1849ss09

1849ss09.pdf

Landfill Methane Outreach Program (Renewal)

OMB: 2060-0446

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 2060-0446 can be found here:

2022-03-25 - Extension without change of a currently approved collection

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SUPPORTING STATEMENT FOR
LANDFILL METHANE OUTREACH PROGRAM,
EPA INFORMATION COLLECTION REQUEST NUMBER 1849.09

January 2019

1. IDENTIFICATION OF THE INFORMATION COLLECTION
1(a)

Title of the Information Collection

This renewal information collection is entitled “Landfill Methane Outreach Program,” ICR
number 1849.09, OMB Control Number 2060-0446.
1(b)

Short Characterization/Abstract

The figures within this supporting statement have been updated for this ICR renewal.
The Landfill Methane Outreach Program (LMOP) is a voluntary program started in 1994
designed to encourage and facilitate the development of environmentally and economically sound
landfill gas (LFG) energy projects across the United States in order to reduce methane emissions
from landfills. LMOP does this by educating local governments and communities about the
benefits of LFG recovery and use; building partnerships between state agencies, industry, energy
service providers, local communities, and other stakeholders interested in developing this valuable
resource in their community; and providing tools to evaluate LFG energy potential.
To continue to be successful it is critical that LMOP gather information from its Partners
about their activities and how the program can improve its support to them. Additionally, for
LMOP to improve the data quality in one of its critical program tools, the LMOP Landfill and
LFG Energy Project Database (LMOP Database), LMOP must gather basic physical and
operational data from municipal solid waste (MSW) landfills without LFG energy projects.
Improving the data quality in this tool will enable LMOP to identify landfills that are good
candidates for LFG energy projects, improve estimates of methane emissions from landfills, and
help LMOP and its Partners prioritize LFG energy project development assistance activities.
Partners are entities that have volunteered to participate in LMOP. LMOP classifies these
Partners into one of five categories: Community Partners, State Partners, Industry Partners, Energy
Partners, and Endorsers. There are three general categories of information collected from the
Partners:
•

Memoranda of understanding (MOU) (electronic format);

•

Annual information on LFG energy projects and MSW landfills with which the
organization is involved (LFG energy project and landfill data) (electronic
format); and

•

Periodic information updates (electronic format).

As described in the 2016 ICR renewal, LMOP developed electronic data collection to
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replace the previous data collection method of emailing Excel spreadsheets to respondents. In 2018,
LMOP transitioned to collecting information on LFG energy project and landfill data via electronic
collection through the Agency’s electronic Greenhouse Gas Reporting Tool (e-GGRT) system. The
Program received authorization for this non-substantive change from OMB on August 29, 2018.
EPA updated its burden estimates for this ICR renewal to reflect this electronic collection method.
Utilizing this electronic collection method is estimated to reduce burden by 0.75 hours per
respondent involved in this task. In total, the burden is reduced by approximately 252 hours per year
for all respondents. Further, electronic data collection is estimated to reduce the Agency’s burden by
199 hours per year.
The LMOP information collection is expected to involve an average of 1,137 existing
Partners and an additional 25 new Partners per year.
This ICR provides a comprehensive description of the information collections under
LMOP. Sections 1 through 5 of this ICR describe the specific information collections (e.g., from
the standpoint of need, use, and respondent activities). In Section 6, EPA estimates the annual
hour and cost burden to respondents and the Agency under these collections.
2. NEED FOR AND USE OF THIS COLLECTION
2(a)

Need/Authority for the Collection

EPA needs to collect the information in the MOU to formally establish participation in
LMOP and to obtain general information about new Partners. Additional LFG energy project and
landfill data collected from certain types of Partners is needed to allow EPA to track, facilitate,
and encourage the implementation of LFG energy projects. This information collection will assist
LMOP in decreasing methane emissions from landfills, increasing the use of methane as a
renewable energy resource, and reducing emissions due to the burning of non-renewable energy
resources such as coal and fuel oil.
All participants, in completing the MOU, agree to provide EPA with information
requested in the MOU and provide contact information for LMOP. Industry Developer and Energy
Partners agree to provide information on LFG energy projects with which they have been
involved. Community Partners agree to provide information on the progress of implementing
LFG energy projects at their landfill(s).
2(b)

Practical Utility/Users of the Data
3

EPA uses information submitted in the MOU to update its database of LMOP Partners.
The database serves as a source of general information and an electronic mailing list. EPA uses
LFG energy project and landfill data submitted by Industry Developer, Energy, and Community
Partners to monitor the progress of LFG energy projects and identify opportunities for new
projects. EPA also uses the data to update the LMOP Database, which is used to prepare reports on
LFG energy projects and the progress of LMOP. EPA uses case studies of successful LFG
energy projects to demonstrate to existing and potential Partners the cost savings and
environmental benefits associated with capturing and using LFG. General information about the
Partners, operational and under construction LFG energy projects, and landfills that may have
potential for developing LFG energy projects is provided on the LMOP website, making it
available to other LMOP Partners as well as the public. These data files were downloaded from
the LMOP website over 4,700 times during calendar year 2017. During EPA fiscal year 2017,
LMOP processed approximately 35 data requests from the public that required accessing data in
the LMOP Database.

3. NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
3(a)

Nonduplication

For new Partners, the information to be collected has not previously been collected by
EPA or any other Federal Agency. For existing Partners with LFG energy projects, some of the
information requested may be available in the existing LMOP Database. To avoid requesting
information that has already been collected, data update requests sent to existing Partners are prepopulated with information from the LMOP Database. Users of the electronic collection system are
asked to review the information presented. The recipients are requested to provide updated or
additional information only if the information is incorrect or incomplete.
EPA began annually collecting certain technical and informational data from MSW
landfills under the Greenhouse Gas Reporting Program (GHGRP) 40 CFR part 98, subpart HH
in 2011. Where data fields overlap (e.g., landfill open and closure years, landfill design capacity,
amount of LFG collected), EPA updates the LMOP Database with data from the GHGRP.
Where LMOP Partners and those entities covered under GHGRP, subpart HH, are the same
organizations, LMOP does not request the same data. As stated above, LMOP pre-populates the
data fields with applicable data from GHGRP, subpart HH.
4

3(b)

Public Notice Required Prior to ICR Submission to OMB

In compliance with the Paperwork Reduction Act of 1995, EPA solicited public comments
on the ICR through an announcement in the Federal Register on September 5, 2018 (83 FR
45124). The Agency did not receive any comments on this ICR renewal.
3(c)

Consultations

In 2018, LMOP attempted to contact fewer than nine Partners regarding the burden of this
information collection, specifically in regards to the electronic collection system (e-GGRT) which
is now used for collecting information from Partners on landfill and LFG energy project data. All
Partners contacted had experience using the new electronic collection system during 2018. The
Partners contacted agreed that the estimated burden for their Partner type was what they would
expect for this effort.
One Partner commented that the burden estimate for accessing the e-GGRT system was
too low. The burden for this specific task is covered under Cross-Media Electronic Reporting
Rule ICR (OMB Control No. 2025-0003) and is outside of the scope of the LMOP ICR to change.
Table 1: List of Partner Consultations Made in 2018
Partner Type

Contact Person, Organization

Industry Partner

Ken Robbins, Casella Waste Systems, Inc.

Industry Partner

Tim Keesling, Enerdyne Power Systems, Inc.

Community Partner

Cliff Shierk, Minnesota Pollution Control Agency

3(d)

Comments on Burden
Estimate
Burden estimate is accurate
based on his experience.
Burden estimate for LMOP
data entry is accurate based
on his experience; burden
estimate for task of
accessing e-GGRT system is
too low (this feedback is out
of scope of LMOP ICR).
Burden estimate is accurate
based on his experience.

Effects of Less Frequent Collection

The MOU are submitted once by organizations that choose to become Partners of LMOP.
To allow EPA to remain current on LFG energy projects, Industry Developer, Energy, and
Community Partners directly involved in projects will be asked annually to update their LFG
energy project and landfill data. All Partners may also update company and contact information
periodically as needed. EPA believes that any reduction in the frequency of this information

collection would impede efforts by EPA to evaluate results of the program, facilitate LFG energy
project implementation, and respond in a timely manner to needs of the Partners.
3(e)

General Guidelines

This information collection request was prepared in compliance with OMB’s and EPA’s
guidelines for ICR preparation.
3(f)

Confidentiality

Participants are not required to reveal confidential business information. Additionally,
participants are given specific instructions to not provide any information that they consider
confidential.
3(g)

Sensitive Questions

No questions of a sensitive nature are asked in the MOU, requests for LFG energy project
and landfill data, or periodic information updates.

4. THE RESPONDENTS AND THE INFORMATION REQUESTED
4(a)

Respondent NAICS Codes

This information collection will encompass a wide variety of respondents. Community
Partners include local agencies and municipalities that own landfills. State agencies involved in
energy, air pollution, and solid waste management are represented through State Partners. Industry
Partners include engine and turbine manufacturers, engineering firms, construction companies,
environmental consultants, and other companies involved in the logistics of developing LFG energy
projects such as law firms and financing companies. Industry Partners are further divided into two
groups: (1) developers are organizations that facilitate, finance, and implement LFG energy
projects; (2) non-developers are manufacturers or suppliers of equipment or expertise needed to
collect and utilize LFG. Energy Partners include utility companies who purchase energy generated
from landfills, power marketers, and direct end users of energy from the landfill. The direct end user
category is potentially the most diverse category. Any facility located near a landfill that utilizes fuel
either in manufacturing products or in heating the facility is a potential LFG end user. Finally,
Endorsers are non-profit organizations coordinating with EPA to publicize and promote the use of
LFG among their members or constituents. These include several trade associations representing
the solid waste industry, public works, municipalities, and renewable energy. Table 2 provides the
North American Industry Classification System (NAICS) code and description for the respondents.
6

Table 2: Respondents to Information Collection
Partner Type
Community Partners
and State Partners

Industry Partners

Energy Partners
Direct usersa

Power marketers
and utilities

Endorsers

NAICS Code
924

NAICS Description
Public Administration, Administration of
Environmental Quality Programs

924110

Public Administration, Administration of Air and
Water Resource and Solid Waste Management
Programs

926130

Public Administration, Regulation and Administration
of Communications, Electric, Gas, and Other Utilities

333611
333618
522110

Turbine and Turbine Generator Set Units Manufacturing
Other Engine Equipment Manufacturing
Commercial Banking

523910

Financial Investments and Related Activities,
Miscellaneous Intermediation

541110
541330
541620
562212

Offices of Lawyers
Engineering Services
Environmental Consulting Services

221210
312120
314110
322291
325193
329199
325212
325412
325414
327120
327310
336111
336120

Natural Gas Distribution
Breweries
Carpet and Rug Mills
Sanitary Paper Product Manufacturing
Ethyl Alcohol Manufacturing
All Other Basic Organic Chemical Manufacturing
Synthetic Rubber Manufacturing
Pharmaceutical Preparation Manufacturing
Biological Product (except Diagnostic) Manufacturing
Clay Building Material and Refractories Manufacturing
Cement Manufacturing
Automobile Manufacturing
Heavy Duty Truck Manufacturing

611310

Colleges, Universities, and Professional Schools

221121
221122

Electric Bulk Power Transmission and Control
Electric Power Distribution

221118

Other Electric Power Generation

813910

Business Associations

Administrative and Support and Waste Management
and Remediation Services, Solid Waste Landfill

a. There is a wide variety of entities that could become direct LFG users. Any facility near a landfill that
uses fuel is a potential direct user. A subset of the NAICS codes and descriptions from current direct
energy users who are LMOP Partners are included in Table 2.

4(b)

Information Requested

(i)

Data Items, Including Recordkeeping Requirements

Information will be collected in MOU, requests for LFG energy project and landfill data,
and through periodic updates. The MOU request the following information from all Partners:
•

Name of the organization;

•

Signature, including electronic signature, of authorized representative with
authorized representative’s printed name and the date of the signature;

•

Information about the primary contact person including name, title, work
address, phone number, fax number, and email address;

•

Brief description of the organization;

•

Organization’s website address; and

•

A camera-ready copy of the organization’s logo or seal.

Requests for LFG energy project and landfill data are sent to Industry Developer, Energy,
and Community Partners to update existing critical LFG energy project data necessary for tracking
GHG reductions from LFG energy projects, such as project size and start year.
All Partners may provide information through periodic updates as needed. These updates
will mainly be changes to contact information for primary contacts and experts, but they can also
include providing or updating a brief description of the organization which LMOP will post on the
LMOP website to provide publicity and encourage networking among Partners. LMOP may also
call or email a selection of Partners to confirm or update project information that LMOP has
received through the media or industry contacts.
Participation in LMOP does not require any records to be kept, although Partners will
likely keep copies of MOU submitted to EPA.
(ii)

Respondent Activities

The respondent activities depend on the aspect of the information collection to which they
are responding. In completing the MOU, respondents will:
•

Review the MOU;

•

Complete the MOU electronically;

•

Sign and submit the form electronically to EPA; and

•

File a copy of the MOU.

In completing the request for LFG energy project and landfill data, respondents will:
8

•

Obtain access to e-GGRT (this step only for new Partners)
o Respondent burden for this specific task is covered under Cross-Media
Electronic Reporting Rule ICR (OMB Control No. 2025-0003)

•

Review instructions;

•

Gather information;

•

Complete or update information; and

•

Submit data updates to EPA via the e-GGRT module.

In replying to or initiating an information update, respondents will:
•

Gather information; and

•

Provide information via the LMOP website, email, or telephone interview.

5. THE INFORMATION COLLECTED - AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT
5(a)

Agency Activities

Agency activities associated with this information collection depend on the aspect of the
information collection that the agency has received. In receiving the MOU, the Agency will:
•

Review the information provided;

•

Sign the MOU;

•

Return a copy of the signed MOU to the Partner;

•

Enter the information into a database; and

•

File the MOU.

In requesting and receiving LFG energy project and landfill data, the Agency will:
•

Assign LFG energy projects and landfills to new Partners;

•

Invite any new Partners to access the e-GGRT module;

•

Populate e-GGRT with the current data on LFG energy projects and landfills
from the LMOP Database;

•

Manage data collection timeline, answer questions, and send reminder emails;

•

Review and validate information provided and follow up if necessary; and

•

Transfer information received in e-GGRT to the LMOP Database.

In receiving an information update from a Partner, the Agency will:
•

Review the data; and

•

Revise data in the database based on the update.

In initiating an information update, the Agency will:
•

Call or email the Partner;

•

Request updated information; and

•

Revise data in the database based on the updates.

5(b)

Collection Methodology and Management

The methods selected for this information collection are chosen based on efficiency and
minimization of burden for respondents and EPA. The MOU can be accessed on the LMOP website
and returned to EPA by email. General Partner information will be posted on the LMOP website
where it can be reviewed for accuracy by the Partner and revised if necessary. LFG energy project
and landfill data update requests will be sent to all Industry Developer, Energy, and Community
Partners. All LFG energy project and landfill data updates received will be reviewed by EPA
before being entered into the LMOP Database.
5(c)

Small Entity Flexibility

EPA expects that some LMOP Partners are small entities. Consistent with the assumptions
made in the previous ICR renewal, LMOP assumed that all State Partners, which represent State
governments, are not classified as small entities since each State population is greater than 50,000.
LMOP also assumed that any new Endorsers, which are non-profits, that join the program will be
classified as small entities. Given the larger number of Partners in other categories, for existing
Endorsers and existing and new Community, Energy, and Industry Partners, LMOP estimated
small entity counts for this ICR renewal based on the distribution of small entities for each Partner
type from the 2012 ICR renewal. The results of this estimation are provided in Table 3.
Table 3: Estimate of Average Annual Small Entities for Each Respondent Category
Respondent Category
State Partners
Community Partners
Endorsers
Energy
Industry Partner, developers
Industry Partner, non-developers
Total

New
0
0
1
1
1
9
12

% of
Total
Category
0%
14%
100%
25%
67%
54%

Existing
0
20
33
27
44
228
352

% of
Total
Category
0%
14%
85%
24%
66%
31%

EPA has designed its approach for this information collection to minimize burden for all
respondents while obtaining sufficient and accurate information. Participation in LMOP is
voluntary. Any small entity that finds the information collection overly burdensome is not required
to participate.
5(d)

Collection Schedule

EPA will collect general information in the MOU, which are completed and submitted by
each Partner upon their agreement to participate in the program. EPA will request updates to LFG
energy project and landfill data via the electronic collection method. These update requests will be
completed in the e-GGRT system annually by Industry Developer, Energy, and Community
Partners. Information may also be updated periodically at the request of EPA or the Partner.

6. ESTIMATING THE BURDEN AND COST OF THE COLLECTION
6(a)

Estimating Respondent Burden

In order to obtain accurate hourly burden and cost estimates, EPA consulted with fewer
than nine Partners regarding burden and cost assumptions in 2007, 2008, 2012, 2015, and 2018.
For this ICR renewal, labor rates were increased to account for an increase in wages, which
impacts cost estimates.
The hourly burden estimates for Industry Developer, Energy, and Community Partners
decreased from the 2016 renewal because of the transition to electronic data collection. More
specifically, the decrease in hours for this task is accounted for in the reduced time estimated to
submit data to LMOP using the e-GGRT system (saving 0.25 hours per respondent) and in
removing redundancy among respondent’s staff members for data review and submission to EPA
(saving 0.5 hours per respondent). The introduction of electronic data collection for this task saves
an estimated 0.75 hours per respondent per year as compared to the estimated burden hours from
the 2016 ICR renewal. Attachment A presents the estimated average annual Partner respondent
burden and costs during the next 3-year ICR period for each type of Partner. Table 4 presents a
summary of the respondent burden.
6(b)

Estimating Respondent Costs

(i)

Estimating Labor Costs

For private-sector respondents (Industry and Energy Partners), EPA used a national
average hourly labor rate (hourly rate plus 110% overhead) of $146.84 for legal staff, $117.12 for
11

managerial staff, $94.34 for technical staff, and $61.48 for clerical staff. Legal, managerial,
technical, and clerical labor rates were obtained from the Bureau of Labor and Statistics average
rates for Professional, Scientific, and Technical Services (NAICS code 541000). Legal rates were
based on lawyers, management wages were based on managers (all other), technical wages were
based on environmental engineers, and clerical rates were based on executive secretaries and
administrative assistants for May 2017. A June 2018 labor rate for all rates was estimated by
applying a 2.5% growth factor from the Employment Cost Index to account for increases in wages
from June 2017 to June 2018. The Employment Cost Index for wages and salaries, by ownership,
occupational group, and industry is located at http://www.bls.gov/news.release/eci.t02.htm.
For public-sector respondents (Community and State Partners), EPA used the same labor
rates used for EPA personnel (see Section 6(c)). These rates are comparable to rates provided by a
Community Partner in 2000 and using them for all public-sector employees provides consistency.
For non-profit sector respondents (Endorsers), EPA used a national average hourly labor
rate (hourly rate plus 110% overhead) of $121.10 for managerial staff, $102.56 for technical staff,
and $61.36 for clerical staff. Managerial, technical, and clerical labor rates were obtained from the
Bureau of Labor and Statistics average rates for Business, Professional, Labor, Political, and
Similar Organizations (NAICS code 813900). Management wages were based on managers (all
other), technical wages were based on engineers (all other), and clerical rates were based on
executive secretaries and administrative assistants for May 2017. A June 2018 labor rate for all
rates was estimated by applying a 2.3% growth factor from the Employment Cost Index to
account for increases in wages from June 2017 to June 2018. The Employment Cost Index for
wages and salaries, by ownership, occupational group, and industry is located at
http://www.bls.gov/news.release/eci.t02.htm.
(ii)

Estimating Capital and Operations and Maintenance Costs

Because this information collection requires respondents only to provide information that is
already available to them, there are no capital costs. Similarly, EPA does not expect any
operations and maintenance (O&M) costs for postage under this information collection as all
responses are expected to be submitted by email or other electronic submittal.

Table 4: Summary of Respondent Burden
New
Partner

Hours

6(c)

Total for 3-year ICR
Period

Average Annual Burden

Community
Endorser
Industry Non-Developer
Energy and IndustryProject Developer
State
Total Hours
Average Burden per
Partner

19.75
1.5
42

576.75
7.5
457.5

33.5

1122

1.5
98.25

7.5
2171.25

3.93

1.91

Community
Endorser
Industry Non-Developer
Energy and Industry
Project Developer
State
Total Cost
Average Cost per Partner

$1,121
$143
$4,302

$33,760
$769
$43,162

$104,644
$2,735
$142,392

$3,291

$107,858

$333,447

$79
$8,935
$357

$414
$185,965
$164

$1,481
$584,699
--

Partner

Cost

Existing

1790
27
1499
3467
27
6809
--

Estimating Agency Burden and Costs

Attachment B presents the estimated Agency burden hours and costs for the information
collection activities associated with LMOP. Table 5 presents a summary of the agency burden.
EPA estimates an average hourly labor cost (labor plus 60% for overhead) of $80.59 for
managerial staff, $55.26 for technical staff, and $22.19 for clerical staff. To derive these estimates,
EPA used the “Salary Table 2018 - GS” from the Department of Personnel Management, available
at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salarytables/18Tables/html/GS_h.aspx. For purposes of this ICR, EPA assigned staff the following
government service levels:
•

Managerial Staff - GS-15, Step 1

•

Technical Staff - GS-12, Step 5

•

Clerical Staff - GS-5, Step 1

Hours
Cost

Table 5: Summary of Agency Burden
2019
2020
2021
Average
913
924
935
924
$50,215 $50,809 $51,403 $50,809
13

Total
2,772
$152,427

6(d)

Estimating the Respondent Universe

The growth in new LMOP Partners joining the program has slowed since program inception, but
has generally remained consistent since the last ICR renewal. EPA estimates during the next 3year ICR period that 25 new Partners will join the program per year and 10 Partners will leave
the program per year, for a net increase of 15 Partners per year. Table 6 presents a summary of
the respondent universe by LMOP Partner category for the next 3-year ICR period. The burden
estimates are based on the total respondent universe. The number of average annual responses is
647, as detailed in Table 7.
Table 6: Summary of LMOP Partners and Other Respondents
Partner
Community
Endorser
Energy
Industry
Non-Developer
Project Developer
State
TOTAL

2019
2020
2021
Average
1
1
1
Existing New Existing New Existing New Existing New1
147
3
149
3
151
3
149
3
39
1
39
1
39
1
39
1
110
2
111
2
112
2
111
2
722
64
40
1,122

16
2
1
25

732
65
41
1,137

16
2
1
25

742
66
42
1,152

16
2
1
25

732
65
41
1,137

16
2
1
25

1 Staff with experience in managing the LMOP Partner database provided insight on future program growth by Partner category.
The number of new Partners joining LMOP per year has declined in recent years and this trend is expected to continue. An
average of 43 new Partners joined per year for the period from 2012 to 2014, and an average of 16 new Partners joined per year
for the period from 2015 to 2017. The majority of existing and new Partners are Industry-Non Developer.

Table 7: Summary of Average Annual Responses
Total Annual Responses
(A)

(B)

Information
Collection
Activity

Number of
Respondents

MOUs

(C)

Number of
Responses

(D)
Number of Existing Respondents
That Keep Records But Do Not
Submit Reports

(E)
Total
Annual
Responses
E=(BxC)+D

N/A
14

Information
Updates

290

N/A

290

LFG energy
project and
landfill data
updates

332

N/A

332

Total

647

6(e)

Bottom Line Burden Hours and Costs

Over the 3-year period covered by this ICR, EPA estimates the total respondent burden of
the program to be 6,809 hours at a labor cost of $584,699. EPA estimates the total Agency
burden to be 2,772 hours at a labor cost of $152,427. The annual respondent burden, averaged
over the 3-year period, is 2,270 hours at a labor cost of $194,890, and the annual Agency burden,
averaged over the 3-year period, is 924 hours at a labor cost of $50,809.
The total burden for existing Partner respondents will increase gradually over each year of
the 3-year ICR period to reflect an increase in the total number of existing Partners, although the
burden per respondent will remain constant. The burden and costs shown for each existing Partner
category in Attachment A reflect the average number of Partners during the 3-year ICR period. The
bottom line burden for new Partners will stay the same for each year of this ICR, since the number
of new Partners joining each year is expected to remain relatively constant over the 3-year ICR
period.
6(f)

Reasons for Change in Burden

Under this renewal ICR, the total respondent burden over the 3-year period is 6,809 hours,
or an average of 2,270 hours per year. The 2016 ICR total respondent burden was 7,566 hours, or
an average of 2,522 hours per year.
The estimated burden decrease for respondents is based on the transition to electronic
collection of updates on LFG energy projects and landfill information. The decrease in hours for
this task is accounted for in the reduced time estimated to submit data to LMOP using the eGGRT system and in removing redundancy among respondent’s staff members for data review
and submission to EPA. The burden estimates have not changed for the other collection activities
under this ICR.
6(g)

Burden Statement

The overall annual public reporting and recordkeeping burden for this collection of
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information is estimated to average 3.5 hours per response.
Burden means the total time, effort, or financial resources expended by persons to
generate, maintain, retain, and 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. The burden for each type of Partner is shown in
Attachment A and the total burden is summarized in Table 4.
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 EPA-HQ-OAR-2003-0078. An electronic version of the public docket is available at
http://www.regulations.gov/ which may be used 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. When
in the system, select “search,” then key in the docket ID number identified in this document. The
documents are also available for public viewing at the Air and Radiation Docket in the EPA
Docket Center (EPA/DC), EPA WJC West Building, Room 3334, 1301 Constitution Ave., NW,
Washington, D.C. The EPA/DC Public Reading Room is open from 8:30 a.m. to 4:30 p.m.,
Monday through Friday, excluding federal holidays. The telephone number for the Reading Room
is 202-566-1744, and the telephone number for the Air and Radiation Docket is 202-566-1742.
Also, you can send comments to the Office of Information and Regulatory Affairs,
Office of Management and Budget, 725 17th Street, NW, Washington, DC 20503, Attention:
Desk Office for EPA. Please include the EPA Docket ID No. EPA-HQ-OAR-2003-0078 and
OMB Control Number 2060-0446 in any correspondence.
Part B of the Supporting Statement
16

This part is not applicable because no statistical methods were used in collecting this information.

ATTACHMENT A - ESTIMATED AVERAGE RESPONDENT BURDEN AND COST
A-1 Existing State Partners
A-2 New State Partners
A-3 Existing Endorsers
A-4 New Endorsers
A-5 Existing Industry Non-Developer Partners
A-6 New Industry Non-Developer Partners
A-7 Existing Community Partners
A-8 New Community Partners
A-9 Existing Energy and Industry-Project Developer Partners
A-10 New Energy and Industry-Project Developer Partners
ATTACHMENT B - ESTIMATED AGENCY BURDEN AND COST
B-1 Agency Burden 2019
B-2 Agency Burden 2020
B-3 Agency Burden 2021

Table A-1
ESTIMATED AVERAGE RESPONDENT BURDEN AND COST: Existing State Partners

INFORMATION
COLLECTION ACTIVITY
Information Update2
Gather information
Provide information via LMOP
website or email
Provide information via telephone
interview
TOTAL

Hours and Costs Per Respondent/Activity1
Total Hours and Costs
Mgr.
Tech.
Cler. Respon. Labor
Number
Total
Total
$80.59 $55.26 $22.19 Hours/
Hours/
Cost/
Cost/ O & M
of
per hour per hour per hour Activity Activity Cost Respondents Year
Year
0.00

0.50

0.00

0.50

$27.63

5.00

$276.32

0.00

0.25

0.00

0.25

$13.82

1.25

$69.08

0.00

0.25

0.00

0.25

$13.82

1.25
7.50

$69.08
$414.48

1 Labor rates for EPA personnel were used for all public-sector personnel, including employees of State agencies. Source for EPA
labor rates: Department of Personnel Management, "Salary Table 2018 - GS" at https://www.opm.gov/policy-data-oversight/payleave/salaries-wages/salary-tables/18Tables/html/GS_h.aspx. For the managerial labor rate, used level GS-15, step 1; for the technical
labor rate, used level GS-12, step 5; for the clerical labor rate, used level GS-5, step 1. All agency labor rates include a multiplier of
1.6 to account for overhead and fringe benefit costs.
2 The only burden for existing State Partners is to submit voluntary periodic information updates. It is assumed that one-quarter of all
existing State Partners will submit an information update each year. It is assumed that half of those that update their information will
provide information through the LMOP website or by email and the other half will provide information through a telephone
interview. During the 3-year ICR period the expected average number of existing State Partners is 41. It is assumed 10 existing State
Partners will provide an information update each year: 5 through the website or by email, and 5 by telephone.

Table A-2
ESTIMATED AVERAGE RESPONDENT BURDEN AND COST: New State Partners
Hours and Costs Per Respondent/Activity1
Total Hours and Costs
Mgr.
Tech.
Cler. Respon. Labor
Number
Total
Total
$80.59 $55.26 $22.19 Hours/
Cost/ O & M
of
Hours/
Cost/
per hour per hour per hour Activity Activity Cost Respondents Year
Year

INFORMATION
COLLECTION
ACTIVITY
Memoranda of Understanding2
Review MOU
0.25
Complete MOU
0.25
Submit MOU to EPA and
file copy
0.00
SUBTOTAL
Information Update3
Gather information
Provide information via
LMOP website or email
Provide information via
telephone interview
SUBTOTAL
TOTAL

0.25
0.25

0.00
0.00

0.50
0.50

$33.96
$33.96

$0
$0

1
1

0.50
0.50

$33.96
$33.96

0.00

0.50

$11.10

0.50
1.50

$11.10
$79.02

0.00

0.50

0.00

0.50

$27.63

0.00

$0.00

0.00

0.25

0.00

0.25

$13.82

0.00

$0.00

0.00

0.25

0.00

0.25

$13.82

0.00

$0.00

0.00
1.50

$0.00
$79.02

1 Labor rates for EPA personnel were used for all public-sector personnel, including employees of State agencies. Source for
EPA labor rates: Department of Personnel Management, "Salary Table 2018 - GS" at https://www.opm.gov/policy-dataoversight/pay-leave/salaries-wages/salary-tables/18Tables/html/GS_h.aspx. For the managerial labor rate, used level GS-15,
step 1; for the technical labor rate, used level GS-12, step 5; for the clerical labor rate, used level GS-5, step 1. All agency
labor rates include a multiplier of 1.6 to account for overhead and fringe benefit costs.
2 All Partners must submit MOU when they join LMOP. As of May 2018, 26 out of the 52 states/territories have joined
LMOP. For the upcoming 3-year ICR period it is expected that 1 new State Partner will join LMOP per year.
3 New State Partners may also submit voluntary periodic information updates. It is assumed that one-quarter of all new State
Partners will submit an information update. It is assumed that half of those that update their information will provide
information through the LMOP website or email and the other half will provide information through a telephone interview.
During the 3-year ICR period an average of 1 new State Partner is expected. This rounds down to 0 new State Partners
submitting an update.

Table A-3
ESTIMATED AVERAGE RESPONDENT BURDEN AND COST: Existing Endorsers

INFORMATION
COLLECTION ACTIVITY
Information Update2
Gather information
Provide information via LMOP
website or email
Provide information via telephone
interview
TOTAL

Hours and Costs Per Respondent/Activity1
Total Hours and Costs
Mgr.
Tech.
Cler. Respon. Labor
Number
Total
Total
$121.10 $102.56 $61.36 Hours/
Hours/
Cost/
Cost/ O & M
of
per hour per hour per hour Activity Activity Cost Respondents Year
Year
0.00

0.50

0.00

0.50

$51.28

5.00

$512.80

0.00

0.25

0.00

0.25

$25.64

1.25

$128.20

0.00

0.25

0.00

0.25

$25.64

1.25
7.50

$128.20
$769.20

1 Labor rates for Endorsers were estimated using the average May 2017 labor rates for NAICS industry grouping 813900, Business,
Professional, Labor, Political, and Similar Organizations from the Bureau of Labor and Statistics Occupational Employment Statistics
at https://www.bls.gov/oes/current/oes_stru.htm. Occupational Title used for clerical labor was "Executive Secretaries and Executive
Administrative Assistants", for technical labor was "Engineers, All Other", and for managerial labor was "Managers, All Other".
Estimated a June 2018 labor rate using a 2.3% growth factor from the employment cost index to account for increases in wages from
June 2017 to June 2018. Obtained growth factor for Occupational Group "Management, professional, and related" from "Table 2.
Seasonally Adjusted: Employment Cost Index for wages and salaries, by ownership, occupational group, and industry" at
http://www.bls.gov/news.release/eci.t02.htm. All labor rates incorporate a factor of 110% to account for overhead and fringe benefit
costs.
2 The only burden for existing Endorsers is to submit voluntary periodic information updates. It is assumed that one-quarter of all
existing Endorsers will submit an information update each year. It is assumed that half of those that update their information will
provide information through the LMOP website or by email and the other half will provide information through a telephone
interview. During the 3-year ICR period the expected average number of existing Endorsers is 39. It is assumed 10 existing Endorsers
will provide an information update each year: 5 through the website or by email, and 5 by telephone.

Table A-4
ESTIMATED AVERAGE RESPONDENT BURDEN AND COST: New Endorsers
Hours and Costs Per Respondent/Activity1
Total Hours and Costs
Number
Total
Total
Mgr.
Tech.
Cler. Respon. Labor
$121.10 $102.56 $61.36 Hours/
Cost/ O & M
of
Hours/
Cost/
per hour per hour per hour Activity Activity Cost Respondents Year
Year

0.25
0.25

0.00
0.00

0.50
0.50

$55.91
$55.91

$0
$0

1
1

0.50
0.50

$55.91
$55.91

0.00

0.50

$30.68

0.50
1.50

$30.68
$142.51

0.00

0.50

0.00

0.50

$51.28

0.00

$0.00

0.00

0.25

0.00

0.25

$25.64

0.00

$0.00

0.00

0.25

0.00

0.25

$25.64

0.00

$0.00

0.00
1.50

$0.00
$142.51

1 Labor rates for Endorsers were estimated using the average May 2017 labor rates for NAICS industry grouping 813900,
Business, Professional, Labor, Political, and Similar Organizations from the Bureau of Labor and Statistics Occupational
Employment Statistics at https://www.bls.gov/oes/current/oes_stru.htm. Occupational Title used for clerical labor was
"Executive Secretaries and Executive Administrative Assistants", for technical labor was "Engineers, All Other", and for
managerial labor was "Managers, All Other". Estimated a June 2018 labor rate using a 2.3% growth factor from the
employment cost index to account for increases in wages from June 2017 to June 2018. Obtained growth factor for
Occupational Group "Management, professional, and related" from "Table 2. Seasonally Adjusted: Employment Cost Index
for wages and salaries, by ownership, occupational group, and industry" at http://www.bls.gov/news.release/eci.t02.htm. All
labor rates incorporate a factor of 110% to account for overhead and fringe benefit costs.
2 All Endorsers must submit Agreements when they join LMOP. For the upcoming 3-year ICR period it is expected that 1
new Endorser will join LMOP per year.
3 New Endorsers may also submit voluntary periodic information updates. It is assumed that one-quarter of all new Endorsers
will submit an information update. It is assumed that half of those that update their information will provide information
through the LMOP website or email and the other half will provide information through a telephone interview. During the 3year ICR period an average of 1 new Endorser is expected. This rounds down to 0 new Endorsers submitting an update.

Table A-5
ESTIMATED AVERAGE RESPONDENT BURDEN AND COST: Existing Industry Non-Developer Partners

INFORMATION
COLLECTION ACTIVITY
Information Update2
Gather information
Provide information via LMOP
website or email
Provide information via telephone
interview
TOTAL

Hours and Costs Per Respondent/Activity1
Legal
Mgr.
Tech.
Cler. Respon. Labor
$146.84 $117.12 $94.34 $61.48 Hours/
Cost/
per hour per hour per hour per hour Activity Activity

O&M
Cost

Total Hours and Costs
Number
Total
Total
of
Hours/
Cost/
Respondents Year
Year

0.00

1.50

0.00

1.50

$141.52

183

274.50

$25,897.45

0.00

1.00

0.00

1.00

$94.34

92.00

$8,679.65

0.00

1.00

0.00

1.00

$94.34

91.00
457.50

$8,585.31
$43,162.41

1 Labor rates for Industry Non-Developer Partners were estimated using the average May 2017 labor rates for NAICS industry grouping 541000,
Professional, Scientific, and Technical Services at https://www.bls.gov/oes/current/oes_stru.htm. Occupational Title used for clerical labor was
"Executive Secretaries and Executive Administrative Assistants", for technical labor was "Environmental Engineers", for managerial labor was
"Managers, All Other", and for legal labor was "Lawyers". Estimated a June 2018 labor rate using a 2.5% growth factor from the employment cost index
to account for increases in wages from June 2017 to June 2018. Obtained growth factor for Occupational Group "Professional, scientific, and technical
services" from "Table 2. Seasonally Adjusted: Employment Cost Index for wages and salaries, by ownership, occupational group, and industry" at
http://www.bls.gov/news.release/eci.t02.htm. All labor rates incorporate a factor of 110% to account for overhead and fringe benefit costs.
2 The only burden for existing Industry-Non Developer Partners is to submit voluntary periodic information updates. It is assumed that one-quarter of
all existing Industry Non-Developer Partners will submit an information update each year. It is assumed that half of those that update their information
will provide information through the LMOP website or by email and the other half will provide information through a telephone interview. During the 3year ICR period the expected average number of existing Industry Non-Developer Partners is 732. It is assumed 183 existing Industry Non-Developer
Partners will provide an information update each year: 92 through the website or by email, and 91 by telephone.

Table A-6
ESTIMATED AVERAGE RESPONDENT BURDEN AND COST: New Industry Non-Developer Partners
Hours and Costs Per Respondent/Activity1
Labor
Tech.
Cler. Respon.
Legal
Mgr.
Cost/
$146.84 $117.12 $94.34 $61.48 Hours/
per hour per hour per hour per hour Activity Activity

INFORMATION
COLLECTION
ACTIVITY
Memoranda of Understanding2
Review MOU
0.50
Complete MOU
0.00
Submit MOU to EPA
and file copy
0.00
SUBTOTAL
Information Update3
Gather information
Provide information via
LMOP website or email
Provide information via
telephone interview
SUBTOTAL
TOTAL

O&M
Cost

Total Hours and Costs
Number
Total
Total
Cost/
of
Hours/
Respondents
Year
Year

0.25
0.25

0.00
0.00

1.00
0.50

$126.29
$52.87

$0
$0

16
16

16.00
8.00

$2,020.59
$845.85

0.00

0.50

$30.74

8.00
32.00

$491.80
$3,358.24

0.00

1.50

0.00

1.50

$141.52

6.00

$566.06

0.00

1.00

0.00

1.00

$94.34

2.00

$188.69

0.00

1.00

0.00

1.00

$94.34

2.00

$188.69

10.00
42.00

$943.44
$4,301.69

1 Labor rates for Industry Non-Developer Partners were estimated using the average May 2017 labor rates for NAICS industry grouping
541000, Professional, Scientific, and Technical Services at https://www.bls.gov/oes/current/oes_stru.htm. Occupational Title used for clerical
labor was "Executive Secretaries and Executive Administrative Assistants", for technical labor was "Environmental Engineers", for managerial
labor was "Managers, All Other", and for legal labor was "Lawyers". Estimated a June 2018 labor rate using a 2.5% growth factor from the
employment cost index to account for increases in wages from June 2017 to June 2018. Obtained growth factor for Occupational Group
"Professional, scientific, and technical services" from "Table 2. Seasonally Adjusted: Employment Cost Index for wages and salaries, by
ownership, occupational group, and industry" at http://www.bls.gov/news.release/eci.t02.htm. All labor rates incorporate a factor of 110% to
account for overhead and fringe benefit costs.
2 All Partners must submit MOU when they join LMOP. For the upcoming 3-year ICR period it is expected that 16 new Industry Non-Developer
Partners will join LMOP per year.
3 New Industry Non-Developer Partners may also submit voluntary periodic information updates. It is assumed that one-quarter of all new
Industry Non-Developer Partners will submit an information update. It is assumed that half of those that update their information will provide
information through the LMOP website or email and the other half will provide information through a telephone interview. During the 3-year
ICR period an average of 16 new Industry Non-Developer Partners is expected. It is assumed 4 new Industry Non-Developer Partners will
provide an information update each year: 2 through the website or by email, and 2 by telephone.

Table A-7
ESTIMATED AVERAGE RESPONDENT BURDEN AND COST: Existing Community Partners

INFORMATION
COLLECTION ACTIVITY
LFG Energy and Landfill Data
update via e-GGRT module2
Review instructions
Gather information
Complete or update information
Submit data updates to EPA via eGGRT module

Hours and Costs Per Respondent/Activity1
Total Hours and Costs
Mgr.
Tech.
Cler.
Respon.
Labor
Number
Total
Total
Cost/
$80.59
$55.26
$22.19 Hours/
O&M
of
Hours/
Cost/
per hour per hour per hour Activity Activity
Cost Respondents Year
Year

0.00
0.00
0.50

0.50
1.00
1.00

0.00
0.00
0.00

0.50
1.00
1.50

$27.63
$55.26
$95.56

$0
$0
$0

149
149
149

0.00

0.25

0.00

0.25

$13.82

149

SUBTOTAL
Information Update3
Gather information
Provide information via LMOP
website or email
Provide information via telephone
interview
SUBTOTAL
TOTAL

74.50
149.00
223.50

$4,117.17
$8,234.34
$14,238.44

37.25

$2,058.58

484.25

$28,648.53

0.00

1.50

0.00

1.50

$82.90

55.50

$3,067.15

0.00

1.00

0.00

1.00

$55.26

19.00

$1,050.02

0.00

1.00

0.00

1.00

$55.26

18.00

$994.75

92.50
576.75

$5,111.92
$33,760.45

1 Labor rates for EPA personnel were used for all public-sector personnel, including employees of State agencies. Source for EPA labor rates:
Department of Personnel Management, "Salary Table 2018 - GS" at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salarytables/18Tables/html/GS_h.aspx. For the managerial labor rate, used level GS-15, step 1; for the technical labor rate, used level GS-12, step 5; for
the clerical labor rate, used level GS-5, step 1. All agency labor rates include a multiplier of 1.6 to account for overhead and fringe benefit costs.
2 All existing Community Partners agreed to submit information on LFG energy projects and landfill data. During the 3-year ICR period there are
an estimated 149 existing Community Partners that will update LFG energy information in e-GGRT each year.
3 Existing Community Partners may submit voluntary periodic information updates. It is assumed that one-quarter of all existing Community
Partners will submit an information update each year. It is assumed that half of those that update their information will provide information
through the LMOP website or email and the other half will provide information through a telephone interview. During the 3-year ICR period the
expected average number of existing Community Partners is 149. It is assumed 37 will provide an information update each year: 19 through the
website or email, and 18 by telephone.

Table A-8
ESTIMATED AVERAGE RESPONDENT BURDEN AND COST: New Community Partners
1

INFORMATION COLLECTION
ACTIVITY
2
Memoranda of Understanding
Review MOU
Complete MOU
Submit MOU to EPA and file copy
SUBTOTAL
LFG Energy and Landfill Data update
via e-GGRT module3
Obtain e-GGRT access4
Review instructions
Gather information
Complete or update information
Submit data updates to EPA via e-GGRT
module

Hours and Costs Per Respondent/Activity
Mgr.
Tech.
Cler. Respon.
Labor
$80.59 $55.26 $22.19 Hours/
Cost/
O&M
Cost
per hour per hour per hour Activity Activity

Total Hours and Costs
Number
Total
Total
Cost/
of
Hours/
Year
Respondents
Year

0.25
0.25
0.00

0.00
0.00
0.50

0.50
0.50
0.50

$33.96
$33.96
$11.10

$0
$0
$0

3
3
3

1.50
1.50
1.50
4.50

$101.89
$101.89
$33.29
$237.07

0.00
0.00
0.00
0.50

0.00
0.50
1.50
1.50

0.00
0.00
0.00
0.00

0.00
0.50
1.50
2.00

$0.00
$27.63
$82.90
$123.19

$0
$1
$0
$0

3
3
3
3

0.00
1.50
4.50
6.00

$0.00
$85.90
$248.69
$369.58

0.00

0.25

0.00

0.25

$13.82

SUBTOTAL
Information Update5
Gather information
Provide information via LMOP website
or email
Provide information via telephone
interview
SUBTOTAL
TOTAL

0.75

$41.45

12.75

$745.61

0.00

1.50

0.00

1.50

$82.90

1.50

$82.90

0.00

1.00

0.00

1.00

$55.26

1.00

$55.26

0.00

1.00

0.00

1.00

$55.26

0.00

$0.00

2.50

$138.16

19.75

$1,120.84

1 Labor rates for EPA personnel were used for all public-sector personnel, including employees of State agencies. Source for EPA labor rates:
Department of Personnel Management, "Salary Table 2018 - GS" at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salarytables/18Tables/html/GS_h.aspx. For the managerial labor rate, used level GS-15, step 1; for the technical labor rate, used level GS-12, step 5; for
the clerical labor rate, used level GS-5, step 1. All agency labor rates include a multiplier of 1.6 to account for overhead and fringe benefit costs.
2 All Partners must submit MOU when they join LMOP. For the upcoming 3-year ICR period it is expected that 3 new Community Partners will
join LMOP per year.
3 All existing Community Partners agreed to submit information on LFG energy projects and landfill data. During the 3-year ICR period there are
an estimated 3 new Community Partners that will update LFG energy information in e-GGRT each year.
4 The burden for this task is zero hours because new e-GGRT user registration is accounted for in ICR OMB Number 2025-0003.
5 New Community Partners may also submit voluntary periodic information updates. It is assumed that one-quarter of all new Community Partners
will submit an information update. It is assumed that half of those that update their information will provide information through the LMOP website
or email and the other half will provide information through a telephone interview. During the 3-year ICR period an average of 3 new Community
Partners is expected. It is assumed 1 new Community Partner will provide an information update each year: 1 through the website or by email, and 0
by telephone.

Table A-9
ESTIMATED AVERAGE RESPONDENT BURDEN AND COST: Existing Energy and Industry-Project Developer Partners

Hours and Costs Per Respondent/Activity1
Legal
Mgr.
Tech.
Cler. Respon.
Labor
$146.84 $117.12 $94.34
$61.48 Hours/
Cost/
per hour per hour per hour per hour Activity Activity

O&M
Cost

Total Hours and Costs
Number
Total
Total
of
Hours/
Cost/
Respondents
Year
Year

0.00
0.00
0.00

0.00
0.00
0.50

0.50
3.00
1.50

0.00
0.00
0.00

0.50
3.00
2.00

$47.17
$283.03
$200.07

$0
$0
$0

176
176
176

88.00
528.00
352.00

$8,302.28
$49,813.67
$35,213.18

0.00

0.25

0.00

0.25

$23.59

176

44.00

$4,151.14

1,012.00

$97,480.27

SUBTOTAL
3

Information Update
Gather information
Provide information via LMOP
website or email
Provide information via telephone
interview
SUBTOTAL
TOTAL

0.00

1.50

0.00

1.50

$141.52

66.00

$6,226.71

0.00

1.00

0.00

1.00

$94.34

22.00

$2,075.57

0.00

1.00

0.00

1.00

$94.34

22.00

$2,075.57

110.00
1,122.00

$10,377.85
$107,858.12

1 Labor rates for Energy and Industry-Project Developer Partners were estimated using the average May 2017 labor rates for NAICS industry grouping
541000, Professional, Scientific, and Technical Services at https://www.bls.gov/oes/current/oes_stru.htm. Occupational Title used for clerical labor was
"Executive Secretaries and Executive Administrative Assistants", for technical labor was "Environmental Engineers", for managerial labor was "Managers, All
Other", and for legal labor was "Lawyers". Estimated a June 2018 labor rate using a 2.5% growth factor from the employment cost index to account for
increases in wages from June 2017 to June 2018. Obtained growth factor for Occupational Group "Professional, scientific, and technical services" from "Table
2. Seasonally Adjusted: Employment Cost Index for wages and salaries, by ownership, occupational group, and industry" at
http://www.bls.gov/news.release/eci.t02.htm. All labor rates incorporate a factor of 110% to account for overhead and fringe benefit costs.
2 All existing Energy and Industry-Project Developer Partners agreed to submit information on LFG energy projects and landfill data. During the 3-year ICR
period there are an estimated 176 existing Energy and Industry-Project Developer Partners that will update LFG energy information in e-GGRT each year.
3 Existing Energy and Industry-Project Developer Partners may submit voluntary periodic information updates. It is assumed that one-quarter of all existing
Energy and Industry-Project Developer Partners will submit an information update each year. It is assumed that half of those that update their information will
provide information through the LMOP website or email and the other half will provide information through a telephone interview. During the 3-year ICR
period the expected average number of existing Energy and Industry-Project Developer Partners is 176. It is assumed 44 will provide an information update
each year: 22 through the website or email, and 22 by telephone.

Table A-10
ESTIMATED AVERAGE RESPONDENT BURDEN AND COST: New Energy and Industry-Project Developer Partners

INFORMATION COLLECTION
ACTIVITY
2
Memoranda of Understanding
Review MOU
Complete MOU
Submit MOU to EPA and file copy

Hours and Costs Per Respondent/Activity1
Legal
Mgr.
Tech.
Cler. Respon.
Labor
$146.84 $117.12 $94.34
$61.48 Hours/
Cost/
per hour per hour per hour per hour Activity Activity
0.50
0.00
0.00

0.25
0.25
0.00

0.00
0.00
0.50

1.00
0.50
0.50

$126.29
$52.87
$30.74

O&M
Cost

Total Hours and Costs
Number
Total
Total
of
Hours/
Cost/
Respondents Year
Year

$0
$0
$0

4
4
4

SUBTOTAL
LFG Energy and Landfill Data update
via e-GGRT module3
Obtain e-GGRT access4
Review instructions
Gather information
Complete or update information
Submit data updates to EPA via e-GGRT
module

0.00
0.00
0.00
0.00

0.00
0.00
0.00
0.50

0.00
0.50
3.00
1.50

0.00
0.00
0.00
0.00

$0.00
0.50
3.00
2.00

$0.00
$47.17
$283.03
$200.07

$0
$0
$0
$0

4
4
4
4

0.00

0.25

0.00

0.25

$23.59

SUBTOTAL
Information Update5
Gather information
Provide information via LMOP website or
email
Provide information via telephone
interview

4.00
2.00
2.00

$505.15
$211.46
$122.95

8.00

$839.56

0.00
2.00
12.00
8.00

$0.00
$188.69
$1,132.13
$800.30

1.00

$94.34

23.00

$2,215.46

0.00

1.50

0.00

1.50

$141.52

1.50

$141.52

0.00

1.00

0.00

1.00

$94.34

1.00

$94.34

0.00

1.00

0.00

1.00

$94.34

SUBTOTAL
TOTAL

0.00

$0.00

2.50

$235.86

33.50

$3,290.88

1 Labor rates for Energy and Industry-Project Developer Partners were estimated using the average May 2017 labor rates for NAICS industry grouping 541000,
Professional, Scientific, and Technical Services at https://www.bls.gov/oes/current/oes_stru.htm. Occupational Title used for clerical labor was "Executive
Secretaries and Executive Administrative Assistants", for technical labor was "Environmental Engineers", for managerial labor was "Managers, All Other", and
for legal labor was "Lawyers". Estimated a June 2018 labor rate using a 2.5% growth factor from the employment cost index to account for increases in wages
from June 2017 to June 2018. Obtained growth factor for Occupational Group "Professional, scientific, and technical services" from "Table 2. Seasonally
Adjusted: Employment Cost Index for wages and salaries, by ownership, occupational group, and industry" at http://www.bls.gov/news.release/eci.t02.htm. All
labor rates incorporate a factor of 110% to account for overhead and fringe benefit costs.
2 All Partners must submit MOU when they join LMOP. For the upcoming 3-year ICR period it is expected that 4 new Energy and Industry-Project Developer
Partners will join LMOP per year.
3 All new Energy and Industry-Project Developer Partners agreed to submit information on LFG energy projects and landfill data. During the 3-year ICR period
there are an estimated 4 new Energy and Industry-Project Developer Partners that will update LFG energy information in e-GGRT each year.
4 The burden for this task is zero hours because new e-GGRT user registration is accounted for in ICR OMB Number 2025-0003.
5 New Energy and Industry-Project Developer Partners may also submit voluntary periodic information updates. It is assumed that one-quarter of all new Energy
and Industry-Project Developer Partners will submit an information update. It is assumed that half of those that update their information will provide information
through the LMOP website or email and the other half will provide information through a telephone interview. During the 3-year ICR period an average of 4 new
Energy and Industry-Project Developer Partners is expected. It is assumed 1 new Energy and Industry-Project Developer Partner will provide an information
update each year: 1 through the website or by email, and 0 by telephone.

Table B-1
ESTIMATED AGENCY BURDEN AND COST FOR 2019
Hours and Costs Per Respondent/Activity1

INFORMATION COLLECTION ACTIVITY

Mgr.
$80.59
Hour

Tech.
$55.26
Hour

Cler.
$22.19
Hour

0.25
0.00
0.00

0.50
0.00
0.50

0.00
0.50
0.00

0.75
0.50
0.50

$47.78
$11.10
$27.63

$0
$0
$0

25
25
25

18.75
12.50
12.50
43.75

$1,194.50
$277.40
$690.80
$2,162.70

0.00
0.00
0.00

0.25
0.25
0.25

0.00
0.00
0.00

0.25
0.25
0.25

$13.82
$13.82
$13.82

$0
$0
$0

328

1.75
1.75
82.00

$96.71
$96.71
$4,531.65

0.00

0.50

0.00

0.50

$27.63

41.00

$2,265.82

0.00

1.00

0.00

1.00

$55.26

328

328.00

$18,126.59

0.00

0.50

0.00

0.50

$27.63

328

164.00
618.50

$9,063.30
$34,180.78

0.00
0.00

0.25
0.50

0.00
0.00

0.25
0.50

$13.82
$27.63

$0
$0

143
143

35.75
71.50
107.25

$1,975.69
$3,951.38
$5,927.06

0.00
0.00

0.50
0.50

0.00
0.00

0.50
0.50

$27.63
$27.63

$0
$0

144
144

71.88
71.88
143.75
913.25

$3,972.10
$3,972.10
$7,944.20
$50,214.75

Memoranda of Understanding2
Review and sign MOU
File MOU and return signed copy to the Partner
Enter MOU information into a database
SUBTOTAL
LFG Energy and Landfill Data update via e-GGRT module3
Assign projects and landfills to new Partners
Invite any new Partners to e-GGRT module
Load most recent LMOP Database into e-GGRT
Manage data collection timeline, answer questions, and send
reminder emails
Review and validate information provided and follow up if
necessary
Transfer information received in e-GGRT to the LMOP
Database
SUBTOTAL
Receive Information Update4
Review information received via LMOP website, email, or
telephone
Revise data in the database
SUBTOTAL
Initiate Information Update4
Call or email Partner and request updated information
Revise data in database
SUBTOTAL
TOTAL

Total Hours and Costs

Respon. Labor
Number
Hours/
Cost/ O & M
of
Activity Activity Cost Respondents

Total
Hours/
Year

Total
Cost/
Year

1 Source for EPA labor rates: Department of Personnel Management, "Salary Table 2018 - GS" at https://www.opm.gov/policy-data-oversight/pay-leave/salarieswages/salary-tables/18Tables/html/GS_h.aspx. For the managerial labor rate, used level GS-15, step 1; for the technical labor rate, used level GS-12, step 5; for the
clerical labor rate, used level GS-5, step 1. All agency labor rates include a multiplier of 1.6 to account for overhead and fringe benefit costs.
2 All Partners must submit MOU when they join LMOP. In 2019, it is expected that 25 new Partners will join LMOP.

3 In 2019, EPA will open the e-GGRT module for electronic reporting of landfill data for each existing Community, Energy, and Industry-Project Developer Partner
to review and revise if necessary, and also provide information on new projects. EPA will assign projects and landfills to applicable new Community, Energy, and
Industry-Project Developer Partners when they join the program and invite them to access the e-GGRT module. During electronic reporting, LMOP estimates that onequarter of respondents will have questions or need reminder emails about accessing the module for data reporting. In 2019, it is estimated that EPA will need to load
LMOP project and landfill data into e-GGRT for 7 new and 321 existing Community, Energy, and Industry-Project Developer Partners.
4 In 2019, it is assumed that one-quarter of all existing and new Partners will submit voluntary periodic information updates. It is assumed that half of those that
update their information will provide information through the LMOP website or email and the other half will provide information through a telephone interview. In
2019, it is anticipated that there will be 1,122 existing and 25 new Partners. It is assumed 287 will provide an information update: 144 through the website or email,
and 143 by telephone interview.

Table B-2
ESTIMATED AGENCY BURDEN AND COST FOR 2020
Hours and Costs Per Respondent/Activity1

INFORMATION COLLECTION ACTIVITY

Mgr.
$80.59
Hour

Tech.
$55.26
Hour

Cler.
$22.19
Hour

0.25
0.00
0.00

0.50
0.00
0.50

0.00
0.50
0.00

0.75
0.50
0.50

$47.78
$11.10
$27.63

$0
$0
$0

25
25
25

18.75
12.50
12.50
43.75

$1,194.50
$277.40
$690.80
$2,162.70

0.00
0.00
0.00

0.25
0.25
0.25

0.00
0.00
0.00

0.25
0.25
0.25

$13.82
$13.82
$13.82

$0
$0
$0

332

1.75
1.75
83.00

$96.71
$96.71
$4,586.91

0.00

0.50

0.00

0.50

$27.63

41.50

$2,293.46

0.00

1.00

0.00

1.00

$55.26

332

332.00

$18,347.65

0.00

0.50

0.00

0.50

$27.63

332

166.00
626.00

$9,173.82
$34,595.26

0.00
0.00

0.25
0.50

0.00
0.00

0.25
0.50

$13.82
$27.63

$0
$0

145
145

36.25
72.50
108.75

$2,003.32
$4,006.64
$6,009.96

0.00
0.00

0.50
0.50

0.00
0.00

0.50
0.50

$27.63
$27.63

$0
$0

146
146

72.75
72.75
145.50
924.00

$4,020.46
$4,020.46
$8,040.91
$50,808.84

Total Hours and Costs

Respon. Labor
Number
Total
Hours/
Cost/ O & M
of
Hours/
Activity Activity Cost Respondents Year

Total
Cost/
Year

1 Source for EPA labor rates: Department of Personnel Management, "Salary Table 2018 - GS" at https://www.opm.gov/policy-data-oversight/pay-leave/salarieswages/salary-tables/18Tables/html/GS_h.aspx. For the managerial labor rate, used level GS-15, step 1; for the technical labor rate, used level GS-12, step 5; for the
clerical labor rate, used level GS-5, step 1. All agency labor rates include a multiplier of 1.6 to account for overhead and fringe benefit costs.
2 All Partners must submit MOU when they join LMOP. In 2020, it is expected that 25 new Partners will join LMOP.

3 In 2020, EPA will open the e-GGRT module for electronic reporting of landfill data for each existing Community, Energy, and Industry-Project Developer Partner
to review and revise if necessary, and also provide information on new projects. EPA will assign projects and landfills to applicable new Community, Energy, and
Industry-Project Developer Partners when they join the program and invite them to access the e-GGRT module. During electronic reporting, LMOP estimates that
one-quarter of respondents will have questions or need reminder emails about accessing the module for data reporting. In 2020, it is estimated that EPA will need to
load LMOP project and landfill data into e-GGRT for 7 new and 325 existing Community, Energy, and Industry-Project Developer Partners.
4 In 2020, it is assumed that one-quarter of all existing and new Partners will submit voluntary periodic information updates. It is assumed that half of those that
update their information will provide information through the LMOP website or email and the other half will provide information through a telephone interview. In
2020, it is anticipated that there will be 1,137 existing and 25 new Partners. It is assumed 291 will provide an information update: 146 through the website or email,
and 145 by telephone interview.

Table B-3
ESTIMATED AGENCY BURDEN AND COST FOR 2021
Hours and Costs Per Respondent/Activity1

INFORMATION COLLECTION ACTIVITY

Mgr.
$80.59
Hour

Tech.
$55.26
Hour

Cler.
$22.19
Hour

0.25
0.00
0.00

0.50
0.00
0.50

0.00
0.50
0.00

0.75
0.50
0.50

$47.78
$11.10
$27.63

$0
$0
$0

25
25
25

18.75
12.50
12.50
43.75

$1,194.50
$277.40
$690.80
$2,162.70

0.00
0.00
0.00

0.25
0.25
0.25

0.00
0.00
0.00

0.25
0.25
0.25

$13.82
$13.82
$13.82

$0
$0
$0

336

1.75
1.75
84.00

$96.71
$96.71
$4,642.18

0.00

0.50

0.00

0.50

$27.63

42.00

$2,321.09

0.00

1.00

0.00

1.00

$55.26

336

336.00

$18,568.70

0.00

0.50

0.00

0.50

$27.63

336

168.00
633.50

$9,284.35
$35,009.74

0.00
0.00

0.25
0.50

0.00
0.00

0.25
0.50

$13.82
$27.63

$0
$0

147
147

36.75
73.50
110.25

$2,030.95
$4,061.90
$6,092.86

0.00
0.00

0.50
0.50

0.00
0.00

0.50
0.50

$27.63
$27.63

$0
$0

147
147

73.63
73.63
147.25
934.75

$4,068.81
$4,068.81
$8,137.62
$51,402.92

Total Hours and Costs

Respon. Labor
Number
Hours/
Cost/ O & M
of
Activity Activity Cost Respondents

Total
Hours/
Year

Total
Cost/
Year

1 Source for EPA labor rates: Department of Personnel Management, "Salary Table 2018 - GS" at https://www.opm.gov/policy-data-oversight/pay-leave/salarieswages/salary-tables/18Tables/html/GS_h.aspx. For the managerial labor rate, used level GS-15, step 1; for the technical labor rate, used level GS-12, step 5; for the
clerical labor rate, used level GS-5, step 1. All agency labor rates include a multiplier of 1.6 to account for overhead and fringe benefit costs.
2 All Partners must submit MOU when they join LMOP. In 2021, it is expected that 25 new Partners will join LMOP.

3 In 2021, EPA will open the e-GGRT module for electronic reporting of landfill data for each existing Community, Energy, and Industry-Project Developer Partner
to review and revise if necessary, and also provide information on new projects. EPA will assign projects and landfills to applicable new Community, Energy, and
Industry-Project Developer Partners when they join the program and invite them to access the e-GGRT module. During electronic reporting, LMOP estimates that onequarter of respondents will have questions or need reminder emails about accessing the module for data reporting. In 2021, it is estimated that EPA will need to load
LMOP project and landfill data into e-GGRT for 7 new and 329 existing Community, Energy, and Industry-Project Developer Partners.
4 In 2021, it is assumed that one-quarter of all existing and new Partners will submit voluntary periodic information updates. It is assumed that half of those that
update their information will provide information through the LMOP website or email and the other half will provide information through a telephone interview. In
2021, it is anticipated that there will be 1,152 existing and 25 new Partners. It is assumed 294 will provide an information update: 147 through the website or email,
and 147 by telephone interview.

File Type	application/pdf
Author	Cappel, Kirsten
File Modified	2019-02-27
File Created	2019-02-27