark Petruzzi, Green Seal                             mpetruzzi@greenseal.org
                       	Brad Miller, BIFMA                                      bmiller@bifma.org
                       	Dean Thompson, Resilient Floor Coverings dean.thompson@rfci.com
                       	Bridgett Luther, Cradle to Cradle                  bridgett@c2certified.org
                       	Robert Frisbee, Green Electronics Council   rfrisbee@greenelectronicscouncil.org
                       	Steve Mawn, ASTM                                      smawn@astm.org
                       	Anne Calas, ANSI                                         acaldas@ansi.org

            
            Subject: Request for Assistance; "Assessment of Environmental Performance Standards and Ecolabels for Federal Procurement" ICR
            

On March 19, 2015, EPA published a Notice in the Federal Register (80 FR 06275) titled "Agency Information Collection Activities; Proposals, Submissions, and Approvals: Assessment of Environmental Performance Standards and Ecolabels for Federal Procurement; EPA ICR No. 2516.01, OMB Control No. 2070-new." (See http://www.regulations.gov/#!documentDetail;D=EPA-HQ-OPPT-2014-0838-0001) This Notice refers to EPA's intention to request new Office of Management and Budget (OMB) clearance of an information collection related to the assessment of environmental performance standards and ecolabels for Federal procurement.

In addition to public notice and comment requirement that the above Notice initiates, OMB regulations at 5 CFR 1320.8(d)(1)) require agencies to consult with potential respondents and data users about specific aspects of an information collection request (ICR) before submitting it to OMB for review and approval, regardless, in the case of ICR renewals, of whether changes have or have not been made to the collection activity.

As part of this required consultation, I am contacting you to solicit your input.  Please note that if you take this opportunity to provide input, your name, affiliation, e-mail address, phone number and any information you provide (e.g., copies of e-mails) will be incorporated and attached to the ICR supporting statement, which will be a public document.  In addition, the OMB Desk Examiner for the ICR in question may contact you to verify the accuracy of any comments EPA identifies in the ICR.

EPA solicits your input on the following questions:

Are the data that EPA seeks under this ICR available from any public source, or already collected by another EPA office or by another agency?  If so, where can the data be found?

Is it clear what is required for data submission?  If not, are there any suggestions for clarifying instructions?  

Would you be interested in an electronic/data submission option?  What type of alternative would you be most likely to utilize  -  web form, diskette, CD-ROM?   

For electronic submission, how should signature requirements be handled  -  Private Key Infrastructure, PINS and passwords, signed paper cover sheet?  

Do you agree with EPA's estimated burden and costs (the ICR addresses only the costs associated with paperwork)?  Are the Bureau of Labor Statistics (BLS) labor rates accurate?  If you have any reason to consider the BLS labor rates as used by EPA inaccurate or inappropriate, explain your rationale.

To access the Federal Register Notice, the ICR supporting document, and any public comments received to date, go to: 
o www.regulations.gov/ 
o enter EPA-HQ-OPPT-2014-0838 in the Enter Keyword or ID field
o click on "Search"
o then click on any of the documents listed within the docket to read the document; you will be most interested in the Supporting Statement, identified by its title beginning "Information Collection Request..."

Your response will be greatly appreciated.  If you have any comments in response to the above questions, or with respect to any other part of the information collection, please respond by return e-mail by May 18, 2015.  EPA will consider those responses, as well as any public comment received in response to the Federal Register Notice identified above, in preparing a final document for OMB review.

Thank you for your assistance. 

Sincerely yours,

Brian Clapp, Environmental Protection Specialist
Chemistry, Economics, and Sustainable Strategies Division
Office of Pollution Prevention and Toxics/Office of Chemical Safety and Pollution Prevention Environmental Protection Agency
Washington, DC 20460
202-564-8838


