 IDENTIFICATION OF INFORMATION COLLECTION
   
 1(a) Title of the Information Collection 
 	
Title: Pollution Prevention Awards Program 
 
ICR Number: EPA ICR No.: 2614.01; OMB Control No.: 2008-0004

Docket ID Number: EPA-R08-OPPT-2020-0013
 
 1(b) Short Characterization/Abstract
 
The Environmental Protection Agency's (EPA) Pollution Prevention (P2) program is a voluntary program that encourages companies to adopt P2 projects that reduce both financial costs (e.g. waste management and cleanup) and environmental costs (e.g. health problems and environmental damage). In passing the Pollution Prevention Act (PPA) in 1990, Congress found that "(T)here are significant opportunities for industry to reduce or prevent pollution at the source through cost-effective changes in production, operation, and raw materials use. Such changes offer industry substantial savings in reduced raw material, pollution control, and liability costs as well as help protect the environment and reduce risks to worker health and safety." 42 U.S.C. § 13101(a)(2). EPA's P2 program is largely carried out through a competitive grant process and the provision of technical assistance to businesses. P2 is any practice that reduces environmental releases of hazardous substances, pollutants, or contaminants prior to entering a waste stream for recycling, treatment, or disposal. In other words, P2 is source reduction, the prevention of waste generation and environmental releases at the source. It is not treatment, minimization, or diversion of wastes. P2 conserves natural resources, including water and energy.

Furthermore, the PPA states the Administrator shall "establish an annual awards program to recognize a company or companies which operate outstanding or innovative source reduction programs" 42 U.S.C. § 13103(b)(13). The EPA P2 Awards Program is an annual, voluntary, and non-monetary awards program that recognizes companies who demonstrate leadership in innovative P2 practices and encourage other entities to consider P2 approaches. This ICR is applicable to awards administered under the P2 Awards Program in EPA's Headquarters office and any of the 10 Regional Offices that choose to participate and implement a P2 Awards Program. 

A company's decision to participate in the EPA P2 Awards Program is voluntary. Participation in the program begins with the completion and submittal of a no-cost application, which outlines a project(s) that has been implemented and meets the goals of the P2 program. Companies who want to be recognized for an award will need to complete an application describing their P2 efforts, activities, cost savings, pounds of hazardous chemicals reduced, energy conserved, or gallons of water saved, and the replicability of their approach. In addition, the application will ask for specific information about their company, such as business size and location. Applications will be collected via an online submission webpage. Application questions will be a combination of drop-down options as well as narrative descriptions. All application submissions, scoring rubric, scoring, and decision memos will be archived and stored in accordance with all applicable records schedules. EPA P2 Coordinators will use this information in the overall evaluation, selection, and scoring process for selecting awardees. 

There will not be a monetary cost for companies to apply to the EPA P2 Awards Program. EPA anticipates it will take applicants an average of less than 11 hours to complete, review, finalize, approve, and apply.

 NEED FOR COLLECTION AND HOW INFORMATION WILL BE USED

2(a) Need/Authority for the Collection

Congress formally authorizes the P2 program in 42 U.S.C. §§13101-13109. This law may be cited as the ``Pollution Prevention Act of 1990'' and with abbreviated citation to "PPA" and the relevant section number. 

The PPA states the Administrator shall "establish an annual award program to recognize a company or companies which operate outstanding or innovative source reduction programs" (PPA 42 USC § 13103 (b)(13)).
      
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. 
Awards made under this announcement will support EPA's FY 2022- 2026 Strategic Plan (https://www.epa.gov/planandbudget/strategicplan), under Goal 7: Ensure Safety of Chemicals for People and the Environment; Objective 7.2: Promote Pollution Prevention.  The P2 program is a key element of EPA's strategic planning efforts.

As part of these 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 is required by EPA in order to meet its strategic goals and to establish an award program to recognize a company's or companies' P2 accomplishments. Participation in the awards program is voluntary.

2(b) Practical Utility/Users of the Data

The information collected by the EPA P2 Awards Program is not designed or intended to support regulatory decision-making by other EPA offices. Companies will apply voluntarily. EPA will use information from the awards application to select and recognize companies who have implemented outstanding P2 practices.

 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. EPA's P2 program anticipates implementing the award program upon approval of this ICR application. Other, non-federal partner organizations promote P2 through awards and recognition programs, but these programs are, for the most part, state-based and not offered at the regional or national level. Almost all information requested from respondents under this ICR is not available from other sources.   

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

Public comments were requested via the Federal Register on June 11, 2020 through August 10, 2020 during a 60-day comment period (85 FR 35652). 

3(c) Consultations
EPA P2 Coordinators asked previous P2 Award applicants to provide input on the EPA P2 Awards application collection efforts for this renewal package. The following partners provided input:

                                     Name 
                                  Affiliation
                                     Phone
                                    Region
Brad Russell 
Consolidated Nuclear Security 
                                 865-576-0007
                                       4
Melissa DeCino
Management and Engineering Services LLC 
                                 303-682-5992
                                       8
Jeff Edwards
Breckenridge Grand Vacations
                                 970-368-6478
                                       8
Elysa Carter
Pacific Sea Food
                                 503-905-4549
                                      10
Shasta Denoso
Exotic Metals Forming Division of Parker Aerospace
253-458-3599
                                      10
 
P2 Award applicants provided feedback on the amount of time needed to respond to the application form. EPA incorporated feedback on the time needed to complete the form in the burden estimate. Some companies provided comments on the current application stating, "the application is perfect; I really love highlighting the unintended benefits. I think highlighting that in the recognition is inspiring to discuss." One company recommended not reducing the character limit because you may lose an understanding of the breadth of some companies work. They recommend a compromise of the 500 character limit for most of the questions, adjusting the project description limit to 750 characters, and keeping the measurable results section at 1000 characters. Another respondent suggested having a place for them to say if they were assisted by an external agency with implementation of the P2 project. 

3(d) Effects of Less Frequent Collection
 
The P2 Awards application is a one-time information submittal for companies that wish to be recognized by the annual EPA P2 Awards Program for P2 activities from the previous three years. Less frequent collection of this data is not feasible because it is an annual award program. Companies may wish to submit applications in multiple years, which is voluntary. 
	
3(e) General Guidelines

All collection activities described within this ICR will adhere to OMB's General Guidelines and regulations under 5 C.F.R. § 1320.5.

3(f) Confidentiality

EPA will not require and does not expect that companies will submit confidential information in the application. However, if the applicant asserts a company's confidentiality claim for certain information provided in the application, EPA will manage that information in accordance with EPA confidentiality regulations at 40 C.F.R. § 2.201 et seq. The P2 program will use confidential company information provided by businesses solely for purposes related to forming partnerships and will disclose the information only to EPA employees and EPA contractors cleared for confidential information with a specific need to know.

3(g) Sensitive Questions
	
No questions of a sensitive nature concerning sexual behavior or attitudes, religious beliefs, or other matters usually considered private are asked in the EPA P2 Awards Program application.

 RESPONDENTS AND INFORMATION REQUESTED
   
4(a) Respondents/NAICS Codes

Respondents are various types of companies from all North American Industry Classification System (NAICS) codes that are located in a state in an EPA Region implementing this Awards Program. Applicant activity includes applying for an award, working with the respective EPA P2 Coordinator (if selected) to discuss awards presentation logistics, attending the awards presentation, and approving writeups, press releases, and presentations. If the applicant chooses, a representative can present on a webinar to inform other businesses of the benefits of implementing P2 projects and practices.
   
4(b) Information Requested

 Data items, including record keeping requirements

Each award applicant will answer the following short answer questions. Each question has a 1000-word limit and weighted value. The weights will be an important factor when scoring and ranking the applications. Each participating EPA Region will score their own applications and select winners. Therefore, only applicants within the same EPA Region are competing against each other, not against those from other Regions.  The questions below might be slightly edited over the next 3 years to improve and provide more clarity to applicants as the program continues to grow.  
      
DRAFT P2 Regional Awards Application - 2024 
If you are a company interested in gaining recognition for pollution prevention activities, please complete the form below. Companies are allowed to submit one application per facility for the awards. There is no limit to how many applications a company can submit. 
 
It is recommended that you answer the application questions in a Word or text document, then paste your responses into the form when you are ready to submit. 
 
If you would like to send any relevant photos or news article text in electronic format, please attach them (in JPGs or PDFs) in an email to p2hub@epa.gov. Include your company or organization name, primary project contact name, and phone number in the email.  

General Questions - These general questions do not have any weight to them and therefore will not be considered in application scores. The purpose of the general questions is to provide context and understand how the potential awardee would participate in outreach. 
 State - Please select the state your company is located in. If your state is not listed your company is not eligible to apply at this time.  If you are a Tribal business or a business located in Indian Country, please select the button labeled "Tribe". 
 Name of Tribe 
 Please enter the name of the Tribe where your business is located. 
 Company Name 
 NAICS Code - Business NAICS code (though this is not required, please include if your company has a NAICS code, you can lookup codes here: https://www.naics.com/search/). 
 Primary Contact Name 
 Contact Title 
 Primary Contact Email Address 
 Primary Contact Phone Number 
 Company Physical Address 
 Number of Employees 
 Description of business (what does your business do and/or make?) (No points; 300 characters). 

Application Questions:
 Company/Business Commitment - Describe your business's commitment and leadership in P2, both internally within the business and externally (e.g. with suppliers, customers, and the community). Include applicable policies, projects, employee and community engagement, and training. As a reminder, P2 does not refer to forms of disposal such as recycling, composting, waste-to-energy, etc. (25 points; 1000-character limit). 
      
 P2 Project or Practice - Describe the P2 project or practice implemented within the past three years which reduced water or energy use, reduced hazardous chemical use, resulted in emissions avoided, and/or reduced hazardous waste. Please briefly address: a) how the initiative was generated; b) overview of the P2 actions; c) what needs of the organization were addressed; d) what unintended benefits were realized. Only include projects that were implemented between January 1, 2021-December 31, 2023. (25 points; 1000 characters). 

 Measurable Results - Describe any measurable results from your P2 project. For example, any cost savings, pounds of hazardous chemicals and/or materials reduced, energy conserved or offset, (kilowatt hours, BTUs or therms), metric tons of carbon dioxide equivalent avoided, and/or gallons of water saved. (25 points; 1000 -characters). 

 P2 Benefits - Describe how your P2 efforts benefited your business and the surrounding community. Describe how your business serves as a model for entities with similar processes or environmental challenges. (15 points; 500-characters). 

 P2 Goals - Describe your business's specific, measurable P2 goals for the coming year. (10 points; 250-character limit). 

 Promotional Materials - Is your business willing to be featured in publicly available newsletters, case studies, or webinars, or on an EPA website? 

 Webinar Participation - Is someone within your business willing to participate (about 15 minutes) in a webinar for other businesses considering P2 strategies? 
 Respondent Activities
            
This is a voluntary, non-monetary awards program. Applicant activities include reviewing program instructions and eligibility requirements, gaining approval from management to apply, collecting relevant information, completing the application and supplementary materials, and submitting the application. Applicants have the information and data readily available to answer the listed short answer questions. The amount of time and effort expended to apply depends on the specific circumstances of the company. EPA does not expect that applicants will expend significant time or resources reviewing instructions, collecting information and completing the application. Furthermore, the time, effort and resources necessary to respond to several questions in the application will be incurred by persons in the normal course of their activities, which is excluded from the "burden" calculation under the Paperwork Reduction Act, see 5 C.F.R. § 1320.3(b)(2).
   
 INFORMATION COLLECTED  -  AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT

5(a) Agency Activities

EPA will engage in the following activities related to the awards application:

 Update the application to be submitted by companies, post Awards Program information to the P2 website and/or Regional P2 website and communicate the solicitation period and requirements for applying to internal and external parties.
 Create and maintain a tracking system to record each participant's application. 
 Respond to questions pertaining to the application. 
 Review all submissions and select awardees.
 Each region will have flexibility on type of award (plaque, certificate) and will purchase and present them to those selected. 
 Each Region will have flexibility on when and where to present awards.
 Develop awardee summaries for P2 websites. 

5(b) Collection Methodology and Management

In collecting and analyzing the information associated with this ICR, EPA will use electronic form software, telephones, and computers, including Microsoft Office products. Each application will be saved electronically in a Regionally designated tracking system to assure all applications are accounted for. All applications received by an EPA Region will be used in the Awards Program review process. EPA will ensure the reasonableness and completeness of collected information by reviewing each submittal.   

EPA will offer all information collection instruments electronically with hard-copy versions available upon request. Electronic submissions do not have a significant impact on respondent or Agency burden. The additional burden of hard-copy submissions is minimal for the risk reduction.

To conserve resources, EPA will encourage and promote the use of electronic submissions via EPA's P2 website; however, hard copy submissions will be permitted upon request. The website will automatically email the applications to the respective Regional P2 Coordinator. Existing Regional Awards Programs have demonstrated the success of this website submission system. 

5(c) Small Entity Flexibility

All data collected under this ICR is voluntarily reported. EPA expects that some of the companies will be small entities. EPA has designed its reporting materials to minimize respondent burden while obtaining sufficient and accurate information. EPA considered the less burdensome collection mechanism of evaluating case studies within EPA's P2 case study database, but this collection mechanism was not adopted for the following reasons: (1) EPA's database of case studies is not inclusive of all P2 projects carried out over the last 3 years that would be eligible for P2 Awards and (2) EPA's database of case studies largely only capture activities supported by the EPA Pollution Prevention and Source Reduction Assistance grant programs. Applicants to the P2 Awards Program are not required to have been supported by EPA's grant programs.

5(d) Collection Schedule

Businesses or organizations may voluntarily submit an application during the solicitation period. The solicitation period will be done on an annual basis and is open for approximately 2 months, once posted. The timing of open solicitation is dependent upon regional discretion but cannot be less than 40 business days.   

 ESTIMATING COLLECTION BURDEN AND COST
   
6(a) Estimating Respondent Burden

For this renewal, EPA used input from existing EPA P2 award applicants to estimate the burden for respondents. Table 1 presents the annual burden hours and costs per respondent as well as the total burden hours and costs per Region during each of the three years covered under this ICR.

6(b) Estimating Respondent Costs

EPA estimates receiving a total of 126 applications over the 3-year ICR period. 7 applications in 6 different regions as the program continues to grow.  Table 1 shows the aggregate annual respondent burden and costs for the information collection activities associated with the EPA P2 Awards Program. 

 Estimating Respondent 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 on employment and earnings. Rates include the cost of overhead. EPA estimates an average respondent's hourly labor rate (e.g. hourly plus overhead) of $104.96 for managerial staff, $68.86 for technical staff, and $36.44 for clerical staff.

 Estimating Respondent Capital and Operations and Maintenance Costs

Companies who choose to participate in the awards program will be requested to submit materials electronically and retain materials in electronic format to conserve paper. For this reason, EPA does not estimate costs for copying and mailing. We estimate 6 regions will implement an award program during the 3-year ICR period and will calculate total amounts for the 6 regions. 


Table 1. Respondent Burden and Costs 
Totals were rounded to nearest decimal.

                    Average Hours and Costs Per Respondent
                       Total Hours and Costs Per Region
                        Information Collection Activity
                                    Manager
                                   Technical
                                   Clerical
                            Respond Hours Per Year
                             Labor Costs 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
                                                                       $104.96 
                                                                        $68.86 
                                                                        $36.44 
                                                                               






                               Award Application
                                       









Review instructions and eligibility requirements

                                                                              3
                                                                               
                                                                              3
                                                                       $206.58 
                                                                              0
                                                                              0
                                                                              7
                                                                             21
                                                                     $1,446.06 
Gather Information
                                                                              1
                                                                             34
                                                                               
                                                                             35
                                                                     $2,446.20 
                                                                              0
                                                                              0
                                                                              7
                                                                            245
                                                                    $17,123.40 
Complete application form and optional supplemental materials
                                                                              4
                                                                              8
                                                                            1.5
                                                                           13.5
                                                                     $1,025.38 
                                                                              0
                                                                              0
                                                                              7
                                                                           94.5
                                                                     $7,177.66 
Submit the application online
                                                                              0
                                                                              3
                                                                               
                                                                              3
                                                                       $206.58 
                                                                              0
                                                                              0
                                                                              7
                                                                             21
                                                                     $1,446.06 
Total all respondents combined
                                                                              5
                                                                             48
                                                                            1.5
                                                                           54.5
                                                                     $3,884.74 
                                                                              0
                                                                              0
                                                                               
                                                                          381.5
                                                                    $27,193.18 
Average (divided by 5 respondents)
                                                                              1
                                                                            9.6
                                                                            0.3
                                                                           10.9
                                                                       $776.95 
                                                                               


                                                                           76.3
                                                                     $5,438.64 
Total Amount for 6 Regions

                                                                               
                                                                               
                                                                               




                                                                          457.8
                                                                    $32,631.82 
Total Burden over 3 year period

                                                                               
                                                                               
                                                                               




                                                                         1373.4
                                                                    $97,895.45 




6(c) Estimating Agency Burden and Costs

EPA P2 Coordinators drew on past P2 Regional Award Applicants for this renewal to estimate staff burden estimates. Table 2 presents the annual burden hours and costs per respondent application as well as the total burden hours and costs per EPA Region during each of the three years covered under this ICR.

Table 2 shows the aggregate annual Agency burden and costs for the information collection activities associated with the EPA P2 Awards Program. The annual hourly burden is approximately 136 hours at a cost of $13,287 per EPA Region. The three-year, bottom-line Agency burden for the life of this ICR is approximately 2448 hours at a cost of $239,175 (6 regions over 3 years).

             Estimating Agency Labor Costs

The hourly labor rates used to determine the estimated costs to the Agency are based on the 2023 GS pay schedule for Washington D.C. locality pay available from the Office of Personnel Management. EPA estimates an average hourly labor cost of $135.28 for managerial staff and $91.60 for professional staff. The labor costs are based on the following GS levels and steps: GS Level 15 Step 5 for managerial rate and GS Level 13 Step 3 for professional rate. EPA multiplied hourly rates by the standard government overhead factor of 1.6. 


Table 2. Agency Burden and Costs

                        Hours and Costs Per Application
                       Total Hours and Costs Per Region
                        Information Collection Activity
                                    Manager
                                 Professional
                             Agency Hours Per Year
                             Labor Costs Per Year
                          Annual Capital Starup Costs
                             Annual O&M Costs
                       No. of Agency Activities Per Year
                          Total Agency Hours Per Year
                              Total Cost Per year
                                                                    Hourly Rate
                                                                       $135.28 
                                                                        $91.60 
                                                                               






                               Award Application
                                       








Update application to be submitted by applicants, post to website, and communicate requirements for applying
                                                                              5
                                                                             40
                                                                             45
                                                                     $4,340.40 
                                                                              0
                                                                              0
                                                                              1
                                                                             45
                                                                     $4,340.40 
Maintain a tracking system to record each applicant's award application status and review submission

                                                                              5
                                                                              5
                                                                       $458.00 
                                                                              0
                                                                              0
                                                                              7
                                                                             35
                                                                     $3,206.00 
Respond to applicant questions about award applications

                                                                              1
                                                                              1
                                                                        $91.60 
                                                                              0
                                                                              0
                                                                              7
                                                                              7
                                                                       $641.20 
Determine which applicants deserve recognition
                                                                              2
                                                                              5
                                                                              7
                                                                       $728.56 
                                                                              0
                                                                              0
                                                                              7
                                                                             49
                                                                     $5,099.92 
Total
                                                                              7
                                                                             51
                                                                             58
                                                                     $5,618.56 
                                                                              0
                                                                              0
                                                                               
                                                                            136
                                                                    $13,287.52 
Total Amount for 6 Regions
                                                                             42
                                                                            306
                                                                            348
                                                                    $33,711.36 
                                                                               


                                                                            816
                                                                    $79,725.12 
Total Burden over 3 year period
                                                                            126
                                                                            918
                                                                           1044
                                                                   $101,134.08 
                                                                               


                                                                           2448
                                                                   $239,175.36 

6(d) Estimating the Respondent Universe and Total Burden and Costs
      
See Table 1 for burden calculations.

6(e) Bottom-Line Burden Hours and Cost Tables
      
The three-year, bottom-line respondent burden for the life of this ICR is outlined below. 

TOTAL NO. OF RESPONDENTS:               126 (for 6 regions over 3 years)                    
TOTAL NO. OF RESPONSES:                 	126 (for 6 regions over 3 years)                        
TOTAL BURDEN HOURS:                          1,373 (for 6 regions over 3 years)       
TOTAL COST TO RESPONDENTS:      	$97,895 (for 6 regions over 3 years) 

6(f) Reasons for Change in Burden
      
Since the initial ICR was approved in 2021 we have a better estimate on how many applications will be received in each region, how many regions are interested in implementing regional award programs, and how long it takes respondents to fill out the application. When the initial ICR was written, the P2 program used estimations and also reached out to State recognition programs to assist us with calculating the burden. State recognition programs are more rigorous and time consuming, therefore our original burden was calculated higher than we anticipated the burden may be.  We originally estimated each region would receive approximately 10 applications each year and that 5 regions would implement award programs.  Over the last three years, we had an averge of around 6 applications per region and only 3-4 regions implemented award programs. For this ICR we are estimating 6 regions will implement award programs and we will receive an average of 7 applications per region. Additionally, we had a small universe of past P2 awardees that assisted us with calculating the actual total burden hours, which we did not have when we initially launched this program.  The overall burden estimate for this collection is 1,552 hours lower than the current ICR.

6(g) Burden Statement
      
 Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency.  This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number.  The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.  
 
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 Number EPA-R08-OPPT-2020-0013 online using www.regulations.gov (our preferred method), by email to payan.melissa@epa.gov or by mail to: EPA R8, 1595 Wynkoop St. Mail Code 8LCRD-CSES, Denver, CO 80202, which is available for online viewing at www.regulations.gov, or in person viewing at the P2 Regional Award Program in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Avenue, NW, Washington, D.C.  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 P2 Regional Award Program is (303) 312-6157.  An electronic version of the public docket is available at www.regulations.gov.  This site can be used to submit or view public comments, access the index listing of the contents of the public docket, and to access those documents in the public docket that are available electronically.  When in the system, select "search," then key in the Docket ID Number identified above.  Also, you can send comments to the Office of Information and Regulatory Affairs, Office of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk Officer for EPA.  Please include the EPA Docket ID Number EPA-R08-OPPT-2020-0013 and OMB Control Number 2008-NEW in any correspondence.


