2233ss01

1. IDENTIFICATION OF THE INFORMATION COLLECTION

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

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

1(b) Short Characterization

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

• Irrigation and landscaping certification programs

• Residential toilets

• Residential faucets

• Irrigation controllers

• Irrigation sensors

• Commercial toilets

• Commercial faucets

• Commercial faucet sensor devices

• Drip/micro irrigation equipment

• Commercial autoclaves

• Commercial medical vacuums

• Commercial image processors

• “Water efficient” new homes
  
  

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

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

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

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

2. NEED FOR AND USE OF THE COLLECTION

2(a) Need and Authority for the Collection

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

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

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

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

2(b) Practical Utility/Users of the Data

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

Partnership Agreement

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

New Certified Product Notification Form

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

Promotional Plan Checklist

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

Annual Update

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

Award Application Form

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

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

3(a) Nonduplication

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

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

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

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

3(c) Consultations

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

Dana Lonn		The Toro Company
Jill Hoyenga		Eugene Power and Water
Pete DeMarco		American Standard, Inc.
Tom Penning		Irrometer
John Koeller		Koeller and Company

3(d) Effects of Less Frequent Collection

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

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

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

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

3(e) General Guidelines

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

3(f) Confidentiality

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

3(g) Sensitive Questions

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

4. THE RESPONDENTS AND THE INFORMATION REQUESTED

4(a) Respondents and NAICS Codes

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

NAICS codes for likely manufacturing partners include:

NAICS Code	2002 NAICS U.S. Title	Index Entry
332998	Enameled Iron and Metal Sanitary Ware Manufacturing	Toilet fixtures, metal, manufacturing
326191	Plastics Plumbing Fixture Manufacturing	Toilet fixtures, plastics, manufacturing
332913	Plumbing Fixture Fitting and Trim Manufacturing	Faucets, plumbing, manufacturing
221310	Water Supply and Irrigation Systems	Irrigation system operation
339114	Dental Equipment and Supplies Manufacturing	Autoclaves, dental, manufacturing
339111	Laboratory Apparatus and Furniture Manufacturing	Autoclaves, laboratory-type (except dental), manufacturing
236116	New Multifamily Housing Construction (except Operative Builders)	Home builders (except operative), multifamily
236115	New Single-Family Housing Construction (except Operative Builders)	Home builders (except operative), single-family
236117	New Housing Operative Builders	Home builders, operative

4(b) Information Requested

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

Partnership Agreement

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

(i) Data items:

The reporting items include:

• Organization name.

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

• Approximate number of employees at the joining organization.

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

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

(ii) Respondent activities:

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

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

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

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

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

New Certified Product Notification Form

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

1. Data items:

The reporting items include:

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

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

(ii) Respondent activities:

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

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

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

Promotional Plan Checklist

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

1. Data items:

The reporting items include:

• Current and planned promotional efforts.

• Planned uses of WaterSense program logo.

• Identification of areas where EPA could assist in future promotional efforts

2. Respondent Activities

• Identify planned promotional activities.

• Review instructions

• Complete the checklist.

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

Annual Update

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

(i) Data items:

The reporting items include:

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

• Current Water Efficient Products, Services, and Activities

As applicable:

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

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

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

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

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

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

• Signature and title of principal contact and date.

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

(ii) Respondent activities:

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

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

• Review instructions for completing the annual update.

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

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

• Respond to EPA questions to clarify data.

Award Application

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

1. Data items:

The application items include:

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

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

2. Respondent activities:

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

• Review instructions and eligibility requirements.

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

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

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

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

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

5(a) Agency Activities

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

Partnership Agreement

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

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

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

• Sign agreement.

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

New Certified Product Notification Form

• Develop notification form.

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

• Answer partner questions about information to be submitted.

• Review completed forms submitted by partners.

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

• Enter data into program database.

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

• Disseminate updated lists as needed.

Promotional Plan Checklist

• Develop checklist to be submitted by partners.

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

• Answer partner questions about information to be submitted.

• Review completed checklist submitted by partner.

• Respond to partner.

• Enter data into program database.

Annual Update

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

• Answer questions regarding the Annual Update.

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

• Record/enter information into a database.

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

Award Application

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

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

• Respond to partner questions about award applications.

• Determine which applications deserve recognition.

• Provide recognition through website, award ceremony or other means.

5(b) Collection Methodology and Management

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

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

5(c) Small Entity Flexibility

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

5(d) Collection Schedule

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

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION

6(a) Estimating Respondent Burden

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

6(b) Estimating Respondent Costs

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

Estimating Labor Costs

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

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

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

6(c) Estimating Agency Burden and Costs

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

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

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

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

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

Partnership Agreement

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

New Certified Product Notification Form

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

Promotional Plan Checklist

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

Annual Update

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

Award Application

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

Total Burden and Costs

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

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

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

Respondents	Respondents/Year	Burden Hours/Year	Respondents over Three Years	Total Burden Hours over Three Years
State, local, and tribal government	214	3,360	642	10,080
Private Sector	427	6,721	1,281	20,163
Individuals	5,000	40,000	15,000	120,000

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

Respondents	Total Labor Costs/Year	Total Capital/O&M Costs/Year	Total Costs/Year	Total Costs over Three Years
State, local, and tribal government	$218,120	$2,117	$220,237	$660,711
Private sector	$436,283	$123,286	$559,569	$1,678,707
Individuals	$2,592,000	$0	$2,592,000	$7,776,000

6(e) Bottom Line Burden Hours and Costs Tables

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

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

	Burden Hours	Total Labor Costs/Year	Total Nonlabor Costs/Year	Total Cost
Respondents	50,081	$3,246,424	$125,403	$3,371,827
Agency	16,441	$624,549	$14,897	$639,446
Total	66,522	$3,870,973	$140,300	$4,011,273

6(f) Reasons for Change in Burden

This ICR does not modify an existing ICR.

6(g) Burden Statement

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

Partnership Agreement

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

New Certified Product Notification Form

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

Promotional Plan Checklist

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

Annual Update

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

Awards Application

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

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

To comment on the Agency's need for this information, the accuracy of the provided burden estimates, and any suggested methods for minimizing respondent burden, including the use of automated collection techniques, EPA has established a public docket for this ICR under Docket ID No EPA-HQ-OW-2006-0408, which is available for public viewing at the Office of Water Docket in the EPA Docket Center (EPA/DC), EPA West, Room 3334, 1301 Constitution Ave., NW, Washington, DC. The EPA Docket Center Public Reading Room is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding legal holidays. The telephone number for the Reading Room is (202) 566-1744, and the telephone number for the Office of Water Docket is (202) 566-2426. Use www.regulations.gov to obtain a copy of the draft collection of information, submit or view public comments, access the index listing of the contents of the docket, and to access those documents in the public docket that are available electronically. Once in the system, select “search,” then key in the docket ID number EPA-HQ-OW-2006-0408.

Exhibit 1: Estimated Respondent Burden

Information Collection Activity	Hours and Costs Per Respondent/Labeled Product							Total Hours and Costs
	Manager	Technical	Clerical	Respond Hours/Year	Labor Costs per Year	Annual Capital Startup Costs	Annual O&M Costs	No. of Respond./ Activities	Total Respond. Hours/Year	Total Cost/Year
Hourly Rate	79.49	64.8	34.86
Partnership Agreement
Review the EPA Water Efficiency Web site, brochure, agreement, and other necessary materials	1	2	0	3	$209			100	300	$20,909
Select a primary contact person for the program	1	0	0	1	$79			100	100	$7,949
Complete the PA, obtain signature of senior official	0.5	1.5	1	3	$172		$5.00	100	300	$17,681
Send the completed agreement to EPA via fax, mail, or online	0	0	1	1	$35		$5.00	100	100	$3,986
Subtotal	2.5	3.5	2	8	$495				800	$50,525
Partnership Agreement: Certified Professionals
Review the EPA Water Efficiency Web site, brochure, agreement, and other necessary materials	0	4	0	4	$259			5000	20,000	$1,296,000
Complete the PA	0	3	0	3	$194			5000	15,000	$972,000
Send the completed agreement to EPA via fax, mail, or online	0	1	0	1	$65			5000	5,000	$324,000
Subtotal	0	8	0	8	$518				40,000	$2,592,000
New Certified Product Notification Form
Apply for label from certification board	1	8	0	9	$598	$897.33	$50.00	125.67	1,131	$194,188
Collect records of each service or product	0	2	0	2	$130		$5.00	125.67	251	$16,915
Select a primary contact person for questions from EPA's Water Efficiency Team	1	1	0	2	$144			125.67	251	$18,133
Complete the Product or Service Application	1	6	0	7	$468			125.67	880	$58,850
Send the completed application to EPA via fax, mail, or online	0	0	1	1	$35		$10.00	125.67	126	$5,638
Subtotal	3	17	1	21	$1,375				2,639	$293,723

Promotional Plan
Identify planned promotional activities	2	8	0	10	$677			191.67	1,917	$129,833
Review instructions	0	1	0	1	$65			191.67	192	$12,420
Complete the checklist	0	1	0	1	$65			191.67	192	$12,420
Send the completed checklist to EPA via fax, mail or online	0	0	1	1	$35		$2.00	191.67	192	$7,065
Subtotal	2	10	1	13	$842				2,492	$161,739
Annual Updates
Collect and review records to assess product information, purchased prodcuts or services, rebate informationduring the reporting year	1	10	0	11	$727			191.67	2,108	$139,438
Review Instructions	0	1	0	1	$65			191.67	192	$12,420
Complete the Annual Update	1	3	0	4	$274		$5.00	191.67	767	$53,455
Send the completed update to EPA via fax, mail, or online	0	0	1	1	$35		$5.00	191.67	192	$7,640
Respond to EPA questions to clarify data	0	1	0	1	$65			191.67	192	$12,420
Subtotal	2	15	1	18	$1,166				3,450	$225,373
Award Applications
Review instructions and eligibility requirements	1	1	0	2	$144			33.33	67	$4,810
Gather data and determine award category	2	5	0	7	$483		$5.00	33.33	233	$16,266
Complete application and supplemental materials	3	8	0	11	$757		$10.00	33.33	367	$25,562
Submit the application via fax, mail, or online	0	0	1	1	$35		$20.00	33.33	33	$1,829
Subtotal	6	14	1	21	$1,419				700	$48,467
TOTAL	15.5	67.5	6	89	$5,815			5,642	50,081	$3,371,827

Exhibit 2: Estimated Agency Burden

Information Collection Activity	Hours and Costs Per Respondent/Labeled Product							Total Hours and Costs
	Manager	Technical	Clerical	Respond Hours/Year	Labor Costs per Year	Annual Capital Startup Costs	Annual O&M Costs	No. of Respond./ Activities	Total Respond. Hours/Year	Total Cost/Year
Hourly Rate	62.91	46.11	18.51
Partnership Agreement
Develop Partnership Agreements and post to Web site	2	6	0.5	8.5	$412			8	68	$3,294
Answer questions posed by potential participants regarding membership in the program.	0	2	0	2	$92			100	200	$9,222
Review completed agreements, record/enter information into a database, and EPA’s Water Efficiency Program Web site	1	4	4	9	$321			100	900	$32,139
Sign agreement	0.5	0.5	1	2	$73		$2.00	5100	10,200	$382,602
Subtotal	3.5	12.5	5.5	21.5	$898				11,368	$427,257
New Certified Product Notification Form
Develop application materials to be submitted by partners and post to Web site	2	8	0	10	$495			13	130	$6,431
Review completed applications submitted by partner	0.5	2	0	2.5	$124		$5.00	125.67	314	$16,171
Enter data into program database	0	1	2	3	$83			125.67	377	$10,447
Compile list of products by product type to post on EPA’s Water Efficiency Program Web site	0	4	0	4	$184			125.67	503	$23,179
Disseminate updated list as requested	0	1	2	3	$83		$20.00	125.67	377	$12,960
Subtotal	2.5	16	4	22.5	$969				1,701	$69,188

Promotional Plan Checklist
Develop checklist to be submitted by partners and post to Web site	1	4	2	7	$284			1	7	$284
Answer partner questions about information to be submitted	0	2	0	2	$92		$2.00	191.67	383	$18,059
Review completed checklist submitted by partner	0	2	0	2	$92		$1.00	191.67	383	$17,867
Enter data into program database	0	1	1	2	$65			191.67	383	$12,386
Subtotal	1	9	3	13	$533				1,157	$48,597
Annual Updates
Maintain a tracking system and develop/revise standard data reports	10	40	10	60	$2,659			1	60	$2,659
Answer questions regarding the Annual Update	0	2	0	2	$92		$2.00	191.67	383	$18,059
Receive and review the plans for consistency and completeness and place any follow-up calls necessary	1	3	0	4	$201		$1.00	191.67	767	$38,763
Record/enter information into a database	0	0	2	2	$37			191.67	383	$7,096
Develop annual data summary	10	100	20	130	$5,610		$5.00	1	130	$5,615
Subtotal	21	145	32	198	$8,599				1,723	$72,192
Award Applications
Maintain a tracking system to record each participant’s award application status	0	20	5	25	$1,015			1	25	$1,015
Develop application to be submitted by partners and post to Web site	0	2	0	2	$92			33	67	$3,074
Respond to partner questions about award applications	2	8	2	12	$532		$2.00	33	400	$17,791
Determine which applications deserve recognition	0	0	0	0	$0		$10.00	33	0	$333
Subtotal	2	30	7	39	$1,639				492	$22,213
TOTAL	30	212.5	51.5	294	$12,639				16,441	$639,446

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