1.	IDENTIFICATION OF THE INFORMATION COLLECTION

	1(a)	Title and Number of the Information Collection Request

	This Information Collection Request (ICR) is entitled "Environmental
Protection Agency Agency information collection activities:  Proposed
collection; Comment Request; Reporting and Recordkeeping Requirements
Under EPA’s Water Efficiency Program," ICR number 2233.01.

	1(b)	Short Characterization

	EPA’s Water Efficiency Program is a voluntary program designed to
create self-sustaining markets for water efficient products and services
via a common label. The program provides incentives for manufacturers to
design, produce, and market water-efficient products. In addition, the
program provides incentives for certified professionals (e.g. certified
auditors, designers, or irrigation installation and maintenance
professionals) to deliver water-efficient services. The program also
encourages consumers and commercial and institutional purchasers of
water-using products and systems to choose water-efficient products and
engage in water-efficient practices. EPA’s Water Efficiency Program
partners with manufacturers, professional certifying organizations,
retailers, utilities, state and local governments, NGOs, developers and
contractors to market and adopt the Water Efficiency Program, and/or
stock or provide  products and services that meet the water-use and
performance specifications developed by the EPA Water Efficiency
Program. The program was developed and is managed by EPA’s Office of
Water (OW). Over the three year ICR period, EPA’s Water Efficiency
Program plans to develop specifications for up to 13 water efficient
products and services, including:

Irrigation and landscaping certification programs

Residential toilets

Residential faucets

Irrigation controllers

Irrigation sensors

Commercial toilets

Commercial faucets

Commercial faucet sensor devices

Drip/micro irrigation equipment

Commercial autoclaves

Commercial medical vacuums

Commercial image processors

“Water efficient” new homes

				

	An organization’s decision to participate in EPA’s Water Efficiency
Program is completely voluntary. Participation begins with the
completion and submittal to EPA of a Partnership Agreement that provides
EPA with general organizational information and the facilities committed
to EPA’s Water Efficiency Program. It is signed by a senior official
that has authority to commit his/her organization to the program and
also is signed by EPA.  

	

	After completing the Partnership Agreement, manufacturers are asked to
submit the New Certified Product Notification Form, appropriate for the
particular category of product (e.g., residential faucets, toilets,
irrigation controllers, irrigation certification program), within 12
months. The form provides information about the products and
certification information. All partners (with the exception of the
certified professionals) are also asked to annually submit a Promotional
Plan Checklist, which is a one-page checklist of planned promotional
activities.

With the exception of certified professionals, EPA’s Water Efficiency
Program asks all partners to submit an Annual Update to inform EPA of
their Program-related activities. Partners are asked to submit results
via the Annual Update in the following areas: EPA’s Water Efficiency
Program labeled products and services, new homes constructed meeting
EPA’s Water Efficiency Program specifications, program promotions, and
product sales information. EPA will use the information collected to
track the progress of the program in transforming the market for water
efficient products and practices, to provide information on labeled
water efficient products and services to consumers, and to recognize
partner accomplishments. 

In year three of the program, EPA will begin an awards program to
recognize significant partner accomplishments. The awards program is
voluntary. Those partners who desire to receive special recognition will
be required to submit an Award Application. EPA plans to encourage
partners to submit all of these forms electronically via the Web site.
It will also make available hard copy forms. 

2.	NEED FOR AND USE OF THE COLLECTION

									

	2(a)	Need and Authority for the Collection

Both the Clean Water Act (CWA) and SDWA have water conservation
provisions and authorities that authorize the EPA’s Water Efficiency
Program as currently described. Section 104(a) and (b) of the CWA
broadly authorizes the Administrator to establish national programs for
the reduction of pollution, which may include cooperation with,
encouragement of, and assistance for public and private efforts to
prevent, reduce, and eliminate pollution. Section 104(o) of the CWA also
authorizes the Administrator to conduct research on methods of reducing
the total flow of sewage, including unnecessary water consumption, which
is a recognition by Congress that water consumption is directly related
to sewage flow and thus to potential water pollution. Section 1442(a)(1)
and (2) of SDWA also provides a source of authority for some aspects of
EPA’s Water Efficiency Program. Those provisions authorize the
Administrator to provide demonstrations relating to the provision of a
dependably safe supply of drinking water. Because both a dependable and
a safe supply of drinking water depend on water availability, water
conservation demonstrations are authorized under these sections.

In January 2003, EPA convened a forum: Closing the Gap: Innovative
Responses for Sustainable Water Infrastructure. At this forum, EPA
highlighted the “Four Pillars of Sustainable Infrastructure”—
better management, full-cost pricing, water efficiency, and watershed
approaches to protection. The Water Efficiency Program is a key element
of EPA’s strategy promote better water management to reduce the need
for costly infrastructure. 

	The 1993 Government Performance and Results Act (GPRA) (PL 103-62)
requires federal agencies to develop plans for what they intend to
accomplish, measure how well they are doing, make appropriate decisions
based on the information they have gathered, and communicate information
about their performance to Congress and to the public. In response, EPA
developed a 5-year Strategic Plan (2003-2008 EPA Strategic Plan)
submitted to Congress on September 30, 2003. Goal 2 of this plan focuses
on ensuring that the nation’s water is both clean and safe. The
National Water Program Guidance: FY 2006 outlines how EPA, States,
Tribes, and others are assuring that the nation’s waters are clean and
safe. One of the key strategies towards this goal highlighted in this
document is creating a new program to increase market demand for
water-efficient products. 

To ensure that agencies develop meaningful performance measures, set
ambitious targets, and link budget expenditures to results, OMB
developed the Program Assessment Rating Tool (PART). PART was designed
to help programs develop and identify meaningful performance measures to
support GPRA reporting. Data collected under this ICR will assist EPA in
completing the PART review process and demonstrating results under GPRA.

		

2(b)	Practical Utility/Users of the Data

	The information collected by EPA’s Water Efficiency Program is not
designed or intended to support regulatory decision-making by OW or
other EPA offices. These data are voluntarily reported by individual EPA
Water Efficiency Program partners. EPA will use information collected
from EPA’s Water Efficiency Program partners for a variety of
purposes, described below:

Partnership Agreement

	EPA will use information submitted in the Partnership Agreement to
officially establish participation in EPA’s Water Efficiency Program
and list partners on the EPA’s Water Efficiency Program Web site. Data
from Partnership Agreements will be entered into a program database that
will serve as a source of general information, assist EPA in tracking
program progress, and provide contact information to allow EPA to keep
partners informed of activities of interest to them.

New Certified Product Notification Form

EPA will use product information submitted by partners to educate and
build awareness among consumers as to which products meet specifications
developed by EPA’s Water Efficiency Program. Information submitted by
partners will be aggregated into a list and posted on EPA’s Water
Efficiency Program Web site. Consumers and institutional purchasers will
be directed to the program Web site to locate model names and numbers of
products and services that meet the Program's specification in various
product and service categories. WaterSense certification bodies will
inform partners when their products have been certified to WaterSense
specifications.

Promotional Plan Checklist

	EPA will use data from the promotional plan to track upcoming efforts,
provide assistance to partners in developing promotional campaigns, and
to coordinate campaigns among partners and EPA efforts.

Annual Update

	EPA will use updated annual data supplied by partners to monitor the
progress of EPA’s Water Efficiency Program in stimulating the supply
of and demand for water efficient products in the market, to determine
the impact of EPA’s Water Efficiency Program on national water
conservation, and to ensure information provided to the public on
labeled products and services is kept current. This information will
also be used to promote the EPA’s Water Efficiency Program and
recognize partner accomplishments.

Award Application Form

	EPA will use information from the award application form to select and
recognize outstanding accomplishments to promote water efficiency and
similar efforts.

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

	3(a)	Nonduplication

	The information to be obtained under this ICR has not been collected by
EPA or any other federal agency. Other nonfederal organizations promote
water conservation, but do not offer a comprehensive program to label
products and services on a national basis. OW is continuing to work with
non-EPA programs to ensure that water conservation promotional efforts
build on each other rather than duplicate efforts.			

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

	EPA requested public comments on this collection on August 4, 2006;
71FR44277. 

	

	EPA received only one comment on this data collection effort. The
commentor was highly supportive of the program and requested only that
it be made clear in the Abstract and Burden Statement that the awards
program itself is voluntary and that program partners will not be
required to participate in this feature of the program.

	3(c)	Consultations

		

	EPA’s Water Efficiency Program staff asked potential stakeholders to
review the requested information. The following stakeholders provided
input:

Dana Lonn

The Toro Company

Jill Hoyenga

Eugene Power and Water

Pete DeMarco

American Standard, Inc.

Tom Penning

Irrometer

John Koeller

Koeller and Company

			

	3(d)	Effects of Less Frequent Collection

The Partnership Agreement is a one-time information submittal for
organizations that wish to participate in EPA’s Water Efficiency
Program as partners. Less frequent collection of this data is not
feasible. Manufacturers are asked to submit a Certified New Product
Notification Form for each product. Less frequent collection of this
information is not feasible.  

All partners (with the exception of the certified professionals) are
asked to submit Promotional Plan Checklists annually to inform EPA of
planned efforts. Requesting this information less frequently is not
feasible as partners would not have promotions planned years in advance.


Partners (with the exception of the certified professionals) submit the
Annual Update to inform EPA of their Program-related activities.
Recognizing and promoting water efficient products and innovative
product development is important to show consumers that simple everyday
decisions, including purchasing EPA’s Water Efficiency Program-labeled
products that perform as well as or better than their less efficient
counterparts, can have a positive impact on the environment and save
money on utility bills. Partners are asked to submit results via the
Annual Update in the following areas: labeled products, qualified new
homes constructed, and product sales information. Requesting this
information less frequently would hinder Agency efforts to generate
relevant and timely case studies, provide up-to-date information on
labeled products and services to the public, and assess program results
that are helpful to participants. It also would hinder the ability of
the Agency to review the activities by individual organizations and the
program as a whole and to gain the information necessary to publicly
recognize significant partner water efficient activities. 

The Award Application is requested for partners desiring additional
recognition. Less frequent collection would hinder EPA efforts to
provide timely recognition of partner achievements.

	3(e)	General Guidelines

	All of the collection activities described within this ICR fall within
OMB’s General Guidelines.

	3(f)	Confidentiality

	Partners may claim information submitted to certify products or
services as confidential business information.  Any information so claim
will be safeguarded from public disclosure.

	3(g)	Sensitive Questions

	

	No questions of a sensitive nature are asked in any of the forms.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

	4(a)	Respondents and NAICS Codes

	Respondents will consist of all EPA’s Water Efficiency Program
partners. EPA’s Water Efficiency Program anticipates partners will
include product manufacturers, professional certifying organizations,
certified professionals, service providers, businesses, institutions,
retailers, distributors, utilities, state and local government,
plumbers, developers, contractors, architects, landscapers, irrigation
professionals and NGO’s. 

 	NAICS codes for likely manufacturing partners include: 

NAICS Code	2002 NAICS U.S. Title	Index Entry

  HYPERLINK "http://www.census.gov/epcd/naics02/def/ND332998.HTM" 332998
	Enameled Iron and Metal Sanitary Ware Manufacturing	Toilet fixtures,
metal, manufacturing

  HYPERLINK "http://www.census.gov/epcd/naics02/def/ND326191.HTM" 326191
	Plastics Plumbing Fixture Manufacturing	Toilet fixtures, plastics,
manufacturing

  HYPERLINK "http://www.census.gov/epcd/naics02/def/ND332913.HTM" 332913
	Plumbing Fixture Fitting and Trim Manufacturing	Faucets, plumbing,
manufacturing

  HYPERLINK "http://www.census.gov/epcd/naics02/def/ND221310.HTM" 221310
	Water Supply and Irrigation Systems	Irrigation system operation

  HYPERLINK "http://www.census.gov/epcd/naics02/def/ND339114.HTM" 339114
	Dental Equipment and Supplies Manufacturing 	Autoclaves, dental,
manufacturing

  HYPERLINK "http://www.census.gov/epcd/naics02/def/ND339111.HTM" 339111
	Laboratory Apparatus and Furniture Manufacturing	Autoclaves,
laboratory-type (except dental), manufacturing

  HYPERLINK "http://www.census.gov/epcd/naics02/def/ND236116.HTM" 236116
	New Multifamily Housing Construction (except Operative Builders)	Home
builders (except operative), multifamily

  HYPERLINK "http://www.census.gov/epcd/naics02/def/ND236115.HTM" 236115
	New Single-Family Housing Construction (except Operative Builders)	Home
builders (except operative), single-family

  HYPERLINK "http://www.census.gov/epcd/naics02/def/ND236117.HTM" 236117
	New Housing Operative Builders	Home builders, operative



4(b)	Information Requested

	Once a prospective partner organization reviews EPA’s Water
Efficiency Program materials and decides to join the program, it will
submit a Partnership Agreement (Attachment 2). Within 12 months of
registering, manufacturers will be asked to complete a New Certified
Product Notification Form (Attachment 3) to provide EPA’s Water
Efficiency Program with information on water efficient products. EPA
also asks partners to submit a Promotional Plan Checklist, Annual
Update, and Award Application (voluntarily at the Partners discretion).
These documents are included in Attachment 4-5.)

Partnership Agreement 

	

	Program participants complete and submit to EPA a two-page Partnership
Agreement appropriate to their partnership category that provides basic
organization information.

							

	(i)	Data items:

	The reporting items include:

	•	Organization name.

	•	Name, title, address, county, postal code, phone number, fax
number, e-mail address, and primary function (choose from a list of
five) of the partner’s primary contact person.

	•	Approximate number of employees at the joining organization.

	•	How the member heard about the EPA’s Water Efficiency Program
(choose from a list of six).

	•	Signature, name, and title of senior official and the date signed.

	(ii)	Respondent activities:

	Participants conduct the following activities in order to complete and
submit the Partnership Agreement:

	•	Review the EPA’s Water Efficiency Program Web site, brochure,
agreement, and other necessary materials.

	•	Select a primary contact person for the EPA’s Water Efficiency
Program.

	•	Complete the Partnership Agreement, including obtaining the
signature of a senior official.

	•	Send the completed form to EPA via fax, mail, or online.

New Certified Product Notification Form

	Within 12 months of joining EPA’s Water Efficiency Program,
manufacturing partners should complete and submit to EPA a New Certified
Product Certification Form. This form is filled out upon successful
completion of third-party testing of product(s) to an EPA Water
Efficiency Program specification, and approval of a WaterSense
certification body.

Data items: 

The reporting items include:

Manufacturer Information (e.g., manufacturer name; name, phone number,
fax, and e-mail address.)

Product Information (e.g., brand name, model name, model number, product
URL, product, category, name of certifying body, certification ID
number, date of certification)

	(ii)	Respondent activities:

	Participants conduct the following activities in order to complete and
submit the New Certified Product Application Form:

Complete the New Certified Product Application Form upon receipt of
certification from the WaterSense certification body.

Send the completed form to EPA via fax, mail, or online.

Promotional Plan Checklist

On an annual basis, partners (with the exception of certified
professionals) complete submit a one-page checklist describing upcoming
promotional efforts. 

Data items: 

The reporting items include: 

Current and planned promotional efforts.

Planned uses of WaterSense program logo.

Identification of areas where EPA could assist in future promotional
efforts



Respondent Activities	

Identify planned promotional activities.

Review instructions

Complete the checklist.

Send the completed checklist to EPA via fax, mail or online.

Annual Update

	Program participants complete and submit to EPA a standard Annual
Update that describes the participant's Program-related activities. The
Annual Updates may contain both descriptive information and quantified
results. 

	(i)	Data items:

	The reporting items include:

	•	Participant Information (e.g., organization name, name, phone
number, and email address of the partner’s primary contact person.)

	•	Current Water Efficient Products, Services, and Activities

		

		As applicable:

		 

For manufacturers: Listing of the product name, make, and model, date of
market launch, number of products shipped, sale information (option to
provide data confidentially to a third party).

For professional certifying organizations, names of professionals
certified in delivery of water efficient services.

For businesses/institutions, number of EPA’s Water Efficiency Program
labeled products purchased, estimated total annual water savings

For builders, number of new homes constructed meeting EPA Water
Efficiency Program specifications.

				

For utilities, gallons of water sold per year, price of units/gallons,
rebate information.

For retailers, geographic area in which products were sold, estimated
marketshare of EPA’s Water Efficiency Program product compared with
conventional product.

		

Signature and title of principal contact and date.

	EPA’s Water Efficiency Program assumes that this information is kept
as a common business practice by participants. Therefore, burden
associated with recordkeeping is not included in this ICR.

						

	(ii)	Respondent activities:

	Participants conduct the following activities in order to complete and
submit the Annual Update:

Collect and review records to assess product and service information,
water efficiency sales, and rebate data.

Review instructions for completing the annual update.

			

•	Complete the Annual Update, including obtaining the signature of the
principal contact.

	•	Send the completed form to EPA via fax, mail, or online.

	•	Respond to EPA questions to clarify data.

Award Application

	Partners who wish to receive additional recognition will submit award
application forms for products and/or services they provided that
promote water efficient or water conservation efforts or adhere to water
efficient guidelines. These applications will be used to recognize
outstanding accomplishments in each award category. Submission of this
application is strictly voluntary: partners only need to complete an
Award Application form if they wish to be considered for an award. 

	

Data items:

The application items include:

	•	Participant Information (e.g., organization name, name, phone
number, and email address of the partner’s primary contact person.)

Award Information (e.g., category, products or services, qualifications)

Respondent activities:

Participants conduct the following activities in order to complete and
submit the Awards Application:

Review instructions and eligibility requirements.

Collect and review records to assess product or service information
during reporting year that qualify for an award.

Determine which categories would be the best fit for each product or
service.

Complete Award Application, including developing supplemental materials
and obtaining the signature of the principal contact. 

Send the completed application to EPA via fax, mail, or online.

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

	5(a)	Agency Activities

	EPA’s Water Efficiency Program will require EPA to engage in the
following activities related to the Partnership Agreement, New Certified
Product Notification Form, Promotional Plan Checklist, Annual Update,
and Award Application:

Partnership Agreement 

	•	Develop Partner Agreement template and post to the EPA Web site.

	•	Answer questions posed by potential participants regarding
membership in the program.

	•	Review completed agreements, record/enter information into a
database, and EPA’s Water Efficiency Program Web site.

	•	Sign agreement.

Respond to the Partner to welcome them to the Program or explain why
partnership could not be accepted.

New Certified Product Notification Form

Develop notification form.

Disseminate form to partners via the EPA’s Water Efficiency Program
Web site.

Answer partner questions about information to be submitted.

Review completed forms submitted by partners.

Respond to partner to inform them that the form has been accepted, or to
explain why it could not be accepted.

Enter data into program database.

Compile list of labeled products and services by category to post on
EPA’s Water Efficiency Program Web site.

Disseminate updated lists as needed.

Promotional Plan Checklist

Develop checklist to be submitted by partners.

Disseminate checklist to partners via the EPA’s Water Efficiency
Program Web site.

Answer partner questions about information to be submitted.

Review completed checklist submitted by partner.

Respond to partner.

Enter data into program database.

Annual Update

	•	Maintain a tracking system and develop/revise standard data
reports.

	•	Answer questions regarding the Annual Update.

	•	Receive and review the annual update for consistency and
completeness and place any follow-up calls necessary.

			

	•	Record/enter information into a database.



	•	Develop and make publicly available an annual summary of EPA’s
Water Efficiency Program partners’ activities, promotions, market
trends, and sales information.

Award Application 

Maintain a record of each participant’s award application status. 

Develop the Award Application and post it to the EPA Water Efficiency
Web site.

Respond to partner questions about award applications.

Determine which applications deserve recognition.

Provide recognition through website, award ceremony or other means.

5(b)	Collection Methodology and Management

	In collecting and analyzing the information associated with this ICR,
EPA uses a telephone system, personal computers, and database software.
EPA ensures the reasonableness and completeness of collected information
by reviewing each submittal. EPA enters the information obtained from
the three forms into a database. 

	EPA plans to offer all information collection instruments in hard copy
and electronically. Electronic submissions do not have a significant
impact on respondent or Agency burden.

	5(c)	Small Entity Flexibility

	All data collected under this ICR are voluntarily reported. EPA expects
that some of the participants in the EPA’s Water Efficiency Program
will be small entities. EPA has designed its reporting materials to
minimize respondent burden while obtaining sufficient and accurate
information. 

	5(d)	Collection Schedule

 

	Organizations may submit Partnership Agreement s to join the EPA’s
Water Efficiency Program at any time. Partners may submit a New
Certified Product Notification Form as needed to certify their products.
Partners will submit Promotional Plan Checklists and Annual Updates to
EPA every year that the partner participates in the program. During Year
3 of the program, partners who submit an Annual Update may submit one or
more Award Applications for review and possible recognition by EPA.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

	6(a)	Estimating Respondent Burden

	EPA used input from potential partners and its experience implementing
other voluntary programs to estimate burden estimates for respondents.
Exhibit 1 presents the burden hours and costs per respondent as well as
for all respondents during each of the three years covered under this
ICR. 

	6(b)	Estimating Respondent Costs

	Exhibit 1 presents the estimated annual respondent costs for
information collection activities associated with EPA’s Water
Efficiency Program. The estimated annual respondent costs are discussed
below.

	Estimating Labor Costs

The labor rates used to determine the estimated costs to respondents are
consistent with the hourly wage rates published by the Bureau of Labor
Statistics publications on employment and earnings. Rates include the
cost of overhead and fringe benefits. EPA estimates an average
respondent hourly labor rate (hourly plus overhead) of $79.49 for
managerial staff, $64.80 for technical staff, and $34.86 for clerical
staff.

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

EPA will encourage partners to submit materials electronically and also
retain materials in electronic format to conserve paper. For this
reason, EPA estimates minimal copying, faxing, and mailing costs ($22
per partner, plus an additional $35 if applying for an award).
Manufacturers wishing to label products will incur an average of $897
per product to engage independent testing organizations to perform
product testing they certify to EPA Water Efficiency Program
specifications. Service providers will need to demonstrate that their
products conform to EPA Water Efficiency Program specifications through
an independent review process.

6(c)	Estimating Agency Burden and Costs

	EPA used its experience implementing other voluntary programs to
estimate burden estimates for Agency staff. Exhibit 2 presents the
burden hours and costs per respondent as well as for all respondents
during each of the three years covered under this ICR. The hourly labor
rates used to determine the estimated costs to the Agency are consistent
with annual labor rates published in the Federal Register and are based
on the 2004 GS pay schedule available from the Office of Personnel
Management. EPA estimates an average hourly labor cost of $62.91 for
managerial staff; $46.11 for technical staff; and $18.51 for clerical
staff. The labor costs are based on the following GS levels and steps:
managerial rates were based on GS Level 14, Step 4; technical labor
rates were based on GS Level 12 Step 5; and clerical labor rates were
based on GS Level 5, Step 1. To derive hourly estimates, EPA divided
annual compensation by 2,080—the number of hours in the Federal
work-year. EPA then multiplied hourly rates by the standard government
overhead factor of 1.6.

EPA anticipates communicating with partners electronically rather than
mailing paper, so we have included minimal photocopying and postage
costs.

Exhibit 2 shows the aggregate annual Agency burden and costs for the
information collection activities associated with EPA’s Water
Efficiency Program. The annual burden to the Agency is approximately
16,441 hours, at a cost of approximately $639,446. The three-year,
bottom-line burden for the life of this ICR is therefore 49,323 hours
and $1,918,338.

6(d)	Estimating the Respondent Universe and Total Burden and Costs

	The universe of each respondent activity varies depending upon the
specific activity. The respondent universe for each information
collection activity associated with EPA Water Efficiency Program is
presented and explained separately below. 

	Partnership Agreement

EPA estimates that 3,800 partners will join the program in the first
year; 5,000 in the second year; and 6,200 in the third year of the
program, for an average of 5,000 partners per year. EPA estimates that
certified professionals will comprise the vast majority of partnerships.
For other partner categories, EPA anticipates welcoming 100 partners in
the first year, 75 in the second year, and 125 in the third year.

	New Certified Product Notification Form

During the three-year period covered by this ICR, EPA anticipates
developing specifications for 13 categories of products. Each product
category has specific information that must be submitted by partners who
desire to label their product(s). EPA anticipates that manufacturers
will submit a total of 450 products for certification in the 13
categories over the first 3 years of the program. This translates to 150
products annually. Of the 450 total applications, EPA anticipates
updating the Web registry of labeled products and services on a monthly
basis. 

	Promotional Plan Checklist

With an exception for certified professionals, EPA plans to request
submission of one Promotional Plan Checklist per partner for each year
the partner participates in the program. Thus, EPA anticipates receiving
100 promotional plans in the first year, 175 in the second and 300 in
the third for an average of 192 per year.

Annual Update 

With an exception for certified professionals, EPA plans to require
submission of one Annual Update per partner for each year the partner
participates in the program. Thus, EPA anticipates receiving 100 Annual
Updates in the first year, 175 in the second and 300 in the third for an
average of 192 per year.

	

Award Application

EPA plans to initiate an awards program by the third year of the Water
Efficiency Program. Based on the popularity of other EPA awards
programs, EPA anticipates receiving 100 applications during the first
round of award applications.

Total Burden and Costs

Exhibit 1 shows the aggregate annual respondent burden and costs for the
information collection activities associates with EPA’s Water
Efficiency Program. Estimated respondent burden hours are presented on a
per respondent basis for the information collected under the Partnership
Agreement, Promotional Plan Checklist, Annual Update and Award
Application, and on a per product/service basis for the New Certified
Product Notification Form. The annual burden to the universe of
respondents is approximately 50,081 hours, at a cost of approximately
$3,371,827. The three-year, bottom-line burden for the life of this ICR
is therefore 150,243 hours and $10,115,418.

EPA expects respondents from individuals (i.e., certified
professionals), private sector businesses, and state and local
governments. Apart from the annual 5,000 partnership agreements from
individuals, EPA estimates that one-third of the respondents will be
state and local governments and two-thirds will be private sector
businesses. Table 1 summarizes the total estimated annual burden over
three years. Table 2 summarizes the total estimated annual and three
year costs by sector.

Table 1: Total Estimated Annual Respondents and Burden Hours (Annual and
Three-Year) by Sector

Respondents	Respondents/Year	Burden Hours/Year	Respondents over Three
Years	Total Burden Hours over Three Years

State, local, and tribal government	214	3,360	642	10,080

Private Sector	427	6,721	1,281	20,163

Individuals		5,000	40,000	15,000	120,000



Table 2: Total Estimated Annual and Three-Year Costs by Sector

Respondents	Total Labor Costs/Year	Total Capital/O&M Costs/Year	Total
Costs/Year	Total Costs over Three Years

State, local, and tribal government	$218,120	$2,117	$220,237	$660,711

Private sector	$436,283	$123,286	$559,569	$1,678,707

Individuals	$2,592,000	$0	$2,592,000	$7,776,000



	6(e)	Bottom Line Burden Hours and Costs Tables

Table 3 summarizes the total estimated annual burden hours and costs for
respondents and for the Agency. The total cost for respondents is
$3,371,827 and the hourly burden is approximately 50,081 hours. The
total cost for the Agency is $639,446 and the hourly burden is
approximately 16,441 hours. Table 3 displays these combined estimates,
as well as the grand total of $4,011,273 and the hourly burden of
approximately 66,522 hours for all information collection activities
under EPA’s Water Efficiency Program.

Table 3: Total Estimated Burden Hours and Costs for Respondents and EPA

	Burden Hours	Total Labor Costs/Year	Total Nonlabor Costs/Year	Total
Cost

Respondents	50,081	$3,246,424	$125,403	$3,371,827

Agency	16,441	$624,549	$14,897	$639,446

Total	66,522	$3,870,973	$140,300	$4,011,273



6(f)	Reasons for Change in Burden

This ICR does not modify an existing ICR.

6(g)	Burden Statement

The estimated average annual respondent reporting and recordkeeping
burden for this collection of information is 89 hours. The respondent
reporting burden for each information collection activity for EPA’s
Water Efficiency Program is presented separately below. Partner
participation in the program is completely voluntary, and thus the
entire reporting and recordkeeping burden will be incurred by partners
that voluntarily choose to participate in the Water Efficiency Program.

Partnership Agreement

The reporting burden for information collection requirements associated
with completing the Partnership Agreement for each respondent is
estimated to be 8 hours. This estimate includes times for reviewing the
instructions on the Partnership Agreement, completing and reviewing the
information requested, and submitting it. 

	New Certified Product Notification Form

The reporting burden for information collection requirements associated
with completing the New Certified Product Notification Form for product
or service submitted by a respondent is estimated to be 21 hours. This
estimate includes third-party testing, assembling the data into a report
format, reviewing it and submitting it.

	Promotional Plan Checklist

The reporting burden for information collection requirements associated
with the Promotional Plan Checklist is estimated to be 13 hours. This
estimate includes identifying promotional activities, reviewing the
instructions, completing the form, and submitting it to EPA.

	Annual Update

The reporting burden for information collection requirements associated
with the Annual Update is 18 hours. This estimate includes gathering
data such as product sales, number of products purchased, number of
rebates issued, gallons of water sold; compiling this information, and
submitting it to EPA (or third party for confidential sales data). 

Awards Application

The reporting burden for information collection requirements associated
with the Awards Application for each respondent is estimated to be 21
hours. This estimate includes reviewing the eligibility requirements and
instruction on the application, gathering data and information for
submission, completing the application, reviewing the information and
narrative description required, and submitting the application to EPA. 

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

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 No
EPA-HQ-OW-2006-0408, which is available for public viewing at the Office
of Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334,
1301 Constitution Ave., NW, Washington, DC. 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 Office of Water Docket
is (202) 566-2426. Use www.regulations.gov to obtain a copy of the draft
collection of information, submit or view public comments, access the
index listing of the contents of the docket, and to access those
documents in the public docket that are available electronically. Once
in the system, select “search,” then key in the docket ID number
EPA-HQ-OW-2006-0408.

Exhibit 1: Estimated Respondent Burden

Information Collection Activity	Hours and Costs Per Respondent/Labeled
Product

	Total Hours and Costs



Manager	Technical	Clerical	Respond Hours/Year	Labor Costs per Year
Annual Capital Startup Costs	Annual O&M Costs	No. of Respond./
Activities	Total Respond. Hours/Year	Total Cost/Year

Hourly Rate	79.49	64.8	34.86







	Partnership Agreement











Review the EPA Water Efficiency Web site, brochure, agreement, and other
necessary materials	1	2	0	3	$209

	100	300	$20,909

Select a primary contact person for the program	1	0	0	1	$79

	100	100	$7,949

Complete the PA, obtain signature of senior official	0.5	1.5	1	3	$172

$5.00	100	300	$17,681

Send the completed agreement to EPA via fax, mail, or online	0	0	1	1	$35

$5.00	100	100	$3,986

Subtotal	2.5	3.5	2	8	$495



800	$50,525

Partnership Agreement: Certified Professionals











Review the EPA Water Efficiency Web site, brochure, agreement, and other
necessary materials	0	4	0	4	$259

	5000	20,000	$1,296,000

Complete the PA	0	3	0	3	$194

	5000	15,000	$972,000

Send the completed agreement to EPA via fax, mail, or online	0	1	0	1	$65

	5000	5,000	$324,000

Subtotal	0	8	0	8	$518



40,000	$2,592,000

New Certified Product Notification Form 











Apply for label from certification board	1	8	0	9	$598	$897.33	$50.00
125.67	1,131	$194,188

Collect records of each service or product	0	2	0	2	$130

$5.00	125.67	251	$16,915

Select a primary contact person for questions from EPA's Water
Efficiency Team	1	1	0	2	$144

	125.67	251	$18,133

Complete the Product or Service Application 	1	6	0	7	$468

	125.67	880	$58,850

Send the completed application to EPA via fax, mail, or online	0	0	1	1
$35

$10.00	125.67	126	$5,638

Subtotal	3	17	1	21	$1,375



2,639	$293,723



Promotional Plan 











Identify planned promotional activities	2	8	0	10	$677

	191.67	1,917	$129,833

Review instructions  	0	1	0	1	$65

	191.67	192	$12,420

Complete the checklist	0	1	0	1	$65

	191.67	192	$12,420

Send the completed checklist to EPA via fax, mail or online	0	0	1	1	$35

$2.00	191.67	192	$7,065

Subtotal	2	10	1	13	$842



2,492	$161,739

Annual Updates











Collect and review records to assess product information, purchased
prodcuts or services, rebate informationduring the reporting year	1	10	0
11	$727

	191.67	2,108	$139,438

Review Instructions	0	1	0	1	$65

	191.67	192	$12,420

Complete the Annual Update	1	3	0	4	$274

$5.00	191.67	767	$53,455

Send the completed update to EPA via fax, mail, or online	0	0	1	1	$35

$5.00	191.67	192	$7,640

Respond to EPA questions to clarify data	0	1	0	1	$65

	191.67	192	$12,420

Subtotal	2	15	1	18	$1,166



3,450	$225,373

Award Applications











Review instructions and eligibility requirements	1	1	0	2	$144

	33.33	67	$4,810

Gather data and determine award category	2	5	0	7	$483

$5.00	33.33	233	$16,266

Complete application and supplemental materials	3	8	0	11	$757

$10.00	33.33	367	$25,562

Submit the application via fax, mail, or online	0	0	1	1	$35

$20.00	33.33	33	$1,829

Subtotal	6	14	1	21	$1,419



700	$48,467

TOTAL	15.5	67.5	6	89	$5,815

	5,642	50,081	$3,371,827



Exhibit 2: Estimated Agency Burden

Information Collection Activity	Hours and Costs Per Respondent/Labeled
Product

	Total Hours and Costs



Manager	Technical	Clerical	Respond Hours/Year	Labor Costs per Year
Annual Capital Startup Costs	Annual O&M Costs	No. of Respond./
Activities	Total Respond. Hours/Year	Total Cost/Year

Hourly Rate	62.91	46.11	18.51







	Partnership Agreement











Develop Partnership Agreements and post to Web site	2	6	0.5	8.5	$412

	8	68	$3,294

Answer questions posed by potential participants regarding membership in
the program.	0	2	0	2	$92

	100	200	$9,222

Review completed agreements, record/enter information into a database,
and EPA’s Water Efficiency Program Web site	1	4	4	9	$321

	100	900	$32,139

Sign agreement	0.5	0.5	1	2	$73

$2.00	5100	10,200	$382,602

Subtotal	3.5	12.5	5.5	21.5	$898



11,368	$427,257

New Certified Product Notification Form 











Develop application materials to be submitted by partners and post to
Web site	2	8	0	10	$495

	13	130	$6,431

Review completed applications submitted by partner	0.5	2	0	2.5	$124

$5.00	125.67	314	$16,171

Enter data into program database	0	1	2	3	$83

	125.67	377	$10,447

Compile list of products by product type to post on EPA’s Water
Efficiency Program Web site	0	4	0	4	$184

	125.67	503	$23,179

Disseminate updated list as requested	0	1	2	3	$83

$20.00	125.67	377	$12,960

Subtotal	2.5	16	4	22.5	$969



1,701	$69,188



Promotional Plan Checklist 











Develop checklist to be submitted by partners and post to Web site	1	4	2
7	$284

	1	7	$284

Answer partner questions about information to be submitted	0	2	0	2	$92

$2.00	191.67	383	$18,059

Review completed checklist submitted by partner	0	2	0	2	$92

$1.00	191.67	383	$17,867

Enter data into program database	0	1	1	2	$65

	191.67	383	$12,386

Subtotal	1	9	3	13	$533



1,157	$48,597

Annual Updates











Maintain a tracking system and develop/revise standard data reports	10
40	10	60	$2,659

	1	60	$2,659

Answer questions regarding the Annual Update	0	2	0	2	$92

$2.00	191.67	383	$18,059

Receive and review the plans for consistency and completeness and place
any follow-up calls necessary	1	3	0	4	$201

$1.00	191.67	767	$38,763

Record/enter information into a database	0	0	2	2	$37

	191.67	383	$7,096

Develop annual data summary	10	100	20	130	$5,610

$5.00	1	130	$5,615

Subtotal	21	145	32	198	$8,599



1,723	$72,192

Award Applications











Maintain a tracking system to record each participant’s award
application status	0	20	5	25	$1,015

	1	25	$1,015

Develop application to be submitted by partners and post to Web site	0	2
0	2	$92

	33	67	$3,074

Respond to partner questions about award applications	2	8	2	12	$532

$2.00	33	400	$17,791

Determine which applications deserve recognition	0	0	0	0	$0

$10.00	33	0	$333

Subtotal	2	30	7	39	$1,639



492	$22,213

TOTAL	30	212.5	51.5	294	$12,639



16,441	$639,446



