1.	IDENTIFICATION OF THE INFORMATION COLLECTION

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

	This Information Collection Request (ICR) is entitled “EPA’s
WaterSense Program (Renewal)” ICR number 2040-0272, Agency No.
2233.04.

	1(b)	Short Characterization

	WaterSense 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 irrigation
auditors, designers, or 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. WaterSense partners with manufacturers, professional
certifying organizations, retailers and distributors, and promotional
partners (e.g. utilities; federal, state, and local governments;
non-governmental organizations (NGOs)) to market and adopt WaterSense,
and/or stock or provide products and services that meet the water-use
and performance specifications developed by WaterSense. The program was
developed and is managed by EPA’s Office of Water (OW). To date, the
program has developed specifications for the following
products/services: 

Irrigation certification programs

Residential toilets

Residential faucets

Flushing urinals

Over the three year ICR period, WaterSense plans to develop
specifications for up to 11 water efficient products and services,
including:

Water-efficient single-family new homes

Showerheads

Weather- or sensor-based irrigation control technology

Pre-rinse spray valves

Flushometer toilets

Water softeners

Steam sterilizers

Cage, rack, and glassware washers

Multi-spray, multi-trajectory, rotating sprinklers

Rain sensors

Microirrigation

	An organization’s decision to participate in WaterSense is completely
voluntary. Participation begins with the completion and submittal to EPA
of a Partnership Agreement that provides EPA with general information
about the organization and its facilities committed to WaterSense. It is
signed by a senior official that has authority to commit his/her
organization to the program and also is signed by EPA. Individual
certified professionals (e.g., irrigation partners) also complete a
Partnership Agreement to join the program.

	

	Within 12 months of 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). The form provides information
about the products that have earned the WaterSense label and their
certification information.

WaterSense currently asks all organizational partners to submit an
Annual Reporting Form to inform EPA of their program-related activities.
WaterSense plans to ask irrigation partners and professional certifying
organizations to submit their first Annual Reporting Form within the
next three years. Partners are asked to submit results via the Annual
Reporting Form in the following areas: WaterSense labeled products,
services, and new homes; marketing efforts; and product sales and
shipment information. EPA uses 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. 

EPA offers an awards program to recognize significant WaterSense
partners’ and other deserving applicants’ accomplishments.
Participation in the awards program is voluntary. Those parties who
desire to receive special recognition are required to submit an Awards
Application. EPA encourages applicants to submit forms electronically
via the Web site. The Agency will also make hard copy forms available. 

During the next three years, WaterSense will partner with licensed
certification providers, who oversee inspections of new homes to
determine if they meet WaterSense specifications. Each licensed
certification provider will be asked to submit a Provider Quarterly
Reporting Form that includes information about the number and general
location of labeled homes, data collected for each home per the
inspection documentation, and a summary of any issues or concerns
identified during the inspection process. 

To assess progress in educating consumers about the WaterSense program,
EPA will conduct a brief Consumer Awareness Survey of a sample of
consumers two times during the next three years. The purpose of these
surveys will be to obtain information at the national level on consumer
awareness and the understanding of WaterSense, the value accrued to the
label in the eyes of consumers, the influence of the program on
purchasing decisions, satisfaction with labeled products, and determine
which methods of communicating about water efficient-products are most
effective.

2.	NEED FOR AND USE OF THE COLLECTION

									

	2(a)	Need and Authority for the Collection

As part of strategic planning efforts, EPA encourages programs to
develop meaningful performance measures, set ambitious targets, and link
budget expenditures to results. Data collected under this ICR will
assist WaterSense to demonstrate results under and carry out evaluation
efforts to ensure continual program improvement. In addition, data will
help EPA monitor market penetration and inform future product categories
and specifications.  

Both the Clean Water Act (CWA) and the Safe Drinking Water Act (SDWA)
have water conservation provisions and authorities that support
WaterSense 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 the SDWA also provides a source of authority for some aspects
of WaterSense. 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.

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
develops a 5-year Strategic Plan that is submitted to Congress. Goal 2
of this plan focuses on ensuring that the nation’s water is both clean
and safe.  The 2006-2011 EPA Strategic Plan highlighted support for
sustainable infrastructure as a key strategy in achieving progress for
its goal of Clean and Safe Water.  EPA’s work in this area is focused
around “Four Pillars of Sustainable Infrastructure”— better
management, full-cost pricing, water efficiency, and watershed
approaches to protection. The WaterSense Program, which was initiated in
2006, is a key element of EPA’s strategic planning efforts to promote
better water management as a means to reduce the need for costly
infrastructure.

The Executive Orders 13514 “Federal Leadership in Environmental,
Energy, and Economic Performance” and 13423 call for federal agencies
to improve water efficiency and management and purchase WaterSense
labeled products as available.

		

2(b)	Practical Utility/Users of the Data

	The information collected by WaterSense is not designed or intended to
support regulatory decision making by OW or other EPA offices. In the
case of programmatic partnership data, it is voluntarily reported by
individual EPA WaterSense partners. EPA will use information collected
for a variety of purposes, described below:

Partnership Agreement

	EPA will use information submitted in the Partnership Agreement to
officially establish participation in WaterSense and list partners on
the WaterSense 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 WaterSense. Information submitted by partners will be
aggregated into a list and posted on the WaterSense 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.

Annual Reporting Form

	EPA will use updated annual data supplied by partners to monitor the
progress of WaterSense in stimulating the supply of and demand for
water-efficient products in the market, to determine the impact of
WaterSense 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 WaterSense and recognize
partner accomplishments.

Awards Application Form

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

Provider Quarterly Reporting Form

	EPA will use information from the provider quarterly reporting forms to
track information about the number and general location of labeled
homes, data collected for each home per the inspection documentation,
and a summary of common issues and concerns identified during the
inspection process.

Consumer Awareness Survey

	EPA will use data from a telephone consumer survey to assess consumer
awareness of the WaterSense label and brand. In the future, EPA will
compare results of this survey with future surveys to assess progress in
educating consumers. EPA will also conduct an Internet-based survey to
determine which methods of communicating water efficient-products are
most effective, assess the cost effectiveness of our outreach efforts
and better target future 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 non-federal 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

	On July 28, 2009, EPA notified the public about this information
request and requested comments on this collection via the Federal
Register. No comments were received during the public comment period.

	3(c)	Consultations

		

	WaterSense staff asked current partners to provide input on WaterSense
data collection efforts. The following partners provided input:

Name

Affiliation

Gail Donaldson

City of Allen, Texas

Jane Arrington

Spartanburg Water

Joanne Bissetta

Concord Public Works

Jeremy Gerking

Amazon LLC

Mary Henderson

Lowe’s Companies Inc.



C.J. Lagan

American Standard

Fernando Fernandez

TOTO USA

Glenn Bowlin

Broussard Associates

Frank Soukup

Emerald Lawns Inc.

	

	Partners provided feedback on the amount of time needed to respond to
WaterSense data collection forms and provided suggestions for improving
data collection. EPA incorporated feedback on the time needed to
complete the forms in the burden estimate. Additional suggestions made
by partners include revising the evaluation criteria for awards, using
online or Word forms in addition to Adobe forms, and changing the time
of year WaterSense requests data. 

		

	3(d)	Effects of Less Frequent Collection

The Partnership Agreement is a one-time information submittal for
organizations and certified professionals that wish to participate in
WaterSense as partners. Less frequent collection of this data is not
feasible. Manufacturers are asked to submit a New Certified Product
Notification Form for each product. Less frequent collection of this
information is not feasible.  

Partners submit the Annual Reporting Form 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
WaterSense 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 Reporting Form in the following areas:
labeled products, labeled new homes, labeled certification programs,
promotional activities, 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 efficiency activities. 

The Awards Application is requested for partners and other interested
applicants desiring additional recognition. Less frequent collection
would hinder EPA efforts to provide timely recognition of achievements.

The Provider Quarterly Reporting Form will be requested from licensed
certification provider partners every 3 months to determine the number
and general location (city, state) of certified homes, data collected
for each home per the inspection documentation, and a summary of issues
and concerns identified during the inspection process. Similar programs
(e.g., the ENERGY STAR New Homes program) collect similar data from
certification providers on the same schedule. Thus, EPA is planning on
collecting data from licensed certification providers on the same
schedule as ENERGY STAR. To keep the public informed of the availability
of WaterSense labeled new homes in a particular area, timely data is
needed.

The Consumer Awareness Survey will be conducted two times over the next
three years. Less frequent collection is not possible.

	3(e)	General Guidelines

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

	3(f)	Confidentiality

	WaterSense manufacturer and retailer/distributor partners may claim
their shipment and sales data as confidential business information
(CBI). EPA’s contractor, ERG, is currently managing CBI collected on
this project using the procedures outlined in ERG’s CBI security plan
entitled Security Plan for Handling Confidential Business Information
Under the Clean Water Act. Project staff are trained in CBI-handling
procedures, as outlined in this plan. Only staff demonstrating their
understanding of CBI handling procedures by passing a written test will
be permitted access to CBI.

	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 WaterSense partners, individuals desiring
recognition and participants in the consumer survey. WaterSense partners
include product manufacturers; professional certifying organizations;
certified professionals; retailers; distributors; utilities; federal,
state, and local government; builders, irrigation professionals and
NGOs. 

	Non-partner respondents will not have NAICS codes as they will be
randomly sampled citizens.

 	NAICS codes for likely partners include: 

NAICS Code	2007 NAICS U.S. Title	Index Entry

327111	Vitreous China Plumbing Fixture and China and Earthenware
Bathroom Accessories Manufacturing	Bathroom accessories, vitreous china
and earthenware, manufacturing

423720

	Plumbing and Heating Equipment and Supplies (Hydronics) Merchant
Wholesalers	Plumbing fixtures merchant wholesalers

326191

	Plumbing Fixture Fitting and Trim Manufacturing	Toilet fixtures,
plastics, manufacturing

444130	Hardware Stores	Hardware stores

444190	Other Building Material Dealers	Building materials supply dealers

221310	Water Supply and Irrigation Systems	Water supply systems

813312	Environment, Conservation and Wildlife Organizations	Conservation
advocacy organizations

339114	Dental Equipment and Supplies Manufacturing	Autoclaves, dental,
manufacturing

339114	Laboratory Apparatus and Furniture Manufacturing	Autoclaves,
laboratory-type (except dental), manufacturing

236115	New Single-Family Housing Construction (except Operative
Builders)	Home builders (except operative), single-family



4(b)	Information Requested

	Once a prospective partner organization reviews WaterSense materials
and decides to join the program, it will submit the appropriate
Partnership Agreement for its partnership category (Attachments 1-6).
Within 12 months of partnering, manufacturers are asked to complete a
New Certified Product Notification Form (Attachments 7-9) to provide
WaterSense with information on WaterSense labeled products. EPA also
asks partners to submit an Annual Reporting Form and Awards Application
(voluntarily at the Partner’s discretion). These documents are
included in Attachments 10-20. Licensed certification providers for new
homes will be asked to submit a Provider Quarterly Reporting Form
(Attachment 21). A sample Consumer Awareness Survey is included as
Attachment 22.  A draft Retailer Location Form has been included as
Attachment 23 which will supplement the Retailer/Distributor Annual
Reporting Form.  

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 (or name of individual for irrigation partner).

	•	Name, title, address, county, postal code, phone number, fax
number, e-mail address, and primary function of the partner’s primary
contact person.

	•	Approximate number of employees at the joining organization.

	•	How the partner heard about WaterSense.

	•	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 WaterSense Web site, brochure, agreement, and other
necessary materials.

	•	Select a primary contact person for WaterSense.

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

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

New Certified Product Notification Form

	Within 12 months of joining WaterSense, manufacturing partners complete
and submit to EPA a New Certified Product Notification Form. This form
is filled out upon successful completion of third-party testing of
product(s) to a WaterSense specification, and approval of a WaterSense
third-party licensed certifying 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 Notification Form:

Apply for label through approved third-party licensed certifying body.

Collect records from each service or product.

Select a primary contact person to answer questions from EPA's
WaterSense Team.

Complete the New Certified Product Notification Form upon receipt of
certification from the third-party licensed certifying body.

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

Answer questions about form if EPA needs clarifications.

Annual Reporting Form

	Program participants complete and submit to EPA a standard Annual
Reporting Form that describes the participant's Program-related
activities. The Annual Reporting Form 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.)

	•	Current Water-Efficient Products, Services, and Activities

		

		As applicable:

		 

For manufacturers: shipment data for both WaterSense and non-WaterSense
labeled products (option to provide data confidentially), information on
product availability and promotional efforts, program feedback.

For retailers and distributors, sales data for both WaterSense and
non-WaterSense labeled products (option to provide data confidentially),
information on product availability and promotional efforts, program
feedback.

For promotional partners (utilities; state, local, and federal
governments, non-profits, and professional and trade associations), past
and planned promotional activities, rebate information, program
feedback.

For irrigation partners, number of WaterSense labeled irrigation
products sold or installed, gallons of water saved per project,
promotional activities.

For professional certifying organizations, total number of professionals
certified through WaterSense labeled programs to deliver water-efficient
services, promotional, recruiting, and educational efforts.

For licensed certifying bodies, number of products tested and certified
to meet WaterSense criteria, number of products failed, suspended,
withdrawn, and/or reinstated, summary of label misuse and dispute
actions. 

For builders, total number of homes built/sold, number of WaterSense
labeled homes built/sold, and marketing efforts to promote WaterSense
labeled products and services. 

							

	

(ii)	Respondent activities:

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

Collect and review records to assess product shipment or sales data,
purchased products or services, number of professionals certified,
number of homes built/sold, promotional activities, and/or rebate
information during the reporting year.

Review instructions for completing the annual update.

			

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

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

	•	Respond to EPA questions to clarify data.

Awards Application

	Partners and non-partners who wish to receive additional recognition
will submit awards application forms for products and/or services they
provided that promote water efficiency 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: applicants only need to
complete an Awards Application form if they wish to be considered for an
award. 

	

Data items:

The application items include:

	•	Applicant Information (e.g., organization or individual name, name,
phone number, and email address of the primary contact person.)

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

Respondent activities:

Applicants 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, service, or promotional
information during the reporting year that qualifies for an award.

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

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

Provider Quarterly Reporting Form

	On a quarterly basis, licensed certification provider partners will
complete and submit a list of information about the number and features
of homes that have received the WaterSense label.

Data items:

The report items include:

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

New Home Information (e.g., number and general location of certified
homes, number and issues related to homes that did not qualify, builder
organization, aggregate data collected for the homes per the inspection
documentation, summary of any issues and concerns identified during the
inspection process)

Respondent activities:

Collect and review records.

Review instructions for submission.

Complete the Provider Quarterly Reporting Form.

Send the complete report to EPA via fax, mail, e-mail, or online.

Consumer Awareness Survey

EPA will conduct a phone survey of consumers to collect baseline data
about consumer awareness of the WaterSense label, brand, and messaging.
EPA will also conduct an Internet-based survey to collect information on
which methods of communicating water efficient-products are most
effective. Part B of this supporting statement describes the sampling
methodologies.

Data items: 

Phone Survey

Awareness of WaterSense label.

Source of information related to WaterSense (how did they hear about
it).

Identification of WaterSense labeled products.

Message retention.

Opinion on the value of water.

Key factors in purchasing water-using products/appliances.

Likelihood of purchasing a WaterSense labeled product versus
conventional product.

Influence on the presence or absence of the WaterSense label on
purchasing decision.

Promotion preferences

Internet Survey

Opinion on the value of water.

Key factors in purchasing water-using products/appliances.

Message retention.

Promotion preferences.

Respondent activities:

Receive phone call or Internet/email request and agree to participate in
survey.

Listen to/review survey instructions.

Respond to survey questions.

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

	5(a)	Agency Activities

	WaterSense will require EPA to engage in the following activities
related to the Partnership Agreement, New Certified Product Notification
Form, Annual Reporting Form, Awards Application, Provider Quarterly
Reporting Form, and Consumer Awareness Survey:

Partnership Agreement 

Develop Partnership Agreements for new partnership categories (e.g.,
builder, certification provider) and post to the WaterSense Web site.

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

	•	Review completed agreements, record/enter information into a
database, and update WaterSense Web site.

	•	Sign agreement.

Respond to the partner to welcome them to WaterSense or explain why the
organization is ineligible for partnership.

New Certified Product Notification Form

Develop notification form and disseminate form to partners via the
WaterSense Web site.

Answer partner questions about information to be submitted.

Review completed forms submitted by partners and clarify any
inconsistencies between the form and the certification file.

 

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
WaterSense Web site.

Disseminate updated lists as needed.

Annual Reporting Form

	•	Develop/revise standard data reports available via the program’s
database for EPA management review. 

	•	Communicate reporting requirements to partners and answer questions
regarding the Annual Reporting Form.

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

			

	•	Maintain a tracking system and record/enter information into
database.



	•	Develop and make publicly available an annual summary of WaterSense
partners’ activities, promotions, and market trends.

Awards Application 

Develop the Award Application and post it to the WaterSense Web site.

Communicate requirements for applying and respond to applicant questions
about award applications.

Compile award applications and maintain a record of each applicant’s
award application status. 

Determine which applications deserve recognition.

Provide recognition through Web site, award ceremony or other means.

Provider Quarterly Reporting Form

Develop the Provider Quarterly Reporting Form and post it to the
WaterSense Web site.

Maintain a tracking system and record results of reporting forms in
database.

Answer partner questions about information to be submitted.

Compile list of number of homes and general location to post on Web site
and include in annual program accomplishments report.

Consumer Awareness Survey

Craft sampling methodology.

Select sample (phone survey only).

Develop survey scripts and instructions.

Implement surveys.

Analyze data.

Report results via program documents (e.g., annual accomplishments
report), presentations, and Web site.

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 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 WaterSense 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 Agreements to join WaterSense at
any time. Partners may submit a New Certified Product Notification Form
as needed when products are certified. Partners will submit Annual
Reporting Forms to EPA every year that the partner participates in the
program. Partners who submit an Annual Reporting Form may submit one or
more Awards Applications for review and possible recognition by EPA.
Licensed certification providers will submit the Provider Quarterly
Reporting Form four times per year. EPA will implement a Consumer
Awareness Survey two times during the next three years. 

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

	6(a)	Estimating Respondent Burden

	EPA used input from potential partners and its experience implementing
WaterSense and 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 WaterSense. 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 $87.42 for
managerial staff, $73.88 for technical staff, and $36.38 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 ($10
per partner, plus an additional $35 if applying for an award). EPA
estimates that licensed certification providers will incur an average of
$25 per year as reports are submitted quarterly. Manufacturers wishing
to label products will incur an average of $3,565 per product to engage
WaterSense Licensed Certifying Bodies (independent testing
organizations) to perform product testing and certify products to EPA
WaterSense specifications.

6(c)	Estimating Agency Burden and Costs

	EPA used its experience implementing WaterSense and 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 2009 GS pay schedule available from the Office of
Personnel Management. EPA estimates an average hourly labor cost of
$70.60 for managerial staff; $51.79 for technical staff; and $20.79 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. EPA 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 WaterSense. The annual
burden to the Agency is approximately 35,998 hours, at a cost of
approximately $1,295,804. The three-year, bottom-line burden for the
life of this ICR is therefore 107,994 hours and $3,887,413.

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 the EPA WaterSense Program is
presented and explained separately below. 

	Partnership Agreement

EPA estimates that 2,272 partners will join the program (1,000
irrigation partners, 650 promotional partners, 195 retailers and
distributors, 156 manufacturers, 11 professional certifying
organizations, 150 builders, 60 licensed certification providers, and 50
commercial and institutional partners) over the three year period, for
an average of 757 partners per year.

	New Certified Product Notification Form

During the three-year period covered by this ICR, EPA anticipates
developing specifications for 11 categories of products in addition to
the two existing categories. 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
1,500 products for certification over the next 3 years of the program.
This translates to 500 products annually. EPA will continue updating the
Web registry of labeled products and services on a bi-monthly basis. 

Annual Reporting Form 

EPA requires submission of one Annual Reporting Form per organization
partner for each year the partner participates in the program. To date,
the program has generally received annual reporting forms from
approximately 30-60% of partners in each category (see Part B). In 2011,
EPA plans to begin collecting annual reporting forms from certified
professionals (irrigation partners) and professional certifying
organizations as well. EPA anticipates receiving a total of 2,154 annual
reporting forms over three years, with an average of 561 per year for
organizational partners and 157 for irrigation partners.  

Awards Application

EPA plans to continue its successful WaterSense awards program. EPA
anticipates receiving a total of 250 award applications, averaging 83
per year.

	Provider Quarterly Reporting Form

EPA plans to request a Provider Quarterly Reporting Form four times a
year from each licensed certification provider. Over the three-year
period, EPA expects to partner with 60 licensed certification providers,
averaging 20 providers per year and 80 Provider Quarterly Reporting
Forms per year, for a total of 240 reports over 3 years. 

	Consumer Awareness Survey

EPA plans to initiate the collection of information in two consumer
awareness surveys. EPA anticipates collecting information from 800
individuals over three years, averaging 266 per year. 

Total Burden and Costs

Exhibit 1 shows the aggregate annual respondent burden and costs for the
information collection activities associated with WaterSense. Estimated
respondent burden hours are presented on a per respondent basis for the
information collected under the Partnership Agreement, Annual Reporting
Form, Awards Application, Provider Quarterly Reporting Form, and
Consumer Awareness Survey and on a per product basis for the New
Certified Product Notification Form. The annual burden to the universe
of respondents is approximately 21,250 hours, at a cost of approximately
$3,369,814. The three-year, bottom-line burden for the life of this ICR
is therefore 63,750 hours and $10,109,442.

EPA expects respondents from individuals (i.e., certified professionals
and consumers), private sector businesses, and state and local
governments. EPA estimates that 20 percent of the respondents will be
state and local governments, 50 percent will be private sector
businesses, and 30 percent will be individuals. 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	357	2,877	1,071	8,631

Private Sector	1,319	14,024	3,957	42,072

Individuals	668	4,350	2,004	13,050



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

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

State, local, and tribal government	$211,843	$4,110	$215,953	$647,859

Private sector	$1,045,192	$1,782,900	$2,828,092	$8,484,277

Individuals	$319,598	$6,171	$325,769	$977,307



	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
$3,336,814 and the hourly burden is approximately 21,250 hours. The
total cost for the Agency is $1,295,804 and the hourly burden is
approximately 35,998 hours. Table 3 displays these combined estimates,
as well as the grand total of $4,665,618 and the hourly burden of
approximately 57,248 hours for all information collection activities
under WaterSense.

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

	Burden Hours	Total Cost

Respondents	21,250	$3,369,814

Agency	35,998	$1,295,804

Total	57,248	$4,665,618



6(f)	Reasons for Change in Burden

The WaterSense program has been modified and expanded since the original
ICR was approved.  The program is expanding in the number of products
certified, new partners joining and reporting, and the addition of the
New Homes portion of the program. Despite this expansion, the overall
burden estimate for this collection is 28,830 hours lower than the
current ICR because EPA also has a better understanding of how long it
actually takes partners to complete program forms now that the program
is underway. Operation & Maintenance cost estimates have risen
substantially however, since product testing by certifying bodies was
found to be more expensive than previously estimated and many more
products are expected to undergo this testing in the next three years.

6(g)	Burden Statement

The estimated average annual reporting and recordkeeping burden for this
collection of information is 19 hours for organizational partners, who
are not manufacturers and who are not applying for an award. The average
burden increases by 16 to 35 hours for manufacturing partners (to
complete New Certified Product Notification Forms). Award applicants are
estimated to spend an additional 20 hours on average. The respondent
reporting burden for each information collection activity for WaterSense
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 WaterSense.

Partnership Agreement

The reporting burden for information collection requirements associated
with completing the Partnership Agreement is estimated to be 7 hours for
organizations and 2.5 hours for irrigation partners. 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 16 hours. This
estimate includes third-party testing, assembling the data into a report
format, reviewing it and submitting it.

	Annual Reporting Form

The reporting burden for information collection requirements associated
with the Annual Reporting Form is 12 hours for partner organizations and
3 hours for irrigation partners. This estimate includes gathering data
such as product sales, number of products purchased, and number of
rebates issued; compiling this information; and submitting it to EPA. 

Awards Application

The reporting burden for information collection requirements associated
with the Awards Application for each respondent is estimated to be 20
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. 

Provider Quarterly Reporting Form

The reporting burden for information collection requirements associated
with the Provider Quarterly Reporting Form for each respondent is
estimated to be 26 hours per year. This estimate includes collecting and
reviewing records, reviewing instructions, completing the reporting
form, and submitting the form to EPA. 

Consumer Awareness Survey

The reporting burden for information collection requirements associated
with the Consumer Awareness Survey for each respondent is estimated to
be 0.25 hours. This estimate includes receiving a phone call (or
Internet-based request), agreeing to participate in survey, listening to
(or reviewing) survey instructions, and responding to survey questions.

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 Annual Respondent Burden and Cost





















	Information Collection Activity	Hours and Costs Per Respondent/Labeled
Product	Total Hours and Costs

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

Hourly Rate	87.42	73.89	36.38	 	 	 	 	 	 	 

Partnership Agreement	 	 	 	 	 	 	 	 	 	 

Review the EPA WaterSense Web site, brochure, agreement, and other
necessary materials	1	2	0	3	$235.20	 	 	424	1,272	$99,725

Select a primary contact person for the program	0.5	0	0	0.5	$43.71	 	 
424	212	$18,533

Complete the PA, obtain signature of senior official	0.5	1.5	1	3	$190.93
 	 	424	1,272	$80,952

Send the completed agreement to EPA via fax, mail, e-mail, or online	0	0
0.5	0.5	$18.19	 	$5.00	424	212	$9,833

Subtotal	2	3.5	1.5	7	$488.03	 	 	 	2,968	$209,043

Partnership Agreement: Certified Professionals	 	 	 	 	 	 	 	 
 	 

Review the EPA WaterSense Web site, brochure, agreement, and other
necessary materials	0	1	0	1	$73.89	 	 	333	333	$24,605

Complete the PA, locate certification proof document	0	1	0	1	$73.89	 
 	333	333	$24,605

Send the completed agreement and certification proof to EPA via fax,
mail, e-mail, or online	0	0.5	0	0.5	$36.95	 	$5.00	333	167	$13,968

Subtotal	0	2.5	0	2.5	$184.73	 	 	 	833	$63,178

New Certified Product Notification Form 	 	 	 	 	 	 	 	 	 	 

Apply for label from approved licensed certifying body	1	8	0	9	$678.54
$3,500.00	$50.00	500	4,500	$2,114,270

Collect records of each service or product	0	2	0	2	$147.78	 	$5.00	500
1,000	$76,390

Select a primary contact person to answer questions from EPA's
WaterSense Team	0.25	0.25	0	0.5	$40.33	 	 	500	250	$20,164

Complete the notification form	1	1	0	2	$161.31	 	 	500	1,000	$80,655

Send the completed application to EPA via fax, mail, e-mail or online	0
0	0.5	0.5	$18.19	 	$10.00	500	250	$14,095

Answer questions from EPA	1	1	0	2	$161.31	 	 	500	1,000	$80,655

Subtotal	3.25	12.25	0.5	16	$1,207.46	 	 	 	8,000	$2,386,229

Annual Reporting Form 	 	 	 	 	 	 	 	 	 	 

Collect and review records to assess product shipment or sales data,
purchased products or services, promotional activities, rebate
information during the reporting year	1	5	0	6	$456.87	 	 	561	3,366
$256,304

Review instructions	0	0.5	0	0.5	$36.95	 	 	561	281	$20,726

Complete the Annual Reporting Form	1	3	0	4	$309.09	 	 	561	2,244
$173,399

Send the completed update to EPA via fax, mail, e-mail, or online	0	0
0.5	0.5	$18.19	 	$5.00	561	281	$13,010

Respond to EPA questions to clarify data	0	1	0	1	$73.89	 	 	561	561
$41,452

Subtotal	2	9.5	0.5	12	$894.99	 	 	 	6,732	$504,892

Annual Reporting Form: Certified Professionals	 	 	 	 	 	 	 	 
 	 

Collect information to assess the practice of efficient irrigation
design and maintenance or use of labeled products	0	1	0	1	$73.89	 	 
157	157	$11,601

Review instructions	0	0.5	0	0.5	$36.95	 	 	157	79	$5,800

Complete the Annual Reporting Form	0	0.5	0	0.5	$36.95	 	 	157	79
$5,800

Send the complete update to EPA via fax, mail, e-mail, or online	0	0.5	0
0.5	$36.95	 	$5.00	157	79	$6,585

Respond to EPA questions to clarify data	0	0.5	0	0.5	$36.95	 	 	157	79
$5,800

Subtotal	0	3	0	3	$221.67	 	 	 	471	$35,587

Awards Applications	 	 	 	 	 	 	 	 	 	 

Review instructions and eligibility requirements	1	1	0	2	$161.31	 	 
83	166	$13,389

Gather data	2	5	0	7	$544.29	 	$5.00	83	581	$45,591

Complete application and supplemental materials	2	8	0	10	$765.96	 
$10.00	83	830	$64,405

Submit the application via fax, mail, e-mail, or online	0	0	1	1	$36.38
 	$20.00	83	83	$4,680

Subtotal	5	14	1	20	$1,507.94	 	 	 	1,660	$128,064

Provider Quarterly Reporting Form (Annualized)*	 	 	 	 	 	 	 	 
 	 

Collect and review records  	4	8	0	12	$940.80	 	 	20	240	$18,816

Review instructions	0	1	0	1	$73.89	 	 	20	20	$1,478

Complete report	0	12	0	12	$886.68	 	 	20	240	$17,734

Submit the report via fax, mail, e-mail, or online	0	0	1	1	$36.38	 
$20.00	20	20	$1,128

Subtotal	4	21	1	26	$1,937.75	 	 	 	520	$39,155

Consumer Awareness Survey	 	 	 	 	 	 	 	 	 	 

Receive survey request and instructions and respond to questions	 
0.125	0.125	0.25	$13.78	 	 	266	67	$3,666

Subtotal	 	0.125	0.125	0.25	$13.78	 	 	266	67	$3,666

TOTAL	16.25	65.875	4.625	86.75	$6,456.34	 	 	2,344	21,250	$3,369,814













*Quarterly Reports will be requested 4 times a year; data presented on
annual basis 





	Three Year Burden	          63,750 	$10,109,442

Exhibit 2. Estimated Annual Agency Burden and Cost























Information Collection Activity	Hours and Costs Per Respondent/Labeled
Product	Total Hours and Costs

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

Hourly Rate	70.60	51.79	20.79	 	 	 	 	 	 	 

Partnership Agreement	 	 	 	 	 	 	 	 	 	 

Develop Partnership Agreements and post to Web site	2	6	0.5	8.5	$462.34
 	 	3	25.5	$1,387

Answer questions posed by potential participants regarding membership in
the program	0	2	0	2	$103.58	 	 	379	758	$39,257

Review completed agreements, record/enter information into a database,
and update WaterSense Web site	1	4	2	7	$319.34	 	 	757	5,299	$241,740

Respond to the partner to welcome them to WaterSense or explain why
organization is ineligible for partnership	0.5	0	0	0.5	$35.30	 	 	757
379	$26,722

Sign agreement	0.5	0.5	1	2	$81.99	 	$2.00	757	10,200	$63,577

Subtotal	4	12.5	3.5	20	$1,002.54	 	 	 	16,661	$372,683

New Certified Product Notification Form 	 	 	 	 	 	 	 	 	 	 

Develop application materials to be submitted by partners and post to
Web site	2	8	0	10	$555.52	 	 	8	80	$4,444

Answer partner questions about form, review completed forms submitted by
partner and clarify any inconsistencies between the form and the
certification file	0.5	0.5	2	3	$102.78	 	$5.00	500	1,500	$53,888

Enter data into program database	0	0	1	1	$20.79	 	 	500	500	$10,395

Respond to partner to inform them that the form has been accepted, or to
explain why it could not be accepted	0.5	0	0	0.5	$35.30	 	 	500	250
$17,650

Compile list of products by product type to post on EPA’s WaterSense
Web site	0	4	0	4	$207.16	 	 	500	2,000	$103,580

Disseminate updated list as requested	0	1	2	3	$93.37	 	$20.00	500	1,500
$56,685

Subtotal	3	13.5	5	21.5	$1,014.92	 	 	 	5,830	$246,642

Annual Reporting Forms	 	 	 	 	 	 	 	 	 	 

Develop/revise standard data reports and communicate reporting
requirements	10	40	10	60	$2,985.50	 	 	1	60	$2,986

Answer questions regarding the Annual Reporting Form	0	2	0	2	$103.58	 
$2.00	359	718	$37,903

Receive and review the reports for consistency and completeness and
place any follow-up calls necessary	1	3	0	4	$225.97	 	$1.00	718	2,872
$162,964

Maintain a tracking system to record/enter information into database	0	0
2	2	$41.58	 	 	718	1,436	$29,854

Develop annual data summary	10	100	20	130	$6,300.80	 	$5.00	1	130
$6,306

Subtotal	21	145	32	198	$9,657.43	 	 	 	5,216	$240,013

Awards Applications	 	 	 	 	 	 	 	 	 	 

Maintain a tracking system to record each participant’s award
application status	0	20	5	25	$1,139.75	 	 	1	25	$1,140

Develop application to be submitted by partners, post to Web site, and
communicate requirements for applying	0	2	0	2	$103.58	 	 	83	166
$8,597

Respond to partner questions about award applications	2	8	2	12	$597.10
 	$2.00	42	504	$25,162

Determine which applications deserve recognition	4	60	0	64	$3,389.80	 
$10.00	83	5,312	$282,183

Subtotal	6	90	7	103	$5,230.23	 	 	 	6,007	$317,082

Provider Quarterly Reporting Form (Annualized)*	 	 	 	 	 	 	 	 
 	 

Develop reporting form	4	8	0	12	$696.72	 	 	1	12	$697

Maintain a tracking system to record results of report in database	10	30
14	54	$2,550.76	 	 	10	540	$25,508

Answer partner questions about information to be submitted	0	0	4	4
$83.16	 	 	20	80	$1,663

Compile list of number of homes and general location to post on Web site
0	8	0	8	$414.32	 	 	20	160	$8,286

Subtotal	14	46	18	78	$3,744.96	 	 	 	792	$36,154

Consumer Awareness Survey	 	 	 	 	 	 	 	 	 	 

Craft sampling methodology	8	24	0	32	$1,807.76	 	 	2	64	$3,616

Select sample	0	24	0	24	$1,242.96	 	 	2	48	$2,486

Develop survey script and instructions	10	20	0	30	$1,741.80	 	 	2	60
$3,484

Implement survey	80	400	40	520	$27,195.60	 	$2,000.00	2	1,040	$58,391

Analyze data	20	120	0	140	$7,626.80	 	 	2	280	$15,254

Subtotal	118	588	40	746	$39,614.92	 	 	 	1,492	$83,230

TOTAL	166	895	105.5	1166.5	$60,265.00	 	 	 	35,998	$1,295,804













*Quarterly Reports will be requested 4 times a year; data presented on
annual basis 





	Three Year Burden	          107,994 	$3,887,413



 Note: this list of products may change based on available information
obtained via EPA’s research activities. EPA will issue a formal notice
of intent (NOI) for each product entering the specification process to
allow full stakeholder input and involvement in the specification
development process.

