1.	IDENTIFICATION OF THE INFORMATION COLLECTION

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

	This Information Collection Request (ICR) is entitled “The U.S.
Environmental Protection Agency’s (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, irrigation professionals, retailers and
distributors, home builders, licensed certification providers 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: 

Professional certification programs

Residential toilets

Residential faucets

Flushing urinals

Showerheads

New homes

Weather-based irrigation controllers

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

Pre-rinse spray valves

Flushometer toilets

Soil-moisture-based irrigation controllers

	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 who 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.

	

WaterSense currently asks all organizational partners to submit an
Annual Reporting Form to inform EPA of their program-related activities.
Partners are asked to submit results via the Annual Reporting Form in
the following areas: WaterSense labeled products, services, and new
homes; promotional activities; product sales and shipment information;
program mark usage; plans for submitting award applications; and program
feedback. 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 WaterSense labeled water-efficient
products and services to consumers, and to recognize partner
accomplishments. 

EPA offers an awards program to recognize significant WaterSense
partners’ accomplishments. Participation in the awards program is
voluntary. Those parties who desire special recognition are required to
submit an Awards Application. The Awards Application is submitted
electronically and enumerates a partner’s achievements in key
criteria.  

WaterSense partners with licensed certification providers, who oversee
inspections of new homes to determine if they meet the WaterSense
specification. Each licensed certification provider is 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 effective
methods of communicating the benefits of water-efficient products.

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 help
WaterSense demonstrate results 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 safe supply of drinking
water depends upon 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 five-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 2011-2015 EPA Strategic Plan highlighted support for
sustainable infrastructure as a key strategy in achieving progress for
its goal of Protecting America’s Waters.  The WaterSense program,
which was initiated in 2006, is a key element of EPA’s strategic
planning efforts to promote the sustainability of water systems and
support adaptation to climate change. 

The Executive Orders 13423 and 13514 “Federal Leadership in
Environmental, Energy, and Economic Performance” 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 website. 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.

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 WaterSense labeled products and services is
current. This information will also be used to promote WaterSense and
recognize partner accomplishments.

Awards Application

	EPA will use information from the Awards Application to select and
recognize outstanding accomplishments that 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 WaterSense
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 its outreach efforts
and better target future efforts.

3.	NON-DUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

	3(a)	Non-Duplication

	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 one another rather than duplicate efforts.			

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

	[To be added following public comment period]

	3(c)	Consultations

		

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

Name

Affiliation

Laura Wing

City of Thornton

Carol Ward-Morris

Arizona Municipal Water Users Association

Jacob Atalla

 KB Home

Evan Matzen

 HD Supply Facilities Maintenance

Annette Mowad

The Home Depot



Lee Mercer

Moen Incorporated

Carissa Sawyer

EnergyLogic, 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 using an online form for the partnership agreement,
removing supplemental materials from the awards application, and
changing the new homes inspection form to a rewritable PDF format. 

		

	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. 

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:
WaterSense labeled products, WaterSense labeled new homes, WaterSense
labeled certification programs, promotional activities, and product
sales and shipment information. Requesting this information less
frequently would hinder Agency efforts to generate relevant and timely
case studies, provide up-to-date information on WaterSense 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 desiring additional
recognition. Less frequent collection would hinder EPA efforts to
provide timely recognition of achievements.

The Provider Quarterly Reporting Form is requested from licensed
certification provider partners every three months to determine the
number and general location (e.g., city, state) of WaterSense labeled
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 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 would hinder an accurate
comparison of attitudes.

	3(e)	General Guidelines

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

	3(f)	Confidentiality

	All shipment and sales data submitted by WaterSense manufacturer and
retailer/distributor partners are collected as confidential business
information (CBI). EPA’s contractor, Eastern Research Group (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 SIC Codes

	Respondents will consist of WaterSense partners and participants in the
consumer survey. WaterSense partners include product manufacturers;
professional certifying organizations; retailers; distributors;
utilities; federal, state, and local government; home builders;
irrigation professionals; licensed certification providers; and NGOs.
Non-partner respondents will not have SIC codes as they will be randomly
sampled citizens.

 	SIC codes for likely partners include: 

SIC Code	SIC Title

3261	Vitreous China Plumbing Fixtures and China and Earthenware Fittings
and Bathroom Accessories

5074	Plumbing and Heating Equipment and Supplies (Hydronics, sold via
retail method)

3432	Plumbing Fixture Fittings and Trim (except shower rods and lawn
hose nozzles)

3523	Farm Machinery and Equipment (except corrals, stalls, holding
gates, hand clippers for animals, and farm conveyors/elevators)

5251	Hardware Stores

5211	Lumber and Other Building Materials Dealers (home center stores)

5083	Farm and Garden Machinery and Equipment (Wholesale) (sold via
retail method)

4941	Water Supply

8399	Social Services, NEC (environment, conservation, and wildlife
advocacy)

3843	Dental Equipment and Supplies

1521	General Contractors-Single-Family Houses

1522	General Contractors-Residential Building, Other Than Single-Family 

1542	General Contractors-Nonresidential Buildings, Other than Industrial
Buildings and Warehouses

8611	Business Associations

9511	Air and Water Resource and Solid Waste Management



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 1-7).
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 8-29. Licensed certification providers for
WaterSense labeled new homes are asked to submit a Provider Quarterly
Reporting Form (Attachment 30). A sample Consumer Awareness Survey is
included as Attachment 31.  

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 for all partners 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.

	Additional reporting items for builder and irrigation partners include:

	•	Service area

	Additional reporting items for manufacturer partners include:

	•	Contact information for reporting, marketing, technical contacts

	(ii)	Respondent Activities:

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

	•	Review the WaterSense website, agreement, and other necessary
materials.

	•	Select a primary, technical, marketing, and/or reporting contact
for the program.

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

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

	Irrigation partners conduct the following activities to complete the
Partnership Agreement:

Review the WaterSense website, agreement, and other necessary materials.

Complete the Partnership Agreement, locate proof of certification
document.

Send the completed form and proof of certification to EPA via fax, mail,
email, or online.

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

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.

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.

Promotional Organizations (utilities; state, local, and federal
governments, nonprofits, and professional and trade associations): past
and planned promotional activities, water supply information, rebate
information, program feedback.

Professional Certifying Organizations: total number of professionals
certified through WaterSense labeled programs to deliver water-efficient
services, promotional, recruiting, and educational efforts.

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:

Builder and promotional partners conduct the following activities in
order to complete and submit the Annual Reporting Form:

Review instructions for online form. 

Review records to assess promotional activities, WaterSense program mark
usage, rebate information, and new homes information for builders

Complete and submit the Annual Reporting Form online.

Manufacturer/retailer/distributor partners conduct the following
activities in order to complete and submit the Annual Reporting Form:

Review instructions for online and hard-copy forms.

Review records to assess promotional efforts, WaterSense program mark
usage, and customers reached during the reporting year. 

Complete and submit the Annual Reporting Form online.

Collect and review records to assess product data during the reporting
year, including non-WaterSense labeled and WaterSense labeled product
shipments and sales.

Send the hard-copy confidential PDF to EPA via mail.

Respond to EPA questions to clarify data.

Awards Application

	Partners who wish to receive additional recognition can submit an
Awards Application 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 if they wish to be considered for an award.
Submitting an Annual Reporting Form is a prerequisite for applying for
an award (except for irrigation partner who are not required to submit
annual reporting forms.).

	

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.

Gather information.

Complete application form and supplemental materials.

Submit the application 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 reporting 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 WaterSense
labeled 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:

Organizations conduct the following activities in order to complete and
submit the Provider Quarterly Reporting Form:

Collect and review records.

Review instructions for submission.

Complete the Provider Quarterly Reporting Form.

Submit the report 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 (e.g., 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 a
conventional product.

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

Promotion preferences.

Internet Survey

Opinion on the value of water.

Key factors in purchasing water-using products/appliances.

Message retention.

Promotion preferences.

Respondent Activities:

Respondents conduct the following activities in order to complete the
Consumer Awareness Survey:

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, Annual Reporting Form, Awards
Application, Provider Quarterly Reporting Form, and Consumer Awareness
Survey:

Partnership Agreement 

Update Partnership Agreements for existing partnership categories, and
post to the WaterSense website.

	•	Answer questions posed by potential participants regarding
partnership.

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

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

Sign agreement.

Annual Reporting Form (All Partners)

	•	Develop/revise PDF reporting forms, and online forms. Post to
website and communicate reporting requirements.

	•	Answer partner questions about forms.

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

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



	•	Develop annual data summary.

Awards Application 

Update application to be submitted by partners, post to website, and
communicate requirements for applying.

Maintain a tracking system to record each participant’s awards
application status and review submission.

Respond to applicant questions about awards applications.

Determine which applications deserve recognition.

Provider Quarterly Reporting Form

Update reporting form and communicate reporting requirements.

Maintain a tracking system to record results of report in database.

Answer partner questions about information to be submitted.

Compile list of number of homes and general location. 

Consumer Awareness Survey

Craft sampling methodology.

Select sample.

Develop survey scripts and instructions.

Implement survey.

Analyze data.

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

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 a Partnership Agreement to join WaterSense at
any time. 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 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 (i.e., hourly plus overhead) of $96.42 for
managerial staff, $74.86 for technical staff, and $40.42 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 ($2 per
partner, plus an additional $5 if applying for an award). 

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 based on the 2012 GS pay schedule available from the Office of
Personnel Management. EPA estimates an average hourly labor cost of
$107.54 for managerial staff and $72.82 for professional staff. The
labor costs are based on the following GS levels and steps: managerial
rates were based on GS Level 15, Step 5 and professional labor rates
were based on GS Level 13 Step 3. EPA multiplied hourly rates by the
standard government overhead factor of 1.6.

EPA anticipates communicating with partners electronically rather than
mailing paper, so it has 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 4,816 hours, at a cost of
approximately $383,854. The three-year, bottom-line burden for the life
of this ICR is therefore 14,448 hours and $1,151,561.

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’s WaterSense program is
presented and explained separately below. 

	Partnership Agreement

EPA estimates that 1,265 partners will join the program (675 irrigation
partners, 300 promotional partners, 90 retailers and distributors, 120
manufacturers, 15 professional certifying organizations, 60 builders,
five licensed certification providers) over the three-year period, for
an average of 421 partners per year.

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 10 to 45 percent of partners in each category (see Part
B). In 2014, EPA plans to begin collecting annual reporting forms from
professional certifying organizations. EPA anticipates receiving a total
of 1,005 annual reporting forms over three years, with an average of 335
per year for organizational partners.  

Awards Application

EPA plans to continue its successful WaterSense awards program. EPA
anticipates receiving a total of 100 award applications, averaging 33
per year.

	Provider Quarterly Reporting Form

EPA requests a Provider Quarterly Reporting Form four times a year from
each licensed certification provider. Over the three-year period, EPA
expects to collect 33 Provider Quarterly Reporting Forms per year, for a
total of 100 reports over three 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. The annual burden to the universe of
respondents is approximately 4,110 hours, at a cost of approximately
$316,018. The three-year, bottom-line burden for the life of this ICR is
therefore 12,330 hours and $948,054.

EPA expects responses from individuals (e.g., certified professionals
and consumers), private sector businesses, and state and local
governments. EPA estimates that 30 percent of the respondents will be
state and local governments, 20 percent will be private sector
businesses, and 50 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 Annual and Three-Year
Burden Hours by Sector

Respondents	Respondents Per Year	Burden Hours Per Year	Respondents Over
Three Years	Total Burden Hours Over Three Years

State, local, and tribal government	326	1,233	978	3,699 

Private Sector	217	822	652	2,466

Individuals	544	2,055	1,631	6,165



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

Respondents	Labor Costs Per Year	O&M Costs Per Year	Total Costs Per Year
Total Costs Over Three Years

State, Local, and Tribal Governments	$94,421 	$385	$94,805	$284,416

Private Sector	$62,947	$256	$63,204	$189,611

Individuals	$157,368	$641	$158,009	$474,027



	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
$316,018 and the hourly burden is approximately 4,110 hours. The total
cost for the Agency is $383,854 and the hourly burden is approximately
4,816 hours. Table 3 displays these combined estimates, as well as the
grand total of $699,872 and the hourly burden of approximately 8,926
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	4,110	$316,018

Agency	4,816	$383,854

Total	8,926	$699,872



6(f)	Reasons for Change in Burden

The WaterSense program has been modified and expanded since the 2010 ICR
was approved; however, the program has made efforts over the last
several years to reduce the burden for its partners and the Agency.
Program changes, including using online forms, eliminating product
notification forms for manufacturers, and deciding not to require
irrigation partners to report annually have led to reduced operation &
maintenance costs and a lower estimated burden. The overall burden
estimate for this collection is 144,966 hours lower than the current ICR
because EPA also has a better understanding of how long it takes
partners to complete program forms and better historical data to project
new partners/forms over the next three years.

6(g)	Burden Statement

The estimated average annual reporting and recordkeeping burden for this
collection of information is five hours for organizational partners, who
are not manufacturers, retailer/distributors or licensed certification
providers, and who are not applying for an award. The average burden
increases by three hours for manufacturer and retailer/distributor
partners and by five hours for licensed certification providers. Award
applicants are estimated to spend an additional 25 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 two hours
for organizations and two-and-a-half 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. 

	Annual Reporting Form

The reporting burden for information collection requirements associated
with the Annual Reporting Form is five hours for builder, promotional
partner, and professional certifying organizations and eight hours for
manufacturer and retailer/distributor 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 25
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 10 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. Visit 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	Total
Hours and Costs

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

Hourly Rate	96.42	74.86	40.42	 	 	 	 	 	 	 

Partnership Agreement (PA)	 	 	 	 	 	 	 	 	 	 

Review the EPA WaterSense website, agreement, and other necessary
materials.	0.5	0	0	0.5	$48.21	 	 	196	98	$9,449

Select a primary, technical, marketing, and/or reporting contact person
for the program.	0.5	0	0	0.5	$48.21	 	 	196	98	$9,449

Complete the PA, obtain signature of senior official.	0.5	0	0	0.5	$48.21
 	 	196	98	$9,449

Send the completed form to EPA via fax, mail, email, or online.	0	0	0.5
0.5	$20.21	 	$2.00	196	98	$4,353

Subtotal	1.5	0	0.5	2	$164.84	 	 	 	392	$32,701

Partnership Agreement: Irrigation Partners	 	 	 	 	 	 	 	 	 	 

Review the EPA WaterSense website, agreement, and other necessary
materials.	0	1	0	1	$74.86	 	 	225	225	$16,844

Complete the PA, locate certification proof document.	0	1	0	1	$74.86	 
 	225	225	$16,844

Send the completed agreement and certification proof to EPA via fax,
mail, email, or online.	0	0.5	0	0.5	$37.43	 	$2.00	225	113	$8,872

Subtotal	0	2.5	0	2.5	$187.15	 	 	 	563	$42,559

Annual Reporting Form 	 	 	 	 	 	 	 	 	 	 

Review instructions for online form.	1	0	0	1	$96.42	 	 	246	246
$23,719

Review records to assess promotional activities, WaterSense program mark
usage, rebate information, and new homes information for builders.	1	2	0
3	$246.14	 	 	246	738	$60,550

Complete and submit the Annual Reporting Form.	0	0	1	1	$40.42	 	 	246
246	$9,943

Subtotal	2	2	1	5	$382.98	 	 	 	1,230	$94,213

Annual Reporting Form: Manufacturers and Retailer/Distributors	 	 	 
 	 	 	 	 	 	 

Review instructions for online and hard copy forms.	0.5	0	0	0.5	$48.21
 	 	88	44	$4,242

Review records to assess promotional efforts, WaterSense program mark
usage, and customers reached during the reporting year.	1	0	0	1	$96.42
 	 	88	88	$8,485

Complete and submit the Annual Reporting Form online.	0	0	1	1	$40.42	 
 	88	88	$3,557

Collect and review records to assess product data during the reporting
year, including non-WaterSense and WaterSense labeled product shipments
and sales.	1.5	2	0	3.5	$294.35	 	 	88	308	$25,903

Send the hard copy confidential PDF to EPA via mail.	0	0	1	1	$40.42	 
$5.00	88	88	$3,997

Respond to EPA questions to clarify data.	1	0	0	1	$96.42	 	 	88	88
$8,485

Subtotal	0	2	0	8	$616.24	 	 	 	704	$54,669

Awards Applications	 	 	 	 	 	 	 	 	 	 

Review instructions and eligibility requirements.	2	0	0	2	$192.84	 	 
33	66	$6,364

Gather information.	7	7	0	14	$1,198.96	 	 	33	462	$39,566

Complete application form and supplemental materials. 	4	4	0	8	$685.12
 	 	33	264	$22,609

Submit the application online. 	0	1	0	1	$74.86	 	 	33	33	$2,470

Subtotal	13	12	0	25	$2,151.78	 	 	 	825	$71,009

Provider Quarterly Reporting Form (Annualized)*	 	 	 	 	 	 	 	 
 	 

Collect and review records.  	0	0	2	2	$80.84	 	 	33	66	$2,668

Review instructions.	0	0	2	2	$80.84	 	 	33	66	$2,668

Complete report.	2	0	2	4	$273.68	 	 	33	132	$9,031

Submit the report online.	0	0	2	2	$80.84	 	 	33	66	$2,668

Subtotal	2	0	8	10	$516.20	 	 	 	330	$17,035

Consumer Awareness Survey	 	 	 	 	 	 	 	 	 	 

Receive survey request and instructions and respond to questions.	0
0.125	0.125	0.25	$14.41	 	 	266	67	$3,833

Subtotal	0	0.125	0.125	0.25	$14.41	 	 	 	67	$3,833

TOTAL	18.5	18.625	9.625	52.75	$4,033.60	 	 	1,087	4,110	$316,018



*Quarterly Reports will be requested four times a year; data will be
presented on an annual basis. 



Exhibit 2. Estimated Annual Agency Burden and Cost





















Information Collection Activity	Hours and Costs Per Respondent	Total
Hours and Costs

 	Manager	Professional	Respondent Hours Per Year	Labor Costs Per
Activity Per Year	Annual Capital Startup Costs	Annual O&M Costs	No.of
Agency Activities Per Year	Total Agency Hours Per Year	Total Cost Per
Year

Hourly Rate	107.54	72.82	 	 	 	 	 	 	 

Partnership Agreement (PA)	 	 	 	 	 	 	 	 	 

Update PAs and post to website.	2	6	8	$652.00	 	 	7	56	$4,564

Answer questions posed by potential participants regarding partnership.
0	2	2	$145.64	 	 	100	200	$14,564

Review completed agreements, record/enter information into a database,
and update WaterSense website.	0	1.5	1.5	$109.23	 	 	196	294	$21,409

Respond to the partner to welcome them to WaterSense or explain why
organization is ineligible for partnership.	0	1.5	1.5	$109.23	 	 	196
294	$21,409

Sign agreement.	0	0.25	0.25	$18.21	 	$2.00	196	49	$3,960

Subtotal	2	11.25	13.25	$1,034.31	 	 	 	893	$65,906

Annual Reporting Form (All Partners)	 	 	 	 	 	 	 	 	 

Develop/revise online reporting forms, post to website, and communicate
reporting requirements.	5	10	15	$1,265.90	 	 	3	45	$3,798

Answer partner questions about forms.	0	1	1	$72.82	 	 	100	100	$7,282

Receive and review the reports for consistency and completeness and
place any follow-up calls necessary.	0	1	1	$72.82	 	 	246	246	$17,914

Maintain a tracking system to record/enter information into database.	0
0.5	0.5	$36.41	 	 	246	123	$8,957

Develop annual data summary.	0	1	1	$72.82	 	 	1	1	$73

Subtotal	5	13.5	18.5	$1,520.77	 	 	 	515	$38,023

Annual Reporting Form (Manufacturer and Retailer/Distributor Partners)
 	 	 	 	 	 	 	 	 

Update PDF reporting forms, online forms, post to website, and
communicate reporting requirements.	5	35	40	$3,086.40	 	 	3	120	$9,259

Answer partner questions about forms.	0	1	1	$72.82	 	 	22	22	$1,602

Receive and review the reports for consistency and completeness and
place any follow-up calls necessary.	1	3	4	$326.00	 	$3.00	88	352
$28,952

Maintain a tracking system to record/enter information into database.	1
0.5	1.5	$143.95	 	 	88	132	$12,668

Develop annual data summary.	2	2	4	$360.72	 	 	1	4	$361

Subtotal	9	41.5	50.5	$3,989.89	 	 	 	630	$52,842

Awards Applications	 	 	 	 	 	 	 	 	 

Update application to be submitted by partners, post to website, and
communicate requirements for applying. 	20	30	50	$4,335.40	 	 	7	350
$30,348

Maintain Award Application tracking system to record each
participant’s status and review submission.	0	2	2	$145.64	 	 	33	66
$4,806

Respond to partner questions about Award Applications.	2	8	10	$797.64	 
 	10	100	$7,976

Determine which applicants deserve recognition.	6	10	16	$1,373.44	 
$5.00	33	528	$45,489

Subtotal	28	50	78	$6,652.12	 	 	 	1,044	$88,619

Provider Quarterly Reporting Form (Annualized)*	 	 	 	 	 	 	 	 
 

Update reporting form and communicate reporting requirements.	0	15	15
$1,092.30	 	 	1	15	$1,092

Maintain a tracking system to record results of report in database.	0	5
5	$364.10	 	 	33	165	$12,015

Answer partner questions about information to be submitted.	0	1	1	$72.82
 	 	10	10	$728

Compile list of number of homes and general location.	0	4	4	$291.28	 
 	33	132	$9,612

Subtotal	0	25	25	$1,820.50	 	 	 	322	$23,448

Consumer Awareness Survey	 	 	 	 	 	 	 	 	 

Craft sampling methodology.	8	24	32	$2,608.00	 	 	2	64	$5,216

Select sample.	0	24	24	$1,747.68	 	 	2	48	$3,495

Develop survey script and instructions.	10	20	30	$2,531.80	 	 	2	60
$5,064

Implement survey.	80	400	480	$37,731.20	 	$2,000.00	2	960	$79,462

Analyze data.	20	120	140	$10,889.20	 	 	2	280	$21,778

Subtotal	118	588	706	$55,507.88	 	 	 	1,412	$115,016

TOTAL	162	729.25	891.25	$70,525.47	 	 	 	4,816	$383,854



*Quarterly Reports will be requested four times a year; data will be
presented on an annual basis.

 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.

