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pdfSUPPORTING STATEMENT FOR
INFORMATION COLLECTION REQUEST NUMBER 1772.08
“INFORMATION COLLECTION ACTIVITIES ASSOCIATED WITH EPA’S ENERGY
STAR® PROGRAM IN THE COMMERCIAL AND INDUSTRIAL SECTORS”
October 5, 2020
Office of Air and Radiation
U.S. Environmental Protection Agency
TABLE OF CONTENTS
1.
2.
3.
4.
5.
6.
IDENTIFICATION OF THE INFORMATION COLLECTION....................................... 1
1(a) Title and Number of the Information Collection .................................................... 1
1(b) Short Characterization or Abstract.......................................................................... 1
NEED FOR AND USE OF THE COLLECTION ............................................................... 4
2(a) Need and Authority for the Collection.................................................................... 4
2(b) Practical Utility and Users of the Data ................................................................... 4
NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA 6
3(a) Nonduplication........................................................................................................ 6
3(b) Public Notice Required Prior to ICR Submission to OMB .................................... 6
3(c) Consultations........................................................................................................... 6
3(d) Effects of Less Frequent Collection ........................................................................ 7
3(e) General Guidelines.................................................................................................. 8
3(f)
Confidentiality ........................................................................................................ 8
3(g) Sensitive Questions ................................................................................................. 8
THE RESPONDENTS AND THE INFORMATION REQUESTED ................................. 9
4(a) Respondents and NAICS Codes ............................................................................. 9
4(b) Information Requested ............................................................................................ 9
THE INFORMATION COLLECTED, AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT ...................................... 24
5(a) Agency Activities.................................................................................................. 24
5(b) Collection Methodology and Management ........................................................... 26
5(c) Small Entity Flexibility ......................................................................................... 27
5(d) Collection Schedule .............................................................................................. 27
ESTIMATING THE BURDEN AND COST OF THE COLLECTION .......................... 28
6(a) Estimating Respondent Burden............................................................................. 28
6(b) Estimating Respondent Costs ............................................................................... 28
6(c) Estimating Agency Burden and Costs .................................................................. 29
6(d) Estimating the Respondent Universe .................................................................... 29
6(e) Bottom Line Burden Hours and Cost Tables ........................................................ 54
6(f)
Reasons for Change in Burden ............................................................................. 55
6(g) Burden Statement .................................................................................................. 59
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1.
IDENTIFICATION OF THE INFORMATION COLLECTION
1(a)
Title and Number of the Information Collection
This ICR is entitled “Information Collection Activities Associated with EPA’s ENERGY
STAR® Program in the Commercial and Industrial Sectors,” ICR Number 1772.08, OMB Control
No. 2060-0347.
1(b)
Short Characterization or Abstract
The U.S. Environmental Protection Agency (EPA) created ENERGY STAR as a
voluntary program to help businesses and individuals protect the environment through superior
energy efficiency. The program focuses on reducing utility-generated emissions by reducing the
demand for energy. In 1991, EPA launched the Green Lights program to encourage corporations,
state and local governments, colleges and universities, and other organizations to adopt energyefficient lighting as a profitable means of preventing pollution and improving lighting quality.
Since then, EPA has rolled Green Lights into ENERGY STAR for the commercial and industrial
sectors and expanded ENERGY STAR to encompass organization-wide energy performance
improvement, such as building technology upgrades, product purchasing initiatives, and employee
training. At the same time, EPA has streamlined the reporting requirements of ENERGY STAR
and focused on providing recognition incentives for improvements (e.g., ENERGY STAR
Awards program). EPA also makes tools and resources available over the web to help the public
overcome the barriers to evaluating their energy performance and investing in profitable
improvements.
For several reasons, the public’s participation in the ENERGY STAR program for
commercial and industrial sectors has continued to increase over the past several years, and EPA
expects their participation to rise even more in the coming years. For example, a growing number
of state and local governments are leveraging ENERGY STAR as a way for the public to respond
to rising energy costs and greenhouse gas emissions, including mandatory energy benchmarking
and disclosure laws that require buildings within their jurisdiction to use EPA’s ENERGY STAR
Portfolio Manager. As of the end of 2018, 29 local governments and three states rely on Portfolio
Manager as the foundation for their energy benchmarking and transparency policies.
Participation in ENERGY STAR has also risen dramatically because of the efforts of trade
associations, utilities, and third-party providers in promoting the program to the public. These
organizations voluntarily communicate ENERGY STAR messages and promote the use of
ENERGY STAR tools and strategies in an effort to help companies reduce their energy
consumption and find more environmentally friendly ways to conduct business.
As participation has increased, EPA has taken measures to reduce the burden on
participants that take advantage of the benefits of ENERGY STAR. For example, EPA has
expanded Portfolio Manager Web Services, which is one of several benchmarking data-entry
1
methods available to users. 1 Because Web Services integrates automated data collection and
entry, it offers significant time-saving advantages over the other methods. For example, it takes
almost five hours to perform a new benchmark using manual data entry, whereas about one hour
using Web Services. A repeat benchmark takes 45 minutes using manual data entry, whereas
about six minutes using Web Services.
Over many years, EPA has seen a growing trend of users opting for Web Services and
thereby realizing these savings. This is illustrated in the bar graph below, which shows the total
number of benchmarks performed annually using Web Services and the other methods. In 2009,
41% of all benchmarks were performed using Web Services. By 2017, this had grown to 73%.
73
51%
41%
In addition to expanding Web Services, the Agency has continued to enhance other
features of Portfolio Manager, allowing participants to enter and retrieve information more
quickly. Furthermore, EPA is always looking for ways to reduce burden and in recent years has
introduced changes to the requirements for certification that reduce both labor and cost for
applicants, without impacting the integrity of the ENERGY STAR certification.
In 2017, the ENERGY STAR program for commercial buildings helped businesses and
organizations save 160 billion kilowatt-hours of electricity, avoid $9 billion in energy costs, and
protect the climate by achieving 110 million metric tons of greenhouse gas reductions. In 2018
alone, more than 270,000 commercial properties used Portfolio Manager to measure and track
their energy use, water use, and waste and materials. On average, ENERGY STAR certified
buildings use 35% less energy than typical buildings nationwide.
1
See Portfolio Web Services at https://portfoliomanager.energystar.gov/webservices/home.
2
In 2017, the ENERGY STAR program for industrial plants helped businesses save 34
billion kilowatt-hours of electricity, avoid $3 billion in energy costs, and protect the climate by
achieving 40 million metric tons of greenhouse gas reductions. As of 2018, 31 diverse industrial
sectors work with ENERGY STAR to strategically manage their energy use, from cookie and
cracker bakeries and pharmaceutical plants to integrated steel mills and petroleum refineries. EPA
provides ENERGY STAR certification for 19 types of manufacturing plants. In 2018, 100
industrial plants earned ENERGY STAR certification.
This ICR examines the information collections under the ENERGY STAR program in the
commercial and industrial sectors. Sections 1 through 5 of this document describe the collections
(e.g., from the standpoint of need and use/utility of the information collected). The sections also
describe respondent and Agency activities. In Section 6, EPA estimates the total annual hour and
cost burden to respondents and the Agency under the collections.
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2.
NEED FOR AND USE OF THE COLLECTION
2(a)
Need and Authority for the Collection
ENERGY STAR is authorized under section 103(g) of the Clean Air Act. The Energy
Policy Act of 2005 further provides authorization to EPA and the U.S. Department of Energy
(DOE) to establish a voluntary program to identify and promote energy-efficient products and
buildings in order to reduce energy consumption, improve energy security, and reduce pollution
through voluntary certification of, or other forms of communication about, products and buildings
that meet the highest energy conservation standards.
In 2015, Congress directed EPA to develop a recognition program for energy efficient
tenant spaces under the ENERGY STAR program. See the Energy Efficiency Improvement Act
of 2015 for more information (42 USC § 17085).
Under federal law, federal agencies may not lease space in any building that has not
earned the ENERGY STAR in the most recent year. All federally owned buildings are also
required to track and report their energy use through ENERGY STAR. See the Energy
Independence and Security Act of 2007 (42 USC § 17091).
ENERGY STAR is a voluntary program aimed at preventing pollution rather than
controlling it after its creation. Information is needed from organizations joining the program for
identification purposes (e.g., contact information) and for establishing their partnership.
ENERGY STAR online tools (e.g., Portfolio Manger) are needed for users to benchmark facility
energy performance, assess energy management goals over time, and identify strategic
opportunities for savings and recognition opportunities. Finally, information is needed from
organizations seeking ENERGY STAR recognition so that EPA can evaluate and verify their
accomplishments and share their lessons learned with the public.
2(b)
Practical Utility and Users of the Data
EPA uses information from organizations joining the program to ascertain basic
identification information about them and verify their commitment to the program. EPA may also
use partnership information for program implementation purposes, such as maintaining up-to-date
listings of products and services available to the public. Further, ENERGY STAR’s tools (e.g.,
Portfolio Manager, Energy Performance Indicator) are available online for the public to
benchmark facility energy performance and identify opportunities for improvements. 2 Finally,
EPA uses information from organizations seeking recognition to evaluate and verify their energy
performance and accomplishments. For example, EPA offers the public an opportunity to display
the ENERGY STAR on their buildings if they meet certain energy performance criteria defined
by EPA. To be approved to receive the ENERGY STAR, buildings must demonstrate that they
See Portfolio Manager at https://www.energystar.gov/portfoliomanager and the Energy Performance Indicator at
https://www.energystar.gov/industrial_plants/measure-track-and-benchmark/energy-star-energy. Additional tools and
resources can be found at https://www.energystar.gov/buildings/tools-and-resources.
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2
meet specific eligibility requirements as well as industry standards for comfort and indoor air
quality. EPA recognition enhances the image of organizations as national leaders in energy
performance.
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3.
NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION
CRITERIA
3(a)
Nonduplication
The information collected under this ICR is not collected by any other EPA office or by
any other federal agency. Therefore, there is not a potential for duplication with other federal
collections.
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 this ICR through an announcement in the Federal Register on December 13, 2018 (83 FR
64125). No comments were received.
3(c)
Consultations
In March 2019, EPA contacted several Partner organizations to request their input on the
ICR’s burden estimates. The purpose of the consultations was to determine if the burden estimates
should be updated or revised in preparing ICR 1772.08. The table identifies the points of contact
(POCs) and their organizations. EPA selected these organizations because of their substantial
experience in carrying out collections under the ENERGY STAR program.
POC Name
Russell
Chambers
Stefanie Damm
Jennifer
McConkey
James
Wilkerson
Organization Name
Phone Number
Email
ENGIE Insight
(509) 329-7111
[email protected]
ENGIE Insight
Principal Real Estate
Investors
Des Moines Public
Schools
(509) 329-7188
[email protected]
(515) 235-1605
[email protected]
(515) 242-7911
[email protected]
Following is a summary of EPA’s questions, POCs’ comments and EPA’s responses (e.g.,
if and how the Agency incorporated the comments into ICR 1772.08):
•
Partnership Agreement: The ICR estimates that an organization in the
commercial and industrial sectors takes 30 minutes on average to read, complete
and submit a Partnership Agreement. EPA asked if this is a reasonable estimate.
The POCs discussed their experiences preparing the agreement and indicated that
30 minutes is reasonable. EPA did not revise its estimate.
•
Portfolio Manager: The ICR estimates respondent burden for Portfolio Manager
based on three alternative benchmarking methods: manual data entry, data entry
6
with Excel spreadsheet, and Web Services. EPA provided three POCs with the
ICR’s burden estimates and asked if they are reasonable. 3, 4
The POCs discussed their experiences and burdens using the tool. They agreed
with the ICR’s burden estimates for new and repeat benchmarks using manual data
entry and data entry with Excel spreadsheet. In regard to new benchmarks using
Web Services, two POCs agreed with the ICR’s estimate of one hour, although one
of them also suggested it might be too high. Another POC suggested 1.5 hours.
Given this feedback, EPA believes the ICR’s estimate of one hour is reasonable.
First, two of the three POCs affirmed it, with a concern it might be too high; this
feedback outweighs the suggestion to raise it. The estimate also has been affirmed
in consultations performed during past ICR renewal cycles. In regard to repeat
benchmarks using Web Services, two POCs agreed with the ICR’s estimate of six
minutes, whereas another suggested it should be two minutes. Given this, EPA
believes the ICR’s estimate of six minutes is reasonable. In summary, EPA did not
revise its benchmarking estimates.
•
ENERGY STAR Certification: The ICR estimates the burden for licensed
professionals (LPs) to perform facility data reviews under the ENERGY STAR
certification program. An applicant’s in-house LP can perform the review or it can
contract an external LP. EPA asked the POCs for input on the cost to contract an
external LP. The POCs offered estimates ranging from $500 to $2,000 per
building. Given their input and EPA’s understanding of industry practices and
costs, the Agency believes $1,200 per building is a reasonable estimate and has
included it in this ICR. 5
3(d)
Effects of Less Frequent Collection
EPA has carefully considered the information collection burden under the ENERGY
STAR program. EPA is confident that those activities requested of respondents are necessary, and
to the extent possible, the Agency has minimized the burden. A number of the requested
activities, for example, will be performed once (e.g., one-time submittal of a Partnership
Agreement). In addition, respondents can satisfy many of the collections in this ICR by
submitting readily available information. For example, users of Portfolio Manager are asked to
enter energy use data (e.g., data from their energy bills). EPA believes strongly that, if the
information collections in this ICR are not performed at the requested frequency, EPA’s ability to
EPA provided the POCs with the burden inputs used in the weighted-average calculations that determined
respondent burden for each benchmarking method. For additional information on these inputs, see Section 6(d) of this
document under the heading, “Benchmarking,” and subheading, “Portfolio Manager.”
4
POCs were asked to provide input on benchmarking methods with which they had experience.
5
EPA is aware, for example, that some properties receive special rates from LPs, as low as $500 per building,
especially if they are certifying multiple buildings. In addition, it is becoming increasingly common for LPs to
include the cost of building certification in their energy efficiency consulting services for the building, which helps to
keep costs low.
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3
implement the ENERGY STAR program and the public’s ability to benefit from the program’s
tools and resources could be hampered significantly.
3(e)
General Guidelines
Information collections performed under this clearance will follow all of OMB’s General
Guidelines regarding federal data collection.
3(f)
Confidentiality
Participation in the ENERGY STAR program is voluntary and may be terminated by
participants or EPA at any time. If a claim of confidential business information (CBI) is asserted,
EPA will manage that information in accordance with EPA’s provisions on confidentiality. 40
CFR Part 2, Subpart B establishes EPA’s general policy on the public disclosure of information
and procedures for handling CBI claims.
3(g)
Sensitive Questions
No questions of a sensitive nature are asked of participants under the ENERGY STAR
program.
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4.
THE RESPONDENTS AND THE INFORMATION REQUESTED
4(a)
Respondents and NAICS Codes
Following are the North American Industry Classification System (NAICS) codes of
respondents most likely to carry out the information collections under this ICR.
Industry Sectors
Agriculture, Forestry, Fishing and Hunting
Mining, Quarrying, and Oil and Gas Extraction
Utilities
Construction
Manufacturing
Wholesale Trade
Retail Trade
Transportation and Warehousing
Information
Finance and Insurance
Real Estate and Rental and Leasing
Professional, Scientific, and Technical Services
Management of Companies and Enterprises
Administrative and Support and Waste Management and Remediation
Services
Educational Services
Health Care and Social Assistance
Arts, Entertainment, and Recreation
Accommodation and Food Services
Other Services (except Public Administration)
Public Administration
4(b)
NAICS
Code(s)
11
21
22
23
31-33
42
44-45
48-49
51
52
53
54
55
56
61
62
71
72
81
92
Information Requested
This section describes the information collections under this ICR, including data items and
respondent activities. The section also identifies the sector (i.e., private and/or public sector) that
is expected to carry out each collection (see the heading introducing each collection).
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JOINING THE ENERGY STAR PROGRAM AND RELATED ACTIVITIES
Organizations interested in joining the ENERGY STAR program may be asked to submit
a Partnership Agreement. They also may be asked to undertake related activities, as described
below.
Commercial and Industrial Sector Partners (Private and Public Sector)
In order to join ENERGY STAR, organizations in the commercial and industrial sectors
are asked to complete and submit a Partnership Agreement to EPA. 6 These Partners agree to
measure and track the energy performance of their organization’s facilities where possible by
using tools such as those offered through ENERGY STAR; develop and implement a plan
consistent with the ENERGY STAR Energy Management Guidelines to achieve energy savings;
help spread the word about the importance of energy efficiency to their staff and community; and
highlight their achievements with recognition offered through ENERGY STAR.
(i)
Data items
•
A Partnership Agreement that includes the following information:
Organization’s name;
Contact information on organization’s Chief Executive;
Contact information on organization’s Energy Manager;
Contact information on organization’s Communications Contact (if
applicable);
Description of organization’s primary business or function (i.e., a
checklist);
Total amount of building/facility square footage owned, leased, and/or
managed; and
Brief explanation of how organization learned about ENERGY STAR.
•
Energy Management Plan.
(ii)
Respondent activities
•
To join ENERGY STAR, organizations are asked to:
Complete and submit the Partnership Agreement online; and
Respond to EPA follow-up questions, if any.
•
Partners may update their existing energy management plan.
6
This participant group includes businesses and other organizations in such fields as commercial and corporate real
estate, education, entertainment, government, healthcare and senior care facilities, hospitality, manufacturing and
industry, multifamily housing, retail, wastewater and drinking water treatment, and associations.
10
Service and Product Providers (Private Sector)
An organization must meet certain eligibility requirements before applying to become a
Service and Product Provider (SPP) Partner. 7 Applicants must demonstrate that they have
actively used the ENERGY STAR approach to help clients achieve their energy management
goals as specified.
•
SPPs serving the existing commercial buildings market must benchmark at least 10
client commercial buildings in the last 12 months using Portfolio Manager and/or
earn the ENERGY STAR certification for at least one client commercial building
using Portfolio Manager and meet other program requirements. [Note that this ICR
addresses benchmarking activities in the section, “Benchmarking,” under the
heading, “Portfolio Manager.” This ICR addresses earning the ENERGY STAR in
the section, “Recognition,” under the heading, “ENERGY STAR Certification.”]
•
SPPs serving the commercial new construction market must submit commercial
building design projects that achieve Designed to Earn the ENERGY STAR.
Eligible design projects are determined by using Target Finder and require
approval from EPA. [Note that this ICR addresses applying for the Designed to
Earn the ENERGY STAR in the section, “Recognition,” under the heading,
“Designed to Earn the ENERGY STAR.”]
•
SPPs serving the industrial market must work with an ENERGY STAR industrial
Partner on at least one energy efficiency project in the last two years and submit a
Teaming Profile to EPA outlining the project scope and resulting savings for that
project.
SPPs interested in joining ENERGY STAR complete and submit a Partnership Agreement
to EPA using an online system. The Partnership Agreement requests SPP company information,
contact information, and select pieces of information to enable automated verification that
Partnership requirements have been met. The Partnership Agreement also lays out Partner
commitments, disclaimers, procedures for dispute resolution, and other issues.
On an annual basis, SPPs may be asked to update contact information (i.e. contact name,
phone, email) displayed on select Service and Product Provider listings on the web site and to
maintain quality of contact mailing lists.
(i)
Data items
•
A Partnership Agreement to be completed and submitted online that includes the
following information:
Applicant company name;
This participant group includes companies that provide energy efficiency services and/or products in the commercial
and industrial markets.
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7
Information about the company, such as web address and markets/sectors
that the organization serves and services available;
Name, title, and contact information of the primary contact,
communications contact, and signatory of the Partnership Agreement; and
For Existing Commercial Buildings SPPs only, information about SPP
activities over the past 12 months (i.e., Portfolio Manager building ID
numbers to complete automated verification of activity); or
For architecture firms only, information about Commercial New
Construction SPP activities (i.e., Designed to Earn the ENERGY STAR of
project achieving Designed to Earn the ENERGY STAR); or
For Industrial SPP only, information about SPP activities (i.e., Teaming
Profile outlining the project scope and resulting savings for that project).
•
Additional communications items that SPP Partner may elect to submit:
One-page success story for web site posting to demonstrate successful
projects or relationships with commercial and institutional clients, or
exemplary use of ENERGY STAR tools.
Communications about SPP efforts for feature in quarterly newsletters or
other medium, at EPA discretion.
(ii)
Respondent activities
•
To join ENERGY STAR, organizations are asked to:
Complete and submit the Partnership Agreement online; and
Complete and submit requested materials for the appropriate partnership
category (e.g., Statement of Energy Design Intent, Teaming Profile) online.
•
SPP Partners are asked to:
Update contact information as needed by notifying program account
manager of any changes and/or using the “My ENERGY STAR Account”
tool; and
Communicate efforts and successes to ENERGY STAR and the broader
market through success stories and other communications.
Energy Efficiency Program Sponsors (Private and Public Sector)
Energy Efficiency Program Sponsors (EEPS) interested in joining ENERGY STAR are
asked to complete and submit a Partnership Agreement. 8, 9 They commit to promote and use
This participant group includes regulated utilities, publicly owned utilities, and energy delivery companies; national,
regional, state, or local government entities; and other organizations involved in coordinating and/or administering
energy-efficiency or environmental education programs that promote ENERGY STAR, including ENERGY STAR
certified commercial and industrial buildings.
9
EEPS are given the opportunity to join one or more programs within ENERGY STAR when they complete and
submit their Partnership Agreement (e.g., C&I, Products). EPA is currently renewing the ICR, “EPA’s ENERGY
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8
ENERGY STAR in a manner consistent with the national ENERGY STAR efforts and
specifically agree to follow all applicable terms and conditions governing the use of the ENERGY
STAR logos, which are registered trade and service marks. Some Partners will be asked on an
annual basis to update organization and contact information displayed on the ENERGY STAR
web site and the Directory of Energy Efficiency Programs (DEEP). The Partners also agree to
promote energy efficiency as an easy and desirable option for organizations and consumers to
prevent pollution, protect the global environment, and save on energy bills.
(i)
Data items
•
Partnership Agreement.
•
Updates to organization and contact information displayed on the ENERGY STAR
web site and the Directory of Energy Efficiency Programs (DEEP).
•
Information to promote energy efficiency as an easy and desirable option for
organizations and consumers to prevent pollution, protect the global environment,
and save on energy bills.
(ii)
Respondent activities
•
To join ENERGY STAR, organizations are asked to complete and submit a
Partnership Agreement.
•
EEPS also agree to:
Update organization and contact information displayed on the ENERGY
STAR web site and the Directory of Energy Efficiency Programs (DEEP)
annually; and
Provide information to promote energy efficiency as an easy and desirable
option for organizations and consumers to prevent pollution, protect the
global environment, and save on energy bills.
BENCHMARKING
Assessing energy use is a critical component of the ENERGY STAR program and
guidance provided by EPA to Partners. EPA provides tools to track, measure and compare energy
use for a range of building types and facilities. Portfolio Manager is the primary tool for
undertaking these activities and is available online at
https://www.energystar.gov/portfoliomanager.
STAR® Product Labeling,” (EPA ICR No. 2078, OMB Control Number 2060-0528). The Product Labeling ICR will
consolidate the burden for EEPS Partnership Agreements across all ENERGY STAR programs. It also includes the
EEPS Partnership Agreement (EPA Form 5900-33), which is used by all EEPS. As such, this ICR (EPA ICR
1772.08) no longer estimates burden for EEPS Partnership Agreements. See Section 6d of this document.
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Portfolio Manager (Private and Public Sector)
Portfolio Manager is an interactive energy management tool that allows users to track and
assess energy and water consumption across their entire portfolio of facilities in a secure online
environment. Users enter energy consumption and cost data into their Portfolio Manager account
to benchmark facility energy performance, assess energy management goals over time and
identify strategic opportunities for savings and recognition opportunities. A “benchmark” is
defined as a measurement of a facility’s energy performance resulting from entering facility
information and at least 12 consecutive months of facility energy data into EPA’s Portfolio
Manager. Portfolio Manager offers multiple types of benchmarks: the 1-100 ENERGY STAR
energy performance score for select commercial facility types, site and source Energy Use
Intensity (EUI) for all commercial facility types, weather normalized energy values, greenhouse
gas emissions, water consumption, and annual energy and water costs.
The ENERGY STAR scale accounts for the impacts of year-to-year weather variations, as
well as facility size, location, and several operating characteristics. Portfolio Manager helps the
user update and track data over time to continuously monitor performance. The user can use both
short and long term trends in energy performance to make budget and management decisions
regarding investments in energy-related projects.
In addition, EPA intends to collect information from Portfolio Manager users on its
usability as a web-based tool and on the effectiveness of Portfolio Manager guidance. Based on
this information, EPA will identify and make needed improvements.
(i)
Data items
•
Information entered into Portfolio Manager:
Contact information;
Facility data (e.g., name, address, year constructed);
Facility operating characteristics (e.g., gross facility area, number of
occupants, operating hours, number of PCs);
Energy use information (e.g., meter name, usage data);
Water use information - optional (e.g., meter name, usage data); and
Solid waste management/disposal information - optional (e.g., meter/waste
type name, disposal quantity).
•
Information provided to EPA on the usability of Portfolio Manager and
effectiveness of guidance.
(ii)
Respondent activities
•
Organizations using the benchmarking feature of the Portfolio Manager system
perform the following activities:
Review the instructions of Portfolio Manager and set up account;
14
Gather facility and energy data; and
Enter the data into Portfolio Manager.
[Note: Users have several options for entering facility and energy data into
Portfolio Manager. These options and associated burden are described in Section
6(d) of this document.]
.
•
Organizations may be asked to respond to EPA questions on the usability of
Portfolio Manager.
•
Organizations may be asked to respond to EPA questions about guidance or
trainings on benchmarking.
Data Collection for Model Development and Beta Testing (Private and Public Sector)
Occasionally during the development, modification or testing of Portfolio Manager or
other tool, EPA may collect information about annual energy use (one year’s worth of energy
data), along with basic information about facility operations, such as the operating hours or
number of workers.
(i)
Data items
•
Information collected from participating organizations:
Contact information;
Facility data (e.g., name, address, year constructed);
Facility operating characteristics (e.g., gross facility area, number of
occupants, operating hours, number of PCs);
Energy use information (e.g., meter name, usage data); and
Water use information (e.g. meter name, usage data).
(ii)
Respondent activities
•
Organizations may be asked to:
Review the instructions of Portfolio Manager or spreadsheet;
Gather facility and energy data; and
Enter the data into Portfolio Manager or spreadsheet.
15
RECOGNITION
ENERGY STAR Certification (Private and Public Sector)
Buildings (Private and Public Sector)
EPA offers the public an opportunity to display the ENERGY STAR on their buildings if
they meet certain energy performance criteria defined by EPA. The online application for the
ENERGY STAR is submitted through EPA’s benchmarking tool, Portfolio Manager. To be
approved to receive the ENERGY STAR, buildings must meet specific eligibility requirements as
well as industry standards for comfort and indoor air quality. A Professional Engineer or
Registered Architect must verify that these requirements have been met and the Application for
ENERGY STAR Certification (stamped/embossed and signed) is submitted. [Note that this ICR
addresses applicant benchmarking activities in the section, “Benchmarking,” under the heading,
“Portfolio Manager.”]
In addition, EPA conducts audits on a small percentage of applications for quality control
purposes. EPA confirms, for example, the accuracy of the information provided in the application
for the ENERGY STAR and may request facility documentation.
EPA also expects to periodically contact representatives of buildings that have earned the
ENERGY STAR to collect information about the characteristics of buildings that lead to top
energy performance and their reasons for benchmarking. This includes information on the
buildings’ construction, equipment used in the buildings, building management, and involvement
in ENERGY STAR. EPA will use this information to better understand the specific design,
construction, and operating characteristics of ENERGY STAR certified buildings and how these
characteristics contributed to the buildings’ top energy performance. In addition, EPA intends to
collect information about the qualification process to measure how easy it is for organizations to
use. EPA needs this information to identify and make improvements to the process that buildings
use to qualify for the ENERGY STAR.
(i)
Data items
•
Application for ENERGY STAR Certification.
•
Audit information requested by EPA as part of its application review or quality
control audit:
ENERGY STAR Certification Audit Form; and
Indoor Environmental Quality Measurement Form for ENERGY STAR
Building Verification Site Visit.
•
Information provided to EPA for analysis of ENERGY STAR certified buildings.
(ii)
Respondent activities
16
•
Organizations applying for the ENERGY STAR perform the following:
Engage a Professional Engineer or Registered Architect to conduct a
facility data review, complete and stamp the application; 10 and
Complete and submit the online application to EPA and respond to EPA
questions if any.
•
Some organizations may be asked to complete forms as part of a quality control
audit performed by EPA on a percentage of applications.
•
ENERGY STAR certified buildings may be asked to respond to EPA questions for
analysis of ENERGY STAR certified buildings.
Plants (Private Sector)
Industrial companies have an opportunity to earn the ENERGY STAR certification for
specific types of plants that meet EPA’s energy efficiency criteria. To measure efficiency and
improve energy use in the company, a company enters basic information about its plant (e.g.,
energy consumption data) into a spreadsheet tool called the Energy Performance Indicator (EPI),
which can be downloaded from EPA’s ENERGY STAR web site. The EPI produces a plant
percentile score between 1 and 100 and compares that score to the most energy-efficient plants in
the industry and to the previous performance for the plant.
If the plant’s EPI score is in the top quartile of the industry’s energy performance scale,
the company can apply for the ENERGY STAR certification by printing out a Statement of
Energy Performance (SEP). A Professional Engineer (PE) verifies, signs and stamps the SEP, and
completes the PE Verification Checklist. The EPI, certified SEP, PE Verification Checklist, Plant
Award Specification Sheet, and Plant Award Application Letter are sent to EPA. If the submittal
contains confidential business information (CBI), the company sends the information to EPA’s
contractor to verify energy performance results. If approved by EPA, the plant receives the
ENERGY STAR certification.
Some companies may submit a profile of their certified plant that describes how the plant
improved its energy performance and obtained recognition. This submission is optional.
10
(i)
Data items
•
Information entered into the EPI or alternative tracking system:
Plant characteristics; and
Energy consumption.
The on-site portion of the facility review can be conducted every other year if applying in consecutive years.
17
•
Statement of Energy Performance.
•
PE Verification Checklist.
•
Plant Award Specification Sheet.
•
Plant Award Application Letter.
•
Profile of certified plant. This is optional.
(ii)
Respondent activities
•
Organizations seeking plant certification perform the following:
Enter information into the EPI or alternative system; and
Complete and submit the application materials to EPA.
•
Some organizations may also prepare and submit a profile of a certified plant. This
is optional.
ENERGY STAR Challenge for Industry (Private Sector)
EPA has established a tool, the ENERGY STAR Challenge for Industry (Challenge),
which encourages companies to pledge to reduce the energy intensity of their sites by 10% within
five years and track their progress towards this goal using a tracking system (e.g., company inhouse tracking systems, Portfolio Manager, EPA’s Energy Tracking Tool). Sites that achieve a
10% reduction in energy intensity within five years of their baseline have the opportunity to apply
for recognition from EPA.
Companies are asked to register their sites’ baseline energy intensity to participate in the
Challenge. Sites that have not achieved recognition in the past (e.g., first-time participants) are
asked to complete the online Challenge for Industry Registration Form. Sites that have achieved
recognition can re-register by checking a box on the online Challenge for Industry Recognition
Application. They do not need to complete the registration form again.
Each site completes the online Challenge for Industry Recognition Application and fills
out a Statement of Energy Improvement (SEI). A Professional Engineer (PE) verifies, prints,
signs, and stamps the SEI and completes a PE Verification Checklist, which are both then sent via
email to EPA. If approved by EPA, the site receives recognition (e.g., a certificate, congratulatory
letter to the CEO).
EPA may ask follow-up questions of companies whose sites achieved recognition (e.g.,
for program evaluation).
(i)
Data items
18
•
Challenge for Industry Registration Form.
•
Challenge for Industry Recognition Application.
•
Statement of Energy Improvement (SEI).
•
PE Verification Checklist.
•
Responses to EPA follow-up questions, if any.
(ii)
Respondent activities
•
Organizations seeking recognition under the ENERGY STAR Challenge for
Industry perform the following:
Prepare and submit the online Challenge for Industry Registration Form if
necessary;
Track energy use;
Prepare and submit the online Challenge for Industry Recognition
Application, SEI and PE Verification Checklist; and
Respond to EPA follow-up questions, if any.
Designed to Earn the ENERGY STAR (Private Sector)
To seek Designed to Earn the ENERGY STAR (DEES) recognition, an organization is
asked to become an ENERGY STAR Partner as an initial step. [Note that this ICR addresses
organizations’ becoming a Partner in the section, “Joining the ENERGY STAR Program and
Related Activities,” under the heading, “Commercial and Industrial Sector Partners.”] Then, an
organization can enter information into EPA’s online tool, Portfolio Manager, and follow simple
user prompts to save and generate information needed for the application. The tool can be used to
obtain an ENERGY STAR score of 1 – 100 to determine if the design project’s estimated annual
energy use meets criteria for DEES recognition.
The organization then generates a Statement of Energy Design Intent (SEDI). The SEDI is
printed, stamped and signed by a Registered Architect or Professional Engineer and Architect of
Record (AOR) and building owner/developer representatives. It is then submitted to EPA for
recognition. Once the application is approved, EPA will email instructions to organizations
meeting the DEES recognition criteria so they can download the DEES graphic.
(i)
Data items
•
Data entered into Portfolio Manager (e.g., property use data).
•
Statement of Energy Design Intent.
19
[Note: Organizations seeking recognition for commercial new construction design
projects are asked to submit the data items above. Organizations seeking recognition for
multifamily high rise new construction design projects are asked to submit the data items
above as well; they also are asked to submit additional documents. 11 These additional
documents are addressed in EPA ICR 2193, “EPA’s ENERGY STAR Program in the
Residential Sector” (OMB Control No. 2060-0586).]
(ii)
Respondent activities
•
Organizations submitting a DEES application perform the following activities:
Review application instructions and create account in Portfolio Manager, if
needed;
Gather design data and estimated annual energy use data;
Enter the data into Portfolio Manager; and
Complete and submit DEES application consisting of SEDI and, for
commercial design projects, Letters of Intent from the Architect of Record
(AOR) and building owner to EPA.
ENERGY STAR Awards (Private and Public Sector)
Organizations interested in receiving recognition for their efforts in improving their
energy performance may apply for an ENERGY STAR Award. EPA currently issues awards to
Commercial and Industrial (C&I) Sector Partners, Service and Product Providers (SPPs), and
Energy Efficiency Program Sponsors (EEPS).
(i)
Data items
•
Information provided by C&I Partners:
General information (e.g., contact information, address, signed/dated); and
Description of the following:
Management practices (e.g., best practices for managing energy).
Organization-wide improvements in energy performance.
Efforts in promoting and communicating success.
•
Information provided by SPPs:
General information (e.g., contact information, address, and signed/dated
certification); and
Description of the following:
Organization and Business Practices.
11
These documents include the following: Multifamily High Rise Developer Participation Agreement (5900-267),
Multifamily High Rise Project Application (5900-266), Multifamily High Rise Testing & Verification Worksheet
(5900-269), Multifamily High Rise Submittal Validation Form (5900-270), and Multifamily High Rise Performance
Path Calculator (5900-268).
20
Benchmarking and Certification (Existing Buildings).
Benchmarking and Certification (Design Projects).
Marketing and Recognition.
•
Information provided by EEPS:
General information (e.g., contact information, address, and signed/dated
certification); and
Description of the following:
Category(-ies) that the EEPS program is designed to address (e.g.,
energy improvements in the C&I sector).
Program design (e.g., in terms of goals).
How ENERGY STAR has been incorporated into the Partner’s
initiative.
Market effects resulting from Partner’s efforts.
Data sources used to support market claims.
(ii)
Respondent activities
•
Organizations that apply for an award are asked to:
Review the instructions; and
Complete and submit the information online.
Treasure Hunt, Improvement-Based Recognition (Private and Public Sector)
EPA provides guidance at its web site to assist owners and managers of commercial
buildings and industrial facilities in conducting walk-throughs to find ways to reduce energy.
Periodically, EPA may encourage these organizations to seek recognition of their voluntary
energy reduction efforts.
An organization seeking recognition first establishes an energy (and optionally, water and
waste) baseline of its facility using Portfolio Manager or Energy Performance Indicator (EPI). It
then plans and conducts a walk-through looking for and estimating energy and cost savings
opportunities. Finally, it submits a summary of this information to EPA, which provides
recognition if warranted.
An organization may decide to implement energy-savings measures and seek additional
recognition post-upgrade by verifying that it implemented the identified measures and/or
improved energy efficiency of its facility by 10, 20, 30 percent or more. This involves measuring
the energy savings using Portfolio Manager or EPI or an equivalent tool if an EPI is not available,
obtaining Professional Engineer verification, and submitting this information to EPA. The
Agency will provide additional recognition if available and warranted.
EPA may ask some organizations to submit a case study or best practices, e.g., for posting
at the EPA web site.
21
(i)
Data items
•
Data entered into Portfolio Manager or EPI.
•
Results of walk-through:
Basic building or plant information;
Energy data (e.g., fuel usage);
Water and waste data (optional); and
Summary of potential energy and cost savings opportunities.
•
Case study or best practices (optional).
(ii)
Respondent activities
•
Organizations seeking recognition perform the following:
Establish a baseline using Portfolio Manager or EPI;
Summarize estimates of potential energy and cost savings opportunities
identified during walk-through;
Submit information to EPA; and
If seeking additional recognition post-upgrade, measure the energy savings
(e.g., using Portfolio Manager), obtain PE verification and submit this
information to EPA.
•
Some organizations may submit a case study or best practices.
Tenant Recognition Program (Private and Public Sector)
In April 2015, Congress passed the Energy Efficiency Improvement Act of 2015. This
legislation mandates EPA to develop a voluntary recognition program for commercial tenants in
buildings. Tenants will be encouraged to design, build and operate their spaces to be energy
efficient. EPA will recognize tenants who meet EPA’s energy efficiency criteria for the design,
build-out and operation of energy efficient tenant spaces.
To apply for recognition, a tenant establishes an account in Portfolio Manager. [Note that
this ICR addresses setting up Portfolio Manager accounts in the section, “Benchmarking,” under
the heading, “Portfolio Manager.”] The tenant then gathers and enters data (e.g., office space
characteristics, lighting inventory) into the tool. If the energy efficiency criteria are met, an
application is generated by the tool. A Professional Engineer or Registered Architect reviews,
verifies and stamps the application. It then can be signed and uploaded to EPA. The Agency
reviews it and provides recognition if warranted. Some participants may be contacted by EPA to
answer questions about their submission, if needed.
(i)
Data items
22
•
Information entered in Portfolio Manager:
Office space characteristics (e.g., operating hours, number of workers);
Equipment inventory (e.g., types of equipment);
Copy of organization’s procurement policy;
Lighting inventory (e.g., type, number and wattage of lighting fixtures);
and
Information on energy meters.
•
Responses to EPA follow-up questions, if any.
(ii)
Respondent activities
•
Tenants seeking recognition perform the following:
Gather and enter data into Portfolio Manager;
Complete and submit an application for recognition if applicable criteria
are met; and
Respond to EPA follow-up questions, if any.
23
5.
THE INFORMATION COLLECTED, AGENCY ACTIVITIES, COLLECTION
METHODOLOGY, AND INFORMATION MANAGEMENT
5(a)
Agency Activities
This section describes EPA’s activities under ENERGY STAR.
JOINING THE ENERGY STAR PROGRAM AND RELATED ACTIVITIES
Partnership Agreements and Related Activities
•
EPA performs the following activities in regard to Partnership Agreements and
related materials for all Partners:
Review the completed Partnership Agreements and related materials;
Follow up with Partners, if needed;
Send emails, passwords, and welcome aboard kits; and
Update and maintain the ENERGY STAR web site.
•
EPA performs the following additional activities in regard to SPPs:
Request updated contact information annually;
Receive and enter updated contact information into database;
Receive and process efforts and successes; and
Receive and process other requested materials for appropriate Partnership
category.
•
EPA receives annual updates from EEPS and updates the Directory of Energy
Efficiency Programs.
BENCHMARKING
Portfolio Manager
•
EPA performs the following activities related to the benchmarking process:
Upgrade Portfolio Manager to enhance functionality (easier data entry,
more sharing options, more reporting metrics, etc);
Maintain secure database infrastructure, including maintaining a firewall
and monitoring system activity;
Perform system maintenance activities, such as deploying software patches,
correcting defects, etc.; and
Collect data submitted through Excel spreadsheets and enter data into
Portfolio Manager.
24
•
EPA performs the following activities in evaluating the usability of Portfolio
Manager and the effectiveness of guidance and trainings on benchmarking in the
tool:
Solicit feedback from respondents;
Review answers to questions; and
Design and develop Portfolio Manager software changes, as applicable, to
make the tool more effective.
Data Collection for Model Development and Beta Testing
•
EPA conducts the data collections.
RECOGNITION
ENERGY STAR Certification
Buildings
•
EPA performs the following activities for buildings applying for the ENERGY
STAR:
Review applications and follow up with organization if questions; and
Send a letter of denial or acceptance.
•
EPA collects information from ENERGY STAR certified buildings in performing
periodic quality control audits.
•
EPA performs the following activities in evaluating ENERGY STAR certified
buildings:
Solicit feedback from respondents;
Review answers to questions; and
Take follow-up action.
Plants
•
EPA performs the following activities for companies seeking the ENERGY STAR
certification for their plants:
Enhance the functionality of and maintains the EPI and other tools and
information on the web site;
Review and evaluate the submissions;
Give permission to display the ENERGY STAR certification logo; and
Review and post profiles of certified plants on the web site.
25
ENERGY STAR Challenge for Industry
•
EPA performs the following activities under the ENERGY STAR Challenge for
Industry:
Review online Challenge for Industry Registration Form;
Review online Challenge for Industry Recognition Application, SEI and PE
Verification Checklist and provide recognition; and
Ask follow-up questions if any.
Designed to Earn the ENERGY STAR
•
EPA performs the following activities for the graphic:
Evaluate the DEES applications; and
Update the ENERGY STAR web site to reflect the information collected.
ENERGY STAR Awards
•
EPA performs the following activities to administer the awards process:
Develop the awards criteria;
Receive and review the information submitted; and
Take follow-up action (e.g., send letters of award or loss).
Treasure Hunt, Improvement-Based Recognition
•
EPA performs the following activities for this program:
Receive and review submissions and provide recognition if warranted;
For organizations seeking additional recognition, receive and review
submissions and provide recognition if warranted; and
Receive and review case study or best practices.
Tenant Recognition Program
•
EPA performs the following activities under the Tenant Recognition program:
Review applications and provide recognition if warranted; and
Contact participants and ask questions, if needed.
5(b)
Collection Methodology and Management
EPA gives respondents the ability to fill out forms (e.g., Partnership Agreements) and
tools electronically. In addition, respondents can submit the information electronically (e.g., via
web forms, email), without the use of postal mail. EPA reviews the submittals to ensure their
accuracy and completeness.
26
5(c)
Small Entity Flexibility
Under ENERGY STAR, EPA has made enhancements to its information collections
where possible to streamline the efforts of small businesses in reporting information and deriving
energy savings. For example, EPA recently added a feature to Portfolio Manager, its interactive
energy management tool, to better promote opportunities for automated data transfer through Web
Services, which is offered as a free service increasingly by many utilities. Web Services is
particularly beneficial for small businesses, which are less likely to have resources to manage
Portfolio Manager data entry themselves.
Through Web Services, users set up buildings in Portfolio Manager and create a
connection with the utility, and then the energy bills are automatically uploaded to Portfolio
Manager on a monthly basis. EPA modified Portfolio Manager to notify small business users if
they are located in a utility service territory that offers free Web Services. The notification
includes a link to the provider's web site to help them connect with the provider and learn about
its services.
.
5(d) Collection Schedule
No information collection in this ICR requires collection more frequently than quarterly.
Many collections are implemented on a one-time or annual basis. Respondents may voluntarily
submit information more frequently.
27
6.
ESTIMATING THE BURDEN AND COST OF THE COLLECTION
6(a)
Estimating Respondent Burden
Exhibits 1 through 3 estimate the annual respondent burden hours for information
collection activities associated with the ENERGY STAR program in the commercial and
industrial sectors. Table 1 presents the total annual hours to respondents under all activities.
6(b)
Estimating Respondent Costs
Exhibits 1 through 3 present the annual respondent costs for information collection
activities associated with the ENERGY STAR program in the commercial and industrial sectors.
Table 1 presents the total annual respondent costs under all activities. Specific cost assumptions
are discussed below.
(i)
Estimating Labor Costs
EPA estimates an average hourly respondent labor cost ($2019) of $115.16/hr for legal
staff, $100.18/hr for managerial staff, $47.21/hr for technical staff, and $29.96/hr for clerical staff.
To derive these hourly estimates, EPA referred to the May 2017 National Occupational
Employment and Wage Estimates published by the U.S. Bureau of Labor Statistics. 12 This
publication summarizes the unloaded (base) hourly rate for major occupational groups. 13 EPA
then applied the standard government overhead factor of 1.6 to the unloaded rate to derive loaded
hourly rates. Finally, EPA updated the loaded hourly rates to December 2018 levels using
Employment Cost Indexes developed by the U.S. Bureau of Labor Statistics. 14
(ii)
Estimating Capital and Operations and Maintenance (O&M) Costs
Operation and maintenance (O&M) costs are those costs associated with a paperwork
requirement incurred continually over the life of the ICR. They are defined by the Paperwork
Reduction Act of 1995 as “the recurring dollar amount of costs associated with O&M or
purchasing services.” This ICR includes lump-sum costs that respondents pay for contractor
support in the completion of various collections, as listed below ($2019):
12
U.S. Bureau of Labor Statistics (BLS), Occupational Employment Statistics (OES), May 2017 National
Occupational Employment and Wage Estimates. Available online at:
https://www.bls.gov/oes/2017/may/oes_nat.htm#23-0000.
13
For purposes of this analysis, the following occupational groups of the U.S. Bureau of Labor Statistics (BLS) were
used: Legal staff, SOC 23-1011, Lawyers; managerial staff, BLS SOC Code 11-1021, General and Operations
Managers; technical staff, BLS SOC Code 17-3027, Mechanical Engineering Technicians; and clerical staff, BLS
SOC Code 43-6014, Secretaries and Administrative Assistants, Except Legal, Medical, and Executive.
14
Bureau of Labor Statistics, Economic News Release, “Table 2. Seasonally adjusted: Employment Cost Index for
wages and salaries, by ownership, occupational group, and industry.” Available online at:
https://www.bls.gov/news.release/eci.t02.htm.
28
•
$1,200 for a respondent to obtain support from an external Professional Engineer
or Registered Architect to conduct a facility data review in applying for ENERGY
STAR certification for a building.
•
$3,480 for a petroleum company to obtain support from a consulting service to
generate energy-efficiency results of its plant for ENERGY STAR certification for
a plant.
•
$130 for a respondent to obtain support from an external Registered Architect or
Professional Engineer in completing (e.g., reviewing, signing) the Statement of
Energy Design Intent (SEDI) for DEES recognition.
•
$1,060 for a respondent to obtain third-party verification of the submittal for
recognition under the Tenant Recognition program.
There are no capital costs associated with any activities related to the ENERGY STAR
program in the commercial and industrial sectors.
6(c)
Estimating Agency Burden and Costs
(i)
Estimating Labor Costs
The hourly Agency labor rates used in this ICR were obtained from the 2019 Salary
Tables for federal civilian employees, which are published by the Office of Personnel
Management. 15 EPA estimates an average hourly labor cost of $80.59/hr for legal staff, $75.36/hr
for managerial staff, $55.26/hr for technical staff, and $22.19/hr for clerical staff. The labor costs
are based on the following GS levels and steps: legal labor rates were based on GS Level 15,
Step 1, managerial labor 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 multiplied hourly rates by the standard government overhead factor
of 1.6. Agency burden and costs are estimated in Exhibits 4 through 6 and Table 2.
(ii)
Estimating Capital and Operations and Maintenance (O&M) Costs
For certain information collections, EPA sends items to respondents using the U.S. postal
service and incurs $0.55 for postage. This includes decals and other items that cannot be sent
electronically.
6(d)
Estimating the Respondent Universe
15
See 2019 General Schedule (Base), “SALARY TABLE 2019-GS RATES FROZEN AT 2018 LEVELS
EFFECTIVE JANUARY 2019,” available at: https://www.opm.gov/policy-data-oversight/pay-leave/salarieswages/salary-tables/pdf/2019/GS_h.pdf.
29
In this section, EPA describes its estimates of the number of respondents carrying out the
information collections under the ENERGY STAR program in the commercial and industrial
(C&I) sectors. In developing its estimates, EPA referred to its databases and other documentation
in order to understand historical trends in the number of new and existing respondents. Based on
this understanding, EPA has estimated the average annual number of respondents associated with
each of the information collections under the program.
In total, EPA estimates 37,021 organizations participate under the ENERGY STAR
program in the commercial and industrial sectors annually. In deriving this estimate, EPA
ascertained the annual number of users of its online tool, Portfolio Manager (36,500
organizations). EPA notes that most respondents in this ICR use the tool during the year and are
therefore captured in this estimate. For example, organizations seeking recognition (e.g., under
ENERGY STAR certification for buildings) benchmark their buildings in Portfolio Manager and
are therefore reflected in the estimate. Therefore, to avoid double-counting, EPA next identified
organizations not captured in the 36,500-organization estimate. EPA estimates that 521
organizations carry out collections that do not involve the tool (36,500 + 521 = 37,021
respondents). Most of the 521 organizations are industrial plants that use the EPI or other tool
instead of Portfolio Manager to track their energy performance.
These organizations are discussed further below.
JOINING THE ENERGY STAR PROGRAM AND RELATED ACTIVITIES (EXHIBIT 1)
Commercial and Industrial Sector Partners
EPA estimates that, on average, 150 organizations in the commercial and industrial sectors
will submit a Partnership Agreement to EPA each year. EPA may ask Partners follow-up
questions. In addition, EPA believes that organizations joining the program already have some
form of existing plans for energy management, which they have prepared as a usual and
customary industry practice. EPA estimates that, each year, five organizations will update their
existing plans to meet ENERGY STAR best practice criteria.
Service and Product Providers
EPA estimates that, on average, 70 SPPs will submit a Partnership Agreement to EPA
each year through an online system. These SPPs will also submit requested materials for their
appropriate category (e.g., Teaming Profiles from Industrial SPPs). In addition, EPA estimates
that, on average, 200 existing SPPs will update their contact information and 125 existing SPPs
will communicate their efforts and successes to EPA annually.
Energy Efficiency Program Sponsors
EEPS are given the opportunity to join one or more programs within ENERGY STAR
(e.g., C&I, Products) when they complete and submit their Partnership Agreement. The ICR,
30
“EPA’s ENERGY STAR® Product Labeling” (EPA ICR No. 2078, OMB Control Number 20600528), will consolidate the burden for the EEPS Partnership Agreement across all ENERGY
STAR programs. 16 As such, this ICR (EPA ICR 1772.08) does not estimate the burden for EEPS
Partnership Agreements.
EPA estimates that, on average, 60 existing EEPS will actively participate in the program,
update contact information on the ENERGY STAR web site and DEEP, and provide information
to promote energy efficiency as an easy and desirable option for organizations and consumers to
prevent pollution, protect the global environment, and save on energy bills.
BENCHMARKING (EXHIBIT 2)
Portfolio Manager
To estimate Portfolio Manager’s burden, EPA collected and analyzed historical data about
the tool, including the annual number of new and active accounts and buildings benchmarked. 17
EPA collected data on the three benchmarking methods offered by the tool: manual data entry,
data entry with Excel spreadsheet, and data entry using Electronic Web Services. EPA entered the
data into an Excel-based model to estimate total annual burden. The table below presents the
annual number of new and active accounts and benchmarked buildings estimated over the next
three years.
Annual Number of New Accounts, Benchmarked Buildings and Active Accounts
in Portfolio Manager1
Annual No. of
Annual No.
Annual Number
Buildings
Benchmarking Method
of New
of Active
Benchmarked –
Accounts
Accounts
Total
1. Manual Data Entry
21,800
66,000
29,600
2. Data Entry with Excel
700
14,000
300
Spreadsheet
3. Data Entry using Electronic Web Services
Provider Accounts
26
219,000
6,600
Customer Accounts
1,200
Total
23,726
299,000
36,500
These estimates are based on an analysis of historical data from standard reports (e.g., benchmarking reports,
quarterly data import reports) and extrapolation over the next three years.
1
EPA is currently renewing ICR 2078 and consolidating the burden of EEPS Partnership Agreements across all
ENERGY STAR programs. ICR 2078 includes the EEPS Partnership Agreement (EPA Form 5900-33), which is used by
all EEPS.
17
As used in this ICR, the number of “buildings benchmarked annually” equals the number of “annual benchmarks”
(i.e., the terms represent the same quantity).
31
16
The model used the data in the table to estimate the burden of each benchmarking method,
as discussed below:
•
Manual Data Entry. EPA estimates that, each year, 21,800 users will read the
instructions and set up an account in Portfolio Manager to benchmark their
buildings manually. In addition, EPA estimates that 66,000 buildings will be
manually benchmarked annually, on average. Of these, EPA estimates that users
will benchmark 65% (42,900) by gathering facility and energy data for their
buildings not using standard industry practices. EPA estimates that users will
benchmark 35% (23,100) by gathering facility and energy data for their buildings
using standard industry practices (i.e., usual and customary business practices that
would be conducted even in the absence of ENERGY STAR). These practices
could include, for example, compiling and keeping readily available, centralized
paper and/or electronic records (e.g., invoices, facility data) for their portfolio of
buildings. Users who employ such standard industry practices would generally
incur a lower incremental burden than others to gather data for Portfolio Manager.
All users will enter the data into Portfolio Manager to benchmark their buildings.
Finally, of the 66,000 buildings benchmarked, EPA estimates that 27.27% (17,998)
are new benchmarks (i.e., buildings benchmarked for the first time) and 72.73%
(48,002) are repeats.
Exhibit 2 includes weighted-average burden estimates for gathering and entering
data into Portfolio Manager to account for standard business practices as well as
new and repeat benchmarks. See the table below for the inputs used in these
weighted-average calculations.
Manual Data Entry
Activity
Gathering data for benchmarks not
using standard business practices
Gathering data for benchmarks using
standard business practices
Entering data into Portfolio Manager
No. of Buildings1
Burden per
New
Benchmark
Burden per
Repeat
Benchmark
42,900
4 hrs
0.5 hr
23,100
2 hrs
0.25 hr
66,000
0.75 hr
0.25 hr
EPA estimates that 27.27% of the buildings in this column are new benchmarks (i.e., buildings benchmarked for the
first time) and 72.73% are repeats.
1
•
Data Entry with Excel Spreadsheet. EPA estimates that, each year, 700
organizations will set up an account to provide their data via Excel spreadsheet to
EPA. The data will be uploaded into Portfolio Manager. In addition, EPA
estimates that 14,000 buildings will be benchmarked annually using this method.
Of these, EPA estimates that 50% (7,000) are new benchmarks (i.e., buildings
benchmarked for the first time) and 50% are repeats.
32
Exhibit 2 includes weighted-average burden estimates for gathering and entering
data into Portfolio Manager to account for new and repeat benchmarks. See the
table below for the inputs used in these weighted-average calculations.
Data Entry with Excel Spreadsheet
Burden per
Activity
No. of Buildings1
New
Benchmark
Gathering data for benchmarks
14,000
2 hrs
Entering data into Portfolio Manager
14,000
0.25 hr
Burden per
Repeat
Benchmark
0.25 hr
0.10 hr
EPA estimates that 50% of the buildings in this column are new benchmarks (i.e., buildings benchmarked for the
first time) and 50% are repeats.
1
•
Data Entry using Electronic Web Services. EPA expects that 26 new providers will
use this benchmarking method each year. EPA estimates that new accounts also
will be established for 1,200 customers each year. In addition, EPA estimates that
information will be gathered and entered into Portfolio Manager for 219,000
buildings annually. Of these, EPA estimates that 11.41% (24,988) are new
benchmarks (i.e., buildings benchmarked for the first time) and 88.59% (194,012)
are repeats.
Exhibit 2 includes weighted-average burden estimates for gathering and entering
data into Portfolio Manager to account for new and repeat benchmarks. See the
table below for the inputs used in these weighted-average calculations.
Data Entry using Electronic Web Services
Burden per
1
Activity
No. of Buildings
New
Benchmark
Gathering data for benchmarks
219,000
1 hr
Entering data into Portfolio Manager
219,000
0.1 hr
Burden per
Repeat
Benchmark
0 hr
0.1 hr
EPA estimates that 11.41% of the buildings in this column are new benchmarks (i.e., buildings benchmarked for the
first time) and 88.59% are repeats.
1
Further, EPA estimates that, each year, it will ask 50 users of Portfolio Manager about the
usability of the tool. It will also ask 50 users for feedback about the guidance or training on the
tool each year.
Data Collection for Model Development and Beta Testing
EPA expects to expand Portfolio Manager or the Energy Performance Indicator (EPI)
downloadable spreadsheet tools by adding new facility types and revising existing types. In doing
so, the Agency may need to gather information for model development and/or beta testing to
33
make sure the tool produces relevant results. EPA expects that organizations will submit
information on 950 properties annually.
RECOGNITION (EXHIBIT 3)
ENERGY STAR Certification
Buildings
EPA estimates that organizations will submit 7,000 applications for the ENERGY STAR
each year. These organizations must benchmark the building, engage a Professional Engineer or
Registered Architect to conduct a facility data review, and submit an online Application for
ENERGY STAR Certification to EPA. [Note that this ICR burdens participants for benchmarking
in the section, “Benchmarking,” under the heading, “Portfolio Manager.” See Exhibit 2.] EPA
estimates that 85% will contract a Professional Engineer or Registered Architect and 15% will use
an in-house Professional Engineer or Registered Architect to perform the facility review. 18
Further, in the spring of 2018, EPA clarified that on-site facility reviews can be performed every
other year (instead of annually) for buildings that apply for certification in consecutive years.
Because of this, EPA expects the number of on-site facility reviews to decrease by one-third
annually. Hence, EPA estimates that 3,987 facility reviews will be performed by a contracted
Professional Engineer or Registered Architect (7,000 applications x 85% x 67%) and 704 facility
reviews by an in-house Professional Engineer or Registered Architect (7,000 applications x 15%
x 67%) annually.
In addition, EPA estimates that, each year, it will ask for additional information from up to
240 applications for ENERGY STAR certification as part of its quality control audits.
EPA also expects to contact representatives of buildings that have earned the ENERGY
STAR to collect information about the characteristics of buildings that lead to top energy
performance. EPA will also collect information about the qualification process to measure how
easy it is for organizations to use. EPA intends to contact no more than 66 representatives
annually.
Plants
EPA estimates that industrial companies will seek ENERGY STAR certification for 115
plants annually, on average, during the 3-year life of this ICR. EPA expects all companies, except
petroleum companies, to use the Energy Performance Indicator (EPI) to track plant energy
performance and generate the Statement of Energy Performance (SEP). EPA estimates this will
be done for 105 non-petroleum plants annually.
18
EPA conducted limited industry consultations in preparing this ICR and improved its estimate of the cost to hire an
external LP. EPA adjusted the cost from $1,665 to $1,200 per property based on industry input. Refer to Section 3(c)
for a summary of the consultations.
34
EPA expects petroleum companies to use a third-party consulting service to measure the
energy efficiency of their plants. To request a plant score from the consulting service, a petroleum
company is estimated to spend 10 minutes and $3,480 as a flat fee per plant. EPA estimates this
will be done for 10 petroleum plants annually.
EPA expects these non-petroleum and petroleum companies to complete the application
materials (e.g., Plant Award Specification Sheet, Plant Award Application Letter, PE Checklist,
Statement of Energy Performance) and submit them to EPA (115 plants/yr).
EPA estimates that four profiles of certified plants will be submitted annually. Profiles are
optional.
ENERGY STAR Challenge for Industry
Companies are asked to register their sites to participate in the Challenge for Industry.
EPA estimates that 60 sites will complete the online Challenge for Industry Registration Form
annually. A site is asked to complete this form if it has not achieved recognition in the past (e.g.,
first-time participants). A site that has achieved recognition in the past and is applying again can
re-register by checking a box on the online Challenge for Industry Recognition Application. They
do not need to complete the registration form again. EPA estimates that 40 sites will re-register
using the recognition application annually.
EPA estimates that 40 sites will seek recognition each year by preparing and submitting
the application materials. There are two options for completing the Statement of Energy
Improvement (SEI). One option is to track energy using an in-house system and then complete the
SEI. EPA estimates that these sites use their existing in-house system to track their energy
performance as a standard industry practice (i.e., usual and customary business practices that
would be conducted even in the absence of ENERGY STAR). EPA does not expect them to incur
any incremental burden in tracking their energy performance under the ENERGY STAR
Challenge for Industry. EPA estimates that 39 sites will use this option annually.
Another option is to use EPA’s Energy Tracking Tool (ETT) to generate the SEI. Unlike
sites that use their existing in-house systems as a standard industry practice, sites using the ETT
will incur incremental burden to set up and use the system. EPA estimates that one site will use
this option annually.
In addition, all 40 sites are asked to complete the online Challenge for Industry
Recognition Application and PE Verification Checklist.
Finally, EPA estimates that, each year, it will contact 33 companies with sites that have
achieved the Challenge for Industry, e.g., for program evaluation purposes.
35
Designed to Earn the ENERGY STAR
EPA estimates that 25 Designed to Earn the ENERGY STAR (DEES) applications will be
submitted to EPA each year by organizations seeking recognition for commercial or multifamily
high rise (MFHR) new construction design projects. The application process involves reviewing
the DEES application instructions and setting up a new account in Portfolio Manager if needed.
EPA estimates six first-time applicants will need to perform these activities. In addition, it
involves gathering and entering design data into the tool and preparing a DEES application
package consisting of a Statement of Energy Design Intent (SEDI). The application is emailed to
EPA. [Note: In addition to these documents, organizations with MFHR projects are asked to
submit additional documents which are not addressed in this ICR. Rather, they are addressed in
EPA ICR 2193, “EPA’s ENERGY STAR Program in the Residential Sector” (OMB Control No.
2060-0586).]
ENERGY STAR Awards
EPA estimates that 75 C&I Partners, 15 SPPs, and 15 EEPS will apply for an ENERGY
STAR Award each year. Of the 75 C&I Partners, EPA estimates that 39 will apply for a Sustained
Excellence Award, which recognizes sustained excellence in energy management in partnership
with ENERGY STAR. They submit streamlined application materials.
Treasure Hunt, Improvement-Based Recognition
EPA estimates that 50 commercial building and 100 industrial organizations will seek
recognition annually. They will first establish a baseline for the building or industrial facility
using Portfolio Manager or EPI. [Note: This ICR burdens the use of Portfolio Manager in the
section, “Benchmarking,” under the heading, “Portfolio Manager.” See Exhibit 2.] They then
plan and conduct a walk-through, estimate the energy and cost savings opportunities, and submit
a summary of this information to EPA. [Note: EPA believes the walk-through and estimation of
savings are, for the most part, a usual and customary business practice that would be conducted
even in the absence of ENERGY STAR. The recognition program adds minor incremental
burden.]
In addition, EPA estimates that 50 commercial buildings and 25 industrial facilities will
decide to implement their energy savings measures and seek additional recognition post-upgrade
annually. These applicants will measure the energy savings, obtain PE verification and submit this
information to EPA. EPA assumes that applicants will use an internal PE for verification.
Finally, EPA estimates that 10 organizations will submit a case study or best practices
annually.
Tenant Recognition Program
EPA estimates that 300 organizations will establish an account in Portfolio Manager to
participate in the program annually. [Note that this ICR addresses setting up Portfolio Manager
36
accounts in the section, “Benchmarking,” under the heading, “Portfolio Manager.”] These
organizations will gather and enter data (e.g., equipment and lighting inventory data) into the tool.
If the energy efficiency criteria are met, an application is generated by the tool, which is
completed by the organization (e.g., reviewed/stamped by a Professional Engineer or Registered
Architect) and uploaded to EPA. EPA estimates that 200 applications will be completed and
submitted annually. In addition, some participants may be contacted by EPA to answer questions
about their submission, if needed.
37
Exhibit 1*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Joining the ENERGY STAR Program and Related Activities
Hours and Costs Per Respondent per Activity
Legal
Total Hours and Costs
Managerial
Technical
Clerical
$115.16
$100.18
$47.21
$29.96
0.00
0.00
0.00
0.25
0.00
varies
0.25
0.25
0.25
0.00
0.00
0.00
0.50
0.25
varies
$36.85
$11.80
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
150
25
varies
75.00
6.25
81.25
$5,527.50
$295.00
$5,822.50
0.00
0.00
0.00
0.00
0.00
varies
5.00
5.00
varies
0.00
0.00
0.00
5.00
5.00
varies
$236.05
$236.05
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
5
5
varies
25.00
25.00
106.25
$1,180.25
$1,180.25
$7,002.75
Complete and submit the Partnership Agreement online
0.00
0.50
0.50
0.00
1.00
$73.70
$0.00
$0.00
70
70.00
$5,159.00
Complete and submit requested materials for appropriate
partnership category
0.00
0.00
0.07
0.00
0.07
$3.30
$0.00
$0.00
70
4.90
$231.00
0.00
0.50
0.57
0.00
1.07
$77.00
$0.00
$0.00
70
74.90
$5,390.00
0.00
0.00
0.00
varies
0.00
0.50
varies
varies
0.16
0.50
varies
varies
0.00
0.00
0.00
varies
0.16
1.00
varies
varies
$7.55
$73.70
varies
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
200
125
varies
varies
32.00
125.00
157.00
231.90
$1,510.00
$9,212.50
$10,722.50
$16,112.50
Information Collection Activity
Total Hours/
Activity
Labor Costs/ Capital Startup O&M Costs/
Number of
Activity
Costs/ Activity
Activity
Activities/ YeaTotal Hours/Ye Total Cost/Year
Commercial and Industrial Sector Partners
Partnership Agreement
Complete and submit the Partnership Agreement online
Respond to EPA follow-up questions, if any
Subtotal
Related Activities
Update existing energy management plan
Subtotal
Subtotal (for Commercial and Industrial Sector Partners)
Service and Product Providers
Partnership Agreement
Subtotal
Related Activities
Update contact information as needed
Communicate efforts and successes
Subtotal
Subtotal (for Service and Product Providers)
38
Exhibit 1 (continued)*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Joining the ENERGY STAR Program and Related Activities
Hours and Costs Per Respondent per Activity
Legal
Information Collection Activity
Total Hours and Costs
Managerial
Technical
Clerical
$100.18
$47.21
$29.96
0.25
0.75
0.00
1.50
$118.03
$0.00
$0.00
0
0.00
$0.00
0.00
varies
0.00
varies
0.00
varies
0.08
varies
0.08
varies
$2.40
varies
$0.00
$0.00
$0.00
$0.00
0
0
0.00
0.00
$0.00
$0.00
0.00
0.00
0.00
0.08
0.08
$2.40
$0.00
$0.00
60
4.80
$144.00
0.00
0.10
2.00
0.15
2.25
$108.93
$0.00
$0.00
60
135.00
$6,535.80
0.00
varies
varies
0.10
varies
varies
2.00
varies
varies
0.23
varies
varies
2.33
varies
varies
$111.33
varies
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
60
varies
varies
139.80
139.80
477.95
$6,679.80
$6,679.80
$29,795.05
$115.16
Total Hours/
Activity
Number of
Labor Costs/ Capital Startup O&M Costs/
Activity
Activities/ YeaTotal Hours/Ye Total Cost/Year
Activity
Costs/ Activity
Energy Efficiency Program Sponsors
Partnership Agreement
Organizations Submitting Entire Partnership Agreement
Complete and submit the Partnership Agreement
0.50
Organizations Submitting Updated Participation Form Only
Update and submit Participation Form online
Subtotal
Related Activities
Update organization and contact information displayed on
the Web site and DEEP
Provide information to promote ENERGY STAR in the
commercial and/or industrial markets
Subtotal
Subtotal (for Energy Efficiency Program Sponsors )
TOTAL
* Exhibit contains rounding.
39
Exhibit 2*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Benchmarking
Total Hours and Costs
Hours and Costs Per Respondent per Activity
Legal
Managerial
Technical
Clerical
$115.16
$100.18
$47.21
$29.96
0.00
0.00
0.50
0.00
0.50
$23.61
$0.00
$0.00
21,800
10,900.00
$514,698.00
0.00
0.00
1.00
0.00
1.00
$47.21
$0.00
$0.00
700
700.00
$33,047.00
0.00
0.00
250.00
0.00
250.00
$11,802.50
$0.00
$0.00
26
6,500.00
$306,865.00
0.00
0.00
0.00
0.00
1.40
varies
0.00
0.00
1.40
varies
$66.09
varies
$0.00
$0.00
$0.00
$0.00
1,200
varies
1,680.00
19,780.00
$79,308.00
$933,918.00
Gather facility and energy data
Enter data into Portfolio Manager
Subtotal
0.00
0.00
0.00
0.00
0.00
0.00
1.20
0.40
1.60
0.00
0.00
0.00
1.20
0.40
1.60
$56.65
$18.88
$75.53
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
66,000
66,000
66,000
79,200.00
26,400.00
105,600.00
$3,738,900.00
$1,246,080.00
$4,984,980.00
Data Entry using Excel Spreadsheet (per building)
Gather facility and energy data
Enter data into Portfolio Manager/spreadsheet
Subtotal
0.00
0.00
0.00
0.00
1.10
0.20
0.00
0.00
1.10
0.20
$51.93
$9.44
$0.00
$0.00
$0.00
$0.00
14,000
14,000
15,400.00
2,800.00
$727,020.00
$132,160.00
0.00
0.00
1.30
0.00
1.30
$61.37
$0.00
$0.00
14,000
18,200.00
$859,180.00
0.00
0.00
0.00
0.00
0.00
0.00
0.10
0.10
0.20
0.00
0.00
0.00
0.10
0.10
0.20
$4.72
$4.72
$9.44
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
219,000
219,000
219,000
21,900.00
21,900.00
43,800.00
$1,033,680.00
$1,033,680.00
$2,067,360.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.25
0.17
varies
varies
0.00
0.00
0.00
0.00
0.25
0.17
varies
varies
$11.80
$8.03
varies
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
50
50
varies
varies
12.50
8.50
21.00
187,401.00
$590.00
$401.50
$991.50
$8,846,429.50
Information Collection Activity
Portfolio Manager
Set Up of New Accounts
New Accounts using Manual Entry - Review instructions in Portfolio Manager
and set up account
New Accounts using Spreadsheet Upload - Review instructions in Portfolio
Manager and set up account
New Providers using Data Exchange - Review instructions and set up
account and automated process
New Accounts using Data Exchange - Conduct initial customer set-up
Subtotal
Total Hours/
Activity
Capital
Labor Costs/
Startup Cost
Activity
Activity
O&M Costs/ Number of
Activity
Activities/ Ye
Total Hours/Year
Total Cost/Year
Manual Data Entry (per building)
Data Entry using Electronic Web Services (per building)
Gather facility and energy data
Submit information to EPA monthly and retrieve/relay scores to customers
Subtotal
Evaluation of Portfolio Manager
Respond to questions about usability of tool
Respond to questions about guidance or training on tool
Subtotal
Subtotal (for Portfolio Manager)
40
Exhibit 2 (continued)*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Benchmarking
Hours and Costs Per Respondent per Activity
Legal
Information Collection Activity
Data Collection for Model Development and Beta Testing
Review instructions of Portfolio Manager or spreadsheet
Gather facility and energy data
Enter data into Portfolio Manager or spreadsheet
Subtotal (for Information for Model Development and Beta Testing)
TOTAL
Managerial
Technical
Clerical
$115.16
$100.18
$47.21
$29.96
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.14
1.79
0.32
2.25
varies
0.00
0.00
0.00
0.00
0.00
*Exhibit contains rounding.
41
Total Hours/
Activity
0.14
1.79
0.32
2.25
varies
Total Hours and Costs
Capital
Labor Costs/ Startup Cost
Activity
Activity
$6.61
$84.51
$15.11
$106.23
varies
$0.00
$0.00
$0.00
$0.00
$0.00
O&M Costs/ Number of
Activity
Activities/ Ye
$0.00
$0.00
$0.00
$0.00
$0.00
950
950
950
950
varies
Total Hours/Year
133.00
1,700.50
304.00
2,137.50
189,538.50
Total Cost/Year
$6,279.50
$80,284.50
$14,354.50
$100,918.50
$8,947,348.00
Exhibit 3*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Recognition
Hours and Costs Per Respondent per Activity
Legal
Information Collection Activity
Total Hours and Costs
Managerial
Technical
Clerical
$115.16
$100.18
$47.21
$29.96
0.00
0.00
2.00
0.00
2.00
$94.42
$0.00
$1,200.00
3,987
7,974.00
$5,160,852.54
0.00
0.00
3.00
0.00
3.00
$141.63
$0.00
$0.00
704
2,112.00
$99,707.52
0.00
0.00
0.00
1.00
1.00
$29.96
$0.00
$0.00
7,000
7,000.00
$209,720.00
0.00
0.00
2.00
0.00
2.00
$94.42
$0.00
$0.00
240
480.00
$22,660.80
Total Hours/ Labor Costs/ Capital Startup
Activity
Activity
Costs/ Activity
O&M Costs/
Activity
Number of
Activities/ Yea Total Hours/Yea
Total Cost/Year
ENERGY STAR Certification
Buildings
Contract a Professional Engineer or Registered Architect to conduct a
facility data review
Engage an internal Professional Engineer or Registered Architect to
conduct a facility data review
Complete and submit the online application to EPA and respond to EPA
questions if any
Provide additional information to EPA as part of quality control audit, if
requested
Respond to EPA questions for the analysis of ENERGY STAR certified
buildings, if requested
Subtotal (for Buildings)
0.00
0.00
0.40
0.00
0.40
$18.88
$0.00
$0.00
66
26.40
$1,246.08
0.00
0.00
varies
varies
varies
varies
$0.00
varies
varies
17,592.40
$5,494,186.94
42
Exhibit 3* (continued)
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Recognition
Hours and Costs Per Respondent per Activity
Legal
Information Collection Activity
Total Hours and Costs
Managerial
Technical
Clerical
$115.16
$100.18
$47.21
$29.96
0.00
0.00
0.00
0.08
0.30
0.50
0.00
0.17
0.30
0.75
$14.16
$36.71
$0.00
$0.00
$0.00
$0.00
105
105
31.50
78.75
$1,486.80
$3,854.55
0.00
0.00
0.00
0.08
0.17
0.50
0.00
0.17
0.17
0.75
$8.03
$36.71
$0.00
$0.00
$3,480.00
$0.00
10
10
1.70
7.50
$34,880.30
$367.10
0.08
varies
varies
0.08
varies
varies
0.34
varies
varies
0.00
varies
varies
0.50
varies
varies
$33.28
varies
varies
$0.00
$0.00
$0.00
$0.00
varies
varies
4
varies
varies
2.00
121.45
17,713.85
$133.12
$40,721.87
$5,534,908.81
Total Hours/ Labor Costs/ Capital Startup
Activity
Activity
Costs/ Activity
O&M Costs/
Activity
Number of
Total Hours/Yea
Activities/ Yea
Total Cost/Year
ENERGY STAR Certification
Plants
Non-Petroleum Plants
Enter information into the EPI
Complete and submit materials to EPA
Petroleum Plants
Generate energy-efficiency results
Complete and submit materials to EPA
All Plants (optional profiles)
Prepare and submit profile of certified plant
Subtotal (for Plants)
Subtotal (for ENERGY STAR Certification)
43
Exhibit 3 (continued)*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Recognition
Hours and Costs Per Respondent per Activity
Legal
Information Collection Activity
Total Hours and Costs
Managerial
Technical
Clerical
$115.16
$100.18
$47.21
$29.96
0.00
0.00
0.17
0.00
0.17
$8.03
$0.00
$0.00
60
10.20
$481.80
0.00
0.00
0.00
2.00
0.00
0.00
0.00
0.50
0.00
2.50
$0.00
$215.34
$0.00
$0.00
$0.00
$0.00
39
1
0.00
2.50
$0.00
$215.34
0.00
0.08
0.42
0.17
0.67
$32.94
$0.00
$0.00
40
26.80
$1,317.60
0.00
0.00
0.00
varies
0.17
varies
0.00
varies
0.17
varies
$8.03
varies
$0.00
$0.00
$0.00
$0.00
33
varies
5.61
45.11
$264.99
$2,279.73
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.75
1.50
0.25
0.25
varies
0.00
0.00
0.00
0.25
varies
0.75
1.50
0.25
0.50
varies
$35.41
$70.82
$11.80
$19.29
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$130.00
$0.00
$0.00
varies
6
25
25
25
varies
4.50
37.50
6.25
12.50
60.75
$212.46
$5,020.50
$295.00
$482.25
$6,010.21
Total Hours/ Labor Costs/ Capital Startup
Activity
Activity
Costs/ Activity
O&M Costs/
Activity
Number of
Total Hours/Yea
Activities/ Yea
Total Cost/Year
ENERGY STAR Challenge for Industry
Prepare and submit online Challenge for Industry Registration Form if
necessary
Track energy use - in-house systems
Track energy use - ETT
Prepare and submit online Challenge for Industry Recognition
Application, SEI and PE Verification Checklist
Respond to EPA follow-up questions if any
Subtotal (for ENERGY STAR Challenge for Industry)
Designed to Earn the ENERGY STAR
Review instructions and create an account in Portfolio Manager
Gather building data and estimated energy use data
Enter data into Portfolio Manager
Complete and submit DEES application to EPA
Subtotal (for Designed to Earn the ENERGY STAR)
44
Exhibit 3 (continued)*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Recognition
Hours and Costs Per Respondent per Activity
Legal
Information Collection Activity
ENERGY STAR Awards
Commercial and Industrial Sector Partners
Review the instructions
Complete and submit the information online
Sustained Excellence
Review the instructions
Complete and submit the information online
Subtotal
Service and Product Providers
Review the instructions
Complete and submit the information online
Subtotal
Energy Efficiency Program Sponsors
Review the instructions
Complete and submit the information online
Subtotal
Subtotal (for ENERGY STAR Awards)
Total Hours and Costs
Managerial
Technical
Clerical
$115.16
$100.18
$47.21
$29.96
0.00
0.00
0.50
3.00
0.50
7.00
0.00
3.00
1.00
13.00
$73.70
$720.89
$0.00
$0.00
$0.00
$0.00
36
36
36.00
468.00
$2,653.20
$25,952.04
0.00
0.00
0.00
0.50
2.00
varies
0.50
3.00
varies
0.00
2.00
varies
1.00
7.00
varies
$73.70
$401.91
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
39
39
75
39.00
273.00
816.00
$2,874.30
$15,674.49
$47,154.03
0.00
0.00
0.00
0.50
3.00
3.50
0.50
7.00
7.50
0.00
3.00
3.00
1.00
13.00
14.00
$73.70
$720.89
$794.59
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
15
15
15
15.00
195.00
210.00
$1,105.50
$10,813.35
$11,918.85
0.00
0.00
0.00
0.00
0.50
1.00
1.50
varies
0.50
2.00
2.50
varies
0.00
1.00
1.00
varies
1.00
4.00
5.00
varies
$73.70
$224.56
$298.26
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
15
15
15
105
15.00
60.00
75.00
1,101.00
$1,105.50
$3,368.40
$4,473.90
$63,546.78
45
Total Hours/ Labor Costs/ Capital Startup
Activity
Activity
Costs/ Activity
O&M Costs/
Activity
Number of
Activities/ Yea Total Hours/Yea
Total Cost/Year
Exhibit 3 (continued)*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Recognition
Hours and Costs Per Respondent per Activity
Legal
Total Hours and Costs
Managerial
Technical
Clerical
$115.16
$100.18
$47.21
$29.96
Establish a baseline - Commercial Buildings
0.00
0.00
0.00
0.00
0.00
$0.00
$0.00
$0.00
50
0.00
$0.00
Establish a baseline - Industrial Facilities
0.00
0.00
0.30
0.00
0.30
$14.16
$0.00
$0.00
100
30.00
$1,416.00
Summarize estimates of potential energy and cost savings opportunities
identified during walk-through
0.00
0.00
1.00
0.00
1.00
$47.21
$0.00
$0.00
150
150.00
$7,081.50
Submit information to EPA
Seek additional recognition - Commercial Buildings
0.00
0.00
0.00
0.00
0.00
2.00
0.08
0.00
0.08
2.00
$2.40
$94.42
$0.00
$0.00
$0.00
$0.00
150
50
12.00
100.00
$360.00
$4,721.00
0.00
0.00
0.00
0.00
0.00
0.00
2.30
1.00
varies
0.00
0.00
0.00
2.30
1.00
varies
$108.58
$47.21
varies
$0.00
$0.00
$0.00
$0.00
$0.00
varies
25
10
varies
57.50
10.00
359.50
$2,714.50
$472.10
$16,765.10
Information Collection Activity
Total Hours/ Labor Costs/ Capital Startup
Activity
Activity
Costs/ Activity
O&M Costs/
Activity
Number of
Activities/ Yea Total Hours/Yea
Total Cost/Year
Treasure Hunt, Improvement-Based Recognition
Seek additional recognition - Industrial Facilities
Submit case study or best practices
Subtotal (for Treasure Hunt, Improvement-Based Recognition)
46
Exhibit 3 (continued)*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Recognition
Hours and Costs Per Respondent per Activity
Legal
Information Collection Activity
Tenant Recognition Program
Gather and enter data into Portfolio Manager
Prepare and submit documentation for recognition
Respond to EPA questions, if needed
Subtotal (for Tenant Recognition)
TOTAL
$115.16
0.00
0.00
0.00
0.00
varies
Managerial
Technical
Clerical
$100.18
$47.21
$29.96
0.00
0.00
0.00
0.00
varies
3.00
0.40
0.50
varies
varies
0.00
0.10
0.00
0.00
varies
*Exhibit contains rounding.
47
Total Hours and Costs
Total Hours/ Labor Costs/ Capital Startup
Activity
Activity
Costs/ Activity
3.00
0.50
0.50
varies
varies
$141.63
$21.88
$23.61
varies
varies
$0.00
$0.00
$0.00
$0.00
$0.00
O&M Costs/
Activity
$0.00
$1,060.00
$0.00
varies
varies
Number of
Activities/ Yea Total Hours/Yea
300
200
20
varies
varies
900.00
100.00
10.00
1,010.00
20,290.21
Total Cost/Year
$42,489.00
$216,376.00
$472.20
$259,337.20
$5,882,847.83
Exhibit 4*
Estimated Annual Agency Burden and Cost
ENERGY STAR Program: Joining the ENERGY STAR Program and Related Activities
Agency Hours and Costs Per Activity
Total Hours and Costs
Capital
Startup
Costs/
Activity
Legal
Managerial
Technical
Clerical
$80.59
$75.36
$55.26
$22.19
0.00
0.00
0.50
0.00
0.50
$27.63
$0.00
$0.00
220
110.00
$6,078.60
Follow up with Partners, if needed
Send emails, passwords, and welcome aboard kits
Update and maintain the ENERGY STAR Web site
Subtotal
Additional SPP Related Activities
Request updated contact information annually
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.25
0.08
30.00
varies
0.00
0.00
0.00
0.00
0.25
0.08
30.00
varies
$13.82
$4.42
$1,657.80
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.55
$0.00
varies
25
220
1
varies
6.25
17.60
30.00
163.85
$345.50
$1,093.40
$1,657.80
$9,175.30
0.00
0.00
0.50
$27.63
$0.00
$0.00
1
0.50
$27.63
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.50
Receive and enter updated contact information into database
Receive and process efforts and successes
Receive and process other requested materials
Subtotal
Additional EEPS Related Activities
0.00
0.17
0.00
varies
0.08
0.00
0.20
varies
0.08
0.17
0.20
varies
$1.78
$9.39
$4.44
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
200
125
70
varies
16.00
21.25
14.00
51.75
$356.00
$1,173.75
$310.80
$1,868.18
0.00
0.00
0.00
0.08
0.08
$1.78
$0.00
$0.00
60
4.80
$106.80
0.00
0.00
0.00
0.00
0.00
varies
0.08
varies
0.08
varies
$1.78
varies
$0.00
$0.00
$0.00
varies
60
varies
4.80
220.40
$106.80
$11,150.28
Information Collection Activity
Total Hours/ Labor Costs/
Activity
Activity
O&M Costs Number of Total Hours/Yea
Activity Activities/ Ye
Total Cost/Year
Partnership Agreements and Related Activities
Partnership Agreements
Review the completed Partnership Agreements and related materials
from C&I, SPP and EEPS Partners
Receive annual updates from EEPS and update the Directory of
Energy Efficiency Programs
Subtotal
Subtotal (for Partnership Letter or Agreement/Related Activities)
*Exhibit contains rounding.
`
48
Exhibit 5*
Estimated Annual Agency Burden and Cost
ENERGY STAR Program: Benchmarking
Agency Hours and Costs Per Activity
Legal
Information Collection Activity
Managerial Technical
Clerical
Total Hours/
Activity
Labor Costs/
Activity
Total Hours and Costs
Capital Startup O&M Costs Number of
Costs/ Activity Activity Activities/ Ye Total Hours/Yea
Total Cost/Year
$80.59
$75.36
$55.26
$22.19
0.00
0.00
0.00
200.00
0.00
0.00
850.00
500.00
600.00
200.00
0.00
0.00
1,250.00
500.00
600.00
$66,481.00
$27,630.00
$33,156.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
1
1
1
1,250.00
500.00
600.00
$66,481.00
$27,630.00
$33,156.00
0.00
0.00
0.08
0.00
0.08
$4.42
$0.00
$0.00
14,000
1,120.00
$61,880.00
0.00
varies
varies
varies
varies
varies
$0.00
$0.00
varies
3,470.00
$189,147.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
varies
150.00
3.00
1,250.00
varies
varies
0.00
0.00
0.00
0.00
varies
150.00
3.00
1,250.00
varies
varies
$8,289.00
$165.78
$69,075.00
varies
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
1
100
1
varies
varies
150.00
300.00
1,250.00
1,700.00
5,170.00
$8,289.00
$16,578.00
$69,075.00
$93,942.00
$283,089.00
0.00
0.00
0.00
0.00
0.00
varies
0.17
0.17
varies
0.00
0.00
varies
0.17
0.17
varies
$9.39
$9.39
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
950
950
varies
161.50
161.50
5,331.50
$8,920.50
$8,920.50
$292,009.50
Portfolio Manager
Maintenance and Use of Portfolio Manager
Upgrade Portfolio Manager to enhance functionality
Maintain secure database infrastructure
Perform system maintenance
Collect data submitted through Excel spreadsheet and enter data into
Portfolio Manager
Subtotal
Evaluation of Portfolio Manager
Solicit feedback from respondents
Review answers to questions
Design and develop software changes
Subtotal
Subtotal (for Portfolio Manager)
Data Collection for Model Development and Beta Testing
Conduct the data collections
Subtotal (for Data Collection for Model Development and Beta Testing)
TOTAL
*Exhibit contains rounding.
`
49
Exhibit 6*
Estimated Annual Agency Burden and Cost
ENERGY STAR Program: Recognition
Total Hours and Costs
Agency Hours and Costs Per Activity
Legal
Managerial Technical
Clerical
Capital
Total Hours/ Labor Costs/ Startup Cost O&M Costs Number of
Activity
Activity
Activities/ Yea
Activity
Activity
Total Hours/Year
Total Cost/Year
Information Collection Activity
ENERGY STAR Certification
Buildings
Review of Applications
Review applications and follow up with organizations if questions
Send a letter of denial/acceptance (and certificate and decal if
accepted)
Quality Control Audits of Applications
Collect information from applicants in performing quality control audits
Evaluation of ENERGY STAR Certified Buildings
Solicit feedback from respondents
Review answers to questions
Take follow-up action
Subtotal (for Buildings)
Plants
Enhance functionality of and maintain the EPI and other tools and
information on the Web site
Review and evaluate the submissions
Give permission to display the ENERGY STAR certification logo
Review and post profiles of certified plants on the Web site
Subtotal (for Plants)
Subtotal (for ENERGY STAR Certification)
ENERGY STAR Challenge for Industry
Review online Challenge for Industry Registration Form
Review online Challenge for Industry Recognition Application, SEI
and PE Verification Checklist and provide recognition
Ask follow-up questions if any
$80.59
$75.36
$55.26
$22.19
0.00
0.10
0.25
0.25
0.60
$26.90
$0.00
$0.00
7,000
4,200.00
$188,300.00
0.00
0.00
0.00
0.08
0.08
$1.78
$0.00
$0.55
7,000
560.00
$16,310.00
0.00
0.00
4.00
0.00
4.00
$221.04
$0.00
$0.00
240
960.00
$53,049.60
0.00
0.00
0.00
0.00
0.00
0.00
0.00
varies
0.40
0.25
0.25
varies
0.00
0.00
0.00
varies
0.40
0.25
0.25
varies
$22.10
$13.82
$13.82
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
varies
66
66
66
varies
26.40
16.50
16.50
5,779.40
$1,458.60
$912.12
$912.12
$260,942.44
0.00
0.00
24.00
0.00
24.00
$1,326.24
$0.00
$0.00
1
24.00
$1,326.24
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
0.00
varies
0.67
0.06
0.17
varies
varies
0.00
0.00
0.00
0.00
varies
0.67
0.06
0.17
varies
varies
$37.02
$3.32
$9.39
varies
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.55
$0.00
varies
varies
115
115
4
varies
varies
77.05
6.90
0.68
108.63
5,888.03
$4,257.30
$445.05
$37.56
$6,066.15
$267,008.59
0.00
0.00
0.25
0.00
0.25
$13.82
$0.00
$0.00
60
15.00
$829.20
0.00
0.25
0.75
0.00
1.00
$60.29
$0.00
$0.00
40
40.00
$2,411.60
0.00
0.00
0.17
0.00
0.17
$9.39
$0.00
$0.00
33
5.61
$309.87
Subtotal (for ENERGY STAR Challenge for Industry)
Designed to Earn the ENERGY STAR
Evaluate the DEES applications
Update the ENERGY STAR Web site to reflect the information
collected
Subtotal (for Designed to Earn the ENERGY STAR)
0.00
varies
varies
0.00
varies
varies
$0.00
$0.00
varies
60.61
$3,550.67
0.00
0.00
1.00
0.00
1.00
$55.26
$0.00
$0.00
25
25.00
$1,381.50
0.00
0.00
6.00
0.00
6.00
$331.56
$0.00
$0.00
1
6.00
$331.56
0.00
0.00
varies
0.00
varies
varies
$0.00
$0.00
varies
31.00
$1,713.06
50
Exhibit 6 (continued)*
Estimated Annual Agency Burden and Cost
ENERGY STAR Program: Recognition
Agency Hours and Costs Per Activity
Information Collection Activity
ENERGY STAR Awards
Commercial and Industrial Sector Partners
Develop the awards criteria
Receive and review the information submitted
Take follow-up action (e.g., send letter of award or loss)
Sustained Excellence
Develop the awards criteria
Receive and review the information submitted
Take follow-up action (e.g., send letter of award or loss)
Subtotal
Service and Product Providers
Develop the awards criteria
Receive and review the information submitted
Take follow-up action (e.g., send letter of award or loss)
Subtotal
Energy Efficiency Program Sponsors
Develop the awards criteria
Receive and review the information submitted
Take follow-up action (e.g., send letter of award or loss)
Subtotal
Subtotal (for ENERGY STAR Awards)
Legal
Managerial Technical
Clerical
Total Hours and Costs
Capital
Total Hours/ Labor Costs/ Startup Cost O&M Costs Number of
Activity
Activity
Activity
Activities/ Yea
Activity
Total Hours/Year
Total Cost/Year
$80.59
$75.36
$55.26
$22.19
0.00
0.00
0.00
1.00
2.00
0.08
4.00
3.00
0.00
1.00
1.00
0.08
6.00
6.00
0.16
$318.59
$338.69
$7.80
$0.00
$0.00
$0.00
$0.00
$0.00
$0.55
1
36
36
6.00
216.00
5.76
$318.59
$12,192.84
$300.60
0.00
0.00
0.00
0.00
1.00
1.00
0.08
varies
4.00
2.00
0.00
varies
1.00
0.50
0.08
varies
6.00
3.50
0.16
varies
$318.59
$196.98
$7.80
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.55
varies
1
39
39
varies
6.00
136.50
6.24
376.50
$318.59
$7,682.22
$325.65
$21,138.49
0.00
0.00
0.00
0.00
1.00
2.00
0.08
varies
4.00
3.00
0.00
varies
1.00
1.00
0.08
varies
6.00
6.00
0.16
varies
$318.59
$338.69
$7.80
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.55
varies
1
15
15
varies
6.00
90.00
2.40
98.40
$318.59
$5,080.35
$125.25
$5,524.19
0.00
0.00
0.00
0.00
0.00
0.50
0.50
0.08
varies
varies
1.00
1.00
0.00
varies
varies
0.50
0.50
0.08
varies
varies
2.00
2.00
0.16
varies
varies
$104.04
$104.04
$7.80
varies
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.55
varies
varies
1
15
15
varies
varies
2.00
30.00
2.40
34.40
509.30
$104.04
$1,560.60
$125.25
$1,789.89
$28,452.57
51
Exhibit 6 (continued)*
Estimated Annual Agency Burden and Cost
ENERGY STAR Program: Recognition
Agency Hours and Costs Per Activity
Legal
Information Collection Activity
Treasure Hunt, Improvement-Based Recognition
Receive and review submissions and provide recognition if
warranted
For organizations seeking additional recognition, receive and review
submissions and provide recognition if warranted
Receive and review case study or best practices
Subtotal (for Treasure Hunt, Improvement-Based Recognition)
Managerial Technical
Clerical
Total Hours and Costs
Capital
Total Hours/ Labor Costs/
O&M Costs Number of
Startup Cost
Activity
Activity
Activity
Activities/ Yea
Activity
Total Hours/Year
Total Cost/Year
$80.59
$75.36
$55.26
$22.19
0.00
0.00
0.50
0.00
0.50
$27.63
$0.00
$0.00
150
75.00
$4,144.50
0.00
0.00
0.50
0.00
0.50
$27.63
$0.00
$0.00
75
37.50
$2,072.25
0.00
0.00
0.00
varies
0.50
0.50
0.00
0.00
0.50
0.50
$27.63
varies
$0.00
$0.00
$0.00
$0.00
10
varies
5.00
117.50
$276.30
$6,493.05
52
Exhibit 6 (continued)*
Estimated Annual Agency Burden and Cost
ENERGY STAR Program: Recognition
Agency Hours and Costs Per Activity
Legal
Managerial Technical
Clerical
Information Collection Activity
Tenant Recognition Program
$80.59
$75.36
$55.26
$22.19
Review applications and provide recognition if warranted
Contact participants and ask questions, if needed
Subtotal (for Tenant Recognition)
TOTAL
0.00
0.00
0.00
0.00
0.00
0.00
0.00
varies
0.50
0.50
varies
varies
0.00
0.00
0.00
varies
* Exhibit contains rounding.
53
Total Hours and Costs
Capital
Total Hours/ Labor Costs/ Startup Cost O&M Costs Number of
Activity
Activity
Activity
Activities/ Yea
Activity
0.50
0.50
varies
varies
$27.63
$27.63
varies
varies
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
$0.00
200
20
varies
varies
Total Hours/Year
100.00
10.00
110.00
6,716.44
Total Cost/Year
$5,526.00
$552.60
$6,078.60
$313,296.54
6(e)
Bottom Line Burden Hours and Cost Tables
(i)
Respondent Tally
As shown in Table 1, EPA estimates the total annual hour and cost burden to respondents
to be 210,306 hours and $14,859,991. The burden to respondents over the three years of this ICR
is estimated to be 630,918 hours and $44,579,973.
TABLE 1
TOTAL ESTIMATED ANNUAL RESPONDENT BURDEN AND COST SUMMARY1
Information Collections
Total
Hours Per
Year
Total
Labor Cost
Per Year
Total
Annual
Capital
Costs
Total
Annual
O&M
Costs
Total Cost
Per Year
Joining the ENERGY STAR
Program and Related
Activities
478
$29,795
$0
$0
$29,795
Benchmarking
189,538
$8,947,348
$0
$0
$8,947,348
Recognition
20,290
$848,398
$0
$5,034,450
$5,882,848
TOTAL
210,306
$9,825,541
$0
$5,034,450
$14,859,991
Table contains rounding.
1
(ii)
Agency Tally
As shown in Table 2, EPA estimates the total annual hour and cost burden to the Agency
to be 12,269 hours and $616,456. The bottom-line burden to the Agency over the three years of
this ICR is estimated to be 36,807 hours and $1,849,368.
TABLE 2
TOTAL ESTIMATED ANNUAL AGENCY BURDEN AND COST SUMMARY1
Information Collections
Total
Hours Per
Year
Total
Labor Cost
Per Year
Total
Annual
Capital
Costs
Total
Annual
O&M
Costs
Total Cost
Per Year
Joining the ENERGY STAR
Program and Related
Activities
Benchmarking
220
$11,029
$0
$121
$11,150
5,332
$292,010
$0
$0
$292,010
Recognition
6,716
$309,326
$0
$3,971
$313,297
TOTAL
12,269
$612,365
$0
$4,092
$616,456
Table includes rounding.
1
54
6(f)
Reasons for Change in Burden
EPA estimates a total annual respondent burden in this ICR, 1772.08, of 210,306 hours.
This is a decrease of 43,778 hours from the currently approved burden of 254,084 hours in ICR
1772.07.
Table 3 explains this decrease. Specifically, the table presents the total annual hours
estimated in ICR 1772.07 and ICR 1772.08 for each information collection (see columns 1-3).
The table then compares their respective hours for each collection to derive the change in hours,
and indicates whether this hour-change resulted from a program change and/or adjustment (see
column 4). The table also briefly describes the program change and/or adjustment (see column
5). Finally, the table sums up all hour-changes to derive the total annual change in hours for all
collections (see the bottom row of the table).
The table shows that there was a 7,656-hour decrease due to program changes and a
36,122-hour decrease due to adjustments. This resulted in a total decrease of 43,778 hours in ICR
1772.08.
Program Changes
The decrease due to program changes resulted primarily from clarifications and
enhancements to EPA’s recognition programs. For example, in 2018, EPA issued clarification
under the ENERGY STAR certification program concerning facility data reviews performed by
licensed professionals (LPs). EPA clarified that on-site facility visits for data reviews and Indoor
Air Quality Measurements can be performed every other year instead of annually for buildings
that apply for certification in consecutive years, although the data review itself is still conducted
every year. This has reduced the estimated number of LP on-site visits conducted annually. This
flexibility regarding the on-site requirement substantially reduces costs as well.
Under the Challenge for Industry, EPA introduced a streamlined registration process for
organizations that achieved recognition in the past and want to re-register. They no longer need
to complete the online Challenge for Industry Registration Form. Under the ENERGY STAR
Awards program, EPA introduced a new Sustained Excellence Award, which requests less
information from eligible C&I Partners. EPA also phased out the National Building Competition
and Small Business Network.
Adjustments
The decrease due to adjustments resulted primarily from updates and improvements to
EPA’s analysis of Portfolio Manager and the ENERGY STAR certification program. Portfolio
Manager is EPA’s voluntary online tool for energy management. Based on its data analysis, EPA
estimates that 299,000 buildings will be benchmarked annually in this ICR, whereas it estimated
246,000 in ICR 1772.07.
55
In addition, EPA updated its analysis to account for changes in user benchmarking
practices and methods. Portfolio Manager data indicate an increasing percentage of users are
opting for Web Services over other benchmarking methods. Whereas EPA estimated 59% of
buildings would be benchmarked using Web Services in ICR 1772.07, it estimates 73% in this
ICR. 19 Web Services offers greater economies of scale and time-savings efficiencies than the
other methods. For example, it takes almost five hours to perform a new benchmark using
manual data entry, whereas about one hour using Web Services.
Portfolio Manager data also indicate that the percentage of repeat benchmarks performed
in the tool has increased over new benchmarks. Whereas EPA estimated that 70% of buildings
benchmarked are repeats in ICR 1772.07, it estimates 83% in this ICR. Repeat benchmarks take
significantly less time than new ones, regardless of the method used. Under Web Services, for
example, it takes about one hour to perform a new benchmark, whereas about six minutes for a
repeat benchmark.
In summary, Portfolio Manager data indicate that users are spending less time per
building benchmarked, on average, than in the past. EPA reflected these data in ICR 1772.08,
which resulted in a decrease in total burden. 20
Under the ENERGY STAR certification program, EPA adjusted the annual number of
applications because of recent changes to Portfolio Manager. In 2018, EPA updated the tool’s
performance metrics for buildings based on the most recent market data available. 21 These
changes have decreased the number of properties eligible for certification. In addition, EPA
conducted limited industry consultations in preparing this ICR and improved its estimates of the
burden and cost for LPs to perform facility reviews. The estimates in ICR 1772.08 reflect current
industry burdens and practices. Refer to Section 6(d) for additional information on LP costs for
ENERGY STAR certifications.
As discussed in Section 1b of this document, this trend has been continuing for many years.
EPA performed limited industry consultations in preparing this ICR and verified the accuracy of its burden
estimates for the tool.
21
The update was part of EPA’s standard process to keep ENERGY STAR metrics as current as possible, and
reflective of current market performance.
56
19
20
TABLE 3
1
COMPARISON OF TOTAL ANNUAL HOURS UNDER ICR 1772.07 AND ICR 1772.08
2
(1) Information Collections
(2) Annual Hour
Burden in ICR
1772.07
(4) Difference in Hour Burden Between ICR
1772.07 and 1772.08
(3) Annual Hour
Burden in ICR
1772.08
Program Change
Adjustment
Total
Joining the ENERGY STAR Program and Related Activities
(5) Description of Adjustment and/or Program Change
Commercial and Industrial Sector
Partners
106.25
106.25
0.00
0.00
0.00
Based on current data, EPA estimates the annual number of respondents and burden per activity to
remain steady over the next 3 years.
Service and Product Providers
231.90
231.90
0.00
0.00
0.00
Based on current data, EPA estimates the annual number of respondents and burden per activity to
remain steady over the next 3 years.
Energy Efficiency Program Sponsors
Small Business Network3
Benchmarking
Portfolio Manager
ENERGY STAR Energy Performance
Indicator and Related Systems4
Data Collection for Model Development
and Beta Testing
155.04
139.80
0.00
(15.24)
(15.24)
Based on current data, EPA estimates the annual number of respondents and burden per activity to
remain steady over the next 3 years. In addition, EPA transferred EEPS Partnership Agreement
burden from this ICR to the ICR, “EPA’s ENERGY STAR® Product Labeling,” (EPA ICR No. 2078,
OMB Control Number 2060-0528), which is currently being renewed. The Product Labeling ICR will
consolidate the burden for EEPS Partnership Agreements across all ENERGY STAR programs. As
revised, ICR 1772.08 estimates EEPS burden only for activities performed after joining the program
(e.g., supplying updated contact information to EPA).
36.00
0.00
(36.00)
0.00
(36.00)
The Small Business Network has been phased out and removed from this ICR.
Based on its analysis of historical data and trends, EPA increased the total annual number of
buildings benchmarked in Portfolio Manager from 246,000 buildings in ICR 1772.07 to 299,000
buildings in ICR 1772.08. In addition, EPA updated its analysis to account for changes in user
benchmarking practices and methods. Portfolio Manager data indicate an increasing percentage of
users are opting for Web Services over other benchmarking methods. Whereas EPA estimated 59%
of buildings would be benchmarked using Web Services in ICR 1772.07, it estimates 73% in this
(32,340.00) ICR. Web Services offers greater economies of scale and time-savings efficiencies than the other
methods. Portfolio Manager data also indicate that the percentage of repeat benchmarks performed
in the tool has increased over new benchmarks. Whereas EPA estimated that 70% of buildings
benchmarked are repeats in ICR 1772.07, it estimates 83% in this ICR. Repeat benchmarks take
significantly less time than new ones, regardless of the method used. In summary, Portfolio Manager
data indicate that users are spending less time per building benchmarked, on average, than in the
past. EPA reflected these data in ICR 1772.08, which resulted in a decrease in total burden.
219,741.00
187,401.00
0.00
(32,340.00)
64.30
0.00
0.00
(64.30)
(64.30)
2,137.50
2,137.50
0.00
0.00
0.00
57
In preparing ICR 1772.08, EPA reorganized its analysis of the Energy Performance Indicator and
related systems by moving it from the "Benchmarking" section to the "Recognition" section under
"ENERGY STAR Certification" and " ENERGY STAR Challenge for Industry."
Based on current data, EPA estimates the annual number of respondents and burden per activity to
remain steady over the next 3 years.
TABLE 3 (continued)
COMPARISON OF TOTAL ANNUAL HOURS UNDER ICR 1772.07 AND ICR 1772.081
2
(1) Information Collections
(2) Annual Hour
Burden in ICR
1772.07
(3) Annual Hour
Burden in ICR
1772.08
Recognition
ENERGY STAR Certification
29,409.15
ENERGY STAR Challenge for Industry
and Related Activities5
Designed to Earn the Energy Star
ENERGY STAR Awards
6
National Building Competition
Treasure Hunt, Improvement-Based
Recognition7
Tenant Recognition Program
17,713.85
2
Program Change
(7,264.00)
Adjustment
(4,431.00)
(5) Description of Adjustment and/or Program Change
Total
EPA adjusted the annual number of ENERGY STAR applications in ICR 1772.08 because of recent
changes to Portfolio Manager (i.e., recalibrated metrics), which have decreased the number of
properties eligible for certification. EPA also conducted limited industry consultations and improved
its estimates of the burden for LPs to perform facility reviews. The estimates in ICR 1772.08 reflect
(11,695.00)
current industry burdens and practices. In addition, EPA revised this analysis by moving portions of
the Energy Performance Indicator burden related to plant certifications from the "Benchmarking"
section to this analysis. Finally, ICR 1772.08 reflects recent program clarifications and
improvements, which have simplified the application process.
60.25
45.11
(14.39)
(0.75)
(15.14)
EPA adjusted the number of respondents based on updated data. The burden estimates in ICR
1772.08 reflect EPA's program experience gained over the past three years. In addition, EPA
revised this analysis by moving portions of the Energy Performance Indicator burden related to the
Challenge for Industry from the "Benchmarking" section to this analysis. Finally, EPA introduced a
streamlined registration process for organizations that have achieved recognition in the past and
want to re-register. They no longer need to complete the online Challenge for Industry Registration
Form.
280.00
60.75
(43.75)
(175.50)
(219.25)
EPA adjusted the number of respondents per activity based on updated data. The burden estimates
in ICR 1772.08 reflect EPA's program experience gained over the past three years. In addition, EPA
simplified some application components (e.g., merged some forms) and no longer collects Design
Profiles.
1,335.00
1,101.00
(234.00)
0.00
(234.00)
Based on current data, EPA estimates the annual number of respondents to remain steady over the
next 3 years. In addition, EPA has introduced a new Sustained Excellence Award, which requests
less information from eligible C&I Partners.
422.78
0.00
(422.78)
0.00
(422.78)
The National Building Competition has been phased out and removed from this ICR.
0.00
359.50
359.50
0.00
359.50
The Treasure Hunt, Improvement-Based Recognition is a new program.
105.00
1,010.00
0.00
905.00
905.00
EPA adjusted the number of respondents and hours per activity based on the pilot phase, which
enhanced the Agency’s understanding of market-wide participation and burdens.
(7,656.00)
(36,122.00)
(43,778.00)
Total (rounded)
1
(4) Difference in Hour Burden Between ICR
1772.07 and 1772.08
254,084.00
210,306.00
Table includes minor rounding. Decreases in burden are shown in parentheses.
This column reflects the collections in ICR 1772.07, except as otherwise noted.
This collection has been phased out and is not included in ICR 1772.08.
In preparing ICR 1772.08, EPA reorganized its analysis of the Energy Performance Indicator and related systems by moving it from the "Benchmarking" section to the “Recognition” section under "ENERGY STAR Certification" and
"ENERGY STAR Challenge for Industry.”
3
4
5
This collection is called "ENERGY STAR Challenge for Industry" in ICR 1772.08.
This collection has been phased out and is not included in ICR 1772.08.
7
This is a new collection in ICR 1772.08.
6
58
6(g)
Burden Statement
The public reporting and recordkeeping burden for this collection of information is
estimated to average 38 minutes per response.
Burden means the total time, effort, or financial resources expended by persons to
generate, maintain, retain, or disclose or provide information to or for a federal agency. This
includes the time needed to review instructions; develop, acquire, install, and utilize technology
and systems for the purposes of collecting, validating, and verifying information, processing and
maintaining information, and disclosing and providing information; adjust the existing ways to
comply with any previously applicable instructions and requirements; train personnel to be able
to respond to a collection of information; search data sources; complete and review the collection
of information; and transmit or otherwise disclose the information. An agency may not conduct
or sponsor, and a person is not required to respond to, a collection of information unless it
displays a currently valid OMB control number. The OMB control numbers for EPA's
regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.
To comment on the Agency’s need for this information, the accuracy of the provided
burden estimates, and any suggested methods for minimizing respondent burden, including the
use of automated collection techniques, EPA has established a public docket for this ICR under
Docket ID Number EPA-HQ-OAR-2006-0407, which is available for online viewing at
www.regulations.gov, or in person viewing at the Air and Radiation Docket in the EPA Docket
Center (EPA/DC), WJC West Building, Room 3334, 1301 Constitution Avenue, NW,
Washington, D.C. The EPA Docket Center Public Reading Room is open from 8:00 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 Air and Radiation Docket is
202-566-1742. An electronic version of the public docket is available at www.regulations.gov.
This site can be used to submit or view public comments, access the index listing of the contents
of the public docket, and to access those documents in the public docket that are available
electronically. When in the system, select “search,” then key in the Docket ID Number identified
above. Also, you can send comments to the Office of Information and Regulatory Affairs, Office
of Management and Budget, 725 17th Street, NW, Washington, D.C. 20503, Attention: Desk
Officer for EPA. Please include the EPA Docket ID Number EPA-HQ-OAR-2006-0407 in any
correspondence.
59
| File Type | application/pdf |
| Author | Purdy, Mark |
| File Modified | 2021-01-06 |
| File Created | 2021-01-06 |