SUPPORTING STATEMENT FOR

                INFORMATION COLLECTION REQUEST NUMBER 2050-0139

              "REPORTING AND RECORD KEEPING REQUIREMENTS UNDER

                         EPA'S WASTEWISE PROGRAM"

                                 June 3, 2011

                               TABLE OF CONTENTS

1.	IDENTIFICATION OF THE INFORMATION COLLECTION REQUEST
      1(a)	Title and Number of the Information Collection Request	4
      1(b)	Short Characterization	4
      1(c)	Existing Terms of Clearance								7
	1(d)	EPA Actions to Comply with Terms of Clearance	8
	(i)	WasteWise Program Evaluation	8
	(ii)	Discussion Paper on Attribution	8
	(iii)	Response rates and descriptive statistics	9

2.	NEED FOR AND USE OF THE COLLECTION
      2(a)	Need and Authority for the Collection	9
      2(b)	Practical Utility/Users of the Data	10

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA
      3(a)	Non-duplication	11
      3(b)	Public Notice Required Prior to ICR Submission to OMB	11
      3(c)	Consultations	11
      3(d)	Effects of Less Frequent Collection	12
      3(e)	General Guidelines	12
      3(f)	Confidentiality	12
      3(g)	Sensitive Questions	12

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED
      4(a)	Respondents and NAICS Codes	13
      4(b)	Information Requested	13
	(i) 	Partner Registration Form	13
	(ii)	Partner Annual Assessment Form	14
	(iii)	Endorser Registration Form	14
            (iv)	Endorser Annual Assessment Form	15
            (v)	New Contact Form	16

5.	THE INFORMATION COLLECTED  --  AGENCY ACTIVITIES, COLLECTION METHODOLOGY, AND INFORMATION MANAGEMENT
      5(a)	Agency Activities	17
	(i) 	Partner Registration Form	17
	(ii)	Partner Annual Assessment Form	17
	(iii)	Endorser Registration Form	18
            (iv)	Endorser Annual Assessment Form	18
            (v)	New Contact Form	19
      5(b)	Collection Methodology and Management	19
      5(c)	Small Entity Flexibility	19
      5(d)	Collection Schedule	20

6.	ESTIMATING THE BURDEN AND COST OF COLLECTION
      6(a)	Estimating Respondent Burden	20
      6(b)	Estimating Respondent Costs	21
      6(c)	Estimating Agency Burden and Costs	26
      6(d)	Estimating the Respondent Universe and Total Burden and Costs	28
      6(e)	Bottom Line Burden Hours and Costs	28
      6(f)	Reasons for Change in Burden	29
      6(g)	Burden Statement	29

7.	POTENTIAL FUTURE WASTEWISE INITIATIVES
	7(a)	WasteWise Challenges  -  Targeting Selective Materials	30
	7(b)	Requirements for Organizations Participating in Challenges	31
      7(c)	Estimating Burden and Costs for Organizations Participating in Challenges 	31
      7(d)	Estimating Agency Burden and Costs for Challenges 	33

                                    TABLES

Table 1:
WasteWise Membership
                                                                             21
Table 2:
Hourly Labor Rates  -  Private Sector
                                                                             21
Table 3:
Local, State and Federal Labor Rates
                                                                             22
Table 4:
Annual Estimated Respondent Burden and Cost  -  Private Sector Respondents
                                                                             23
Table 5:
Annual Estimated Respondent Burden and Cost  -  State/Local Respondents
                                                                             24
Table 6:
Annual Estimated Respondent Burden and Cost  -  Federal Respondents
                                                                             25
Table 7:
Agency Labor Rates
                                                                             26
Table 8:
Annual Estimated Agency Burden and Cost
                                                                             27
Table 9:
Bottom Line Burden and Cost to Respondents
                                                                             28
Table 10:
Bottom Line Burden and Cost to EPA
                                                                             29
Table 11:
Annual Estimated Burden for Challenge Respondents for a Single Challenge
                                                                             32
Table 12:
Annual Estimated Agency Burden and Cost for a Single Challenge
                                                                             33

                                  ATTACHMENTS

Attachment A: 	ICR Renewal Terms and Clearance. Office of Management and Budget, Control Number 2050-0139, June 24, 2008.
Attachment B: 	Evaluation of the WasteWise Program: Promoting Environmental Results through Evaluation. EPA Office of Policy, Economics, and Innovation, July 2010.
Attachment C: 	Attributing Benefits to Voluntary Programs in EPA's Office of Resource Conservation and Recovery: Challenges and Options. James Boyd and Cynthia Manson, Resources for the Future, March 2011.
Attachment D:  Response Rates and Descriptive Statistics for WasteWise Program
Attachment E: 	Partner Registration Form
Attachment: F-J	Partner Annual Assessment Form
                  * Attachment F:  Waste Prevention and Recycling
                  * Attachment G:  Municipal Solid Waste Disposed Data
                  * Attachment H:  Buy-Manufactured Recycled Products
                  * Attachment I:  Cost Savings-Revenue
                  * Attachment J:  Comments
Attachment K: 	New Contact Form
Attachment L: 	Endorser Registration Form
Attachment M:  Endorser Annual Assessment Form
Attachment N: 	Sample WasteWise Challenge Registration Forms
Attachment O:	Partnership Agreement Form
Attachment P:	Endorser Agreement Form

1.	IDENTIFICATION OF THE INFORMATION COLLECTION

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

            This Information Collection Request (ICR) is entitled "EPA's WasteWise Program," EPA ICR No. 1698.09, OMB Control No. 2050-0139.

      1(b)	Short Characterization

            This submission is intended to request renewal of an ICR for EPA's WasteWise Program, as described in this document. EPA's existing ICR was approved in 2008, with Terms of Clearance, for a three year period. The existing ICR expires on June 30, 2011. EPA's efforts to comply with the Terms of Clearance are discussed below.

            Overview

            The WasteWise program is an EPA partnership program that encourages companies, non-profit organizations, state/local/tribal/federal governments, schools, colleges, and universities to engage in waste reduction activities. WasteWise activities focus on waste prevention, recycling collection, and purchasing or manufacturing recycled-content products. The program was developed and is managed by EPA's Office of Resource Conservation and Recovery (ORCR), Resource Conservation and Sustainability Division (RCSD).

            WasteWise began in 1994 and since then has helped more than 3,000 organizations, including small, medium, and large businesses; local, state, and federal governments; and other public and private sector organizations plan, develop, and implement cutting-edge waste reduction programs and measure their results.  It was one of the first programs developed to specifically focus on waste prevention and recycling as a way to bring about waste reduction and provide environmental benefits, while at the same time reducing overall costs.  The program provides one-on-one technical assistance, tools, and resources to assist member organizations in designing waste reduction programs that are flexible, yet tailored to their individual needs.  WasteWise offers a program-specific on-line web-based data management and reporting system to track and report partner progress in the program.  It also uses EPA's Waste Reduction Model (WaRM) to quantify the environmental benefits of partner actions in the program.  Mentoring opportunities are also available to allow like-sector organizations the benefit of implementing waste reduction program elements that are proven to work.

            The WasteWise program is viewed nationally, as well as internationally, as a model program to help organizations bring about waste reduction in a cost-effective manner.  Many states promote the use of WasteWise to help organizations in their state achieve greater waste reduction.  Over the years, several international government agencies have consulted with EPA and tailored their national partnership programs after the WasteWise model.  It has become apparent over the years that the WasteWise program provides a cadre of resources and technical assistance that are unique in promoting waste reduction and obtaining measurable results.

            In return for their participation in the program, active WasteWise Partners and Endorsers receive:

            * A well-developed approach to program design, implementation, and documentation of results that can be implemented within a variety of organizations;
            * Recognition opportunities through annual awards and being featured on the WasteWise Web site and other WasteWise publications;
            * Opportunities to network with individuals implementing waste reduction activities in a variety of industry sectors;
            * Access to an online data management and reporting system to facilitate internal tracking and allow for better waste management;
            * Helpline, program representative, and list server services that assist with the identification of waste reduction opportunities, setting measurable goals, and researching technical questions;
            * Access to a library and Web site of technical assistance resources to assist in achieving waste reduction goals; and
            * A climate benefits profile which provides a summary of the amount of equivalent greenhouse gas (ghg) reductions that results from a partner's waste prevention and recycling efforts.

            During 2011, EPA transitioned its municipal solid waste management focus to promote sustainable materials management (SMM).  SMM is a life-cycle approach to resource conservation and waste prevention and management. Its purpose is to eliminate waste throughout the life of materials use  -  from extraction through intended use, ultimately reducing the amount of materials used; wastes generated; and associated environmental impacts.  EPA plans to target specific waste streams and sectors in transitioning to its SMM focus and the WasteWise tools; technical assistance; and data management and reporting system will be an integral part of this overall effort.  Data collected as part of the SMM initiatives will be obtained through the existing WasteWise data management system.  Data collection forms will be provided to OMB for approval and will include cost burden estimates.  Section 7 of this ICR provides more details of how EPA plans to use key WasteWise program elements as a tool for promoting SMM.

            WasteWise Partners

            Partner participation begins when an organization submits an online Partner Registration Form (Attachment E) that provides general information.  Partners submit a Partnership Agreement Form committing them to identify specific goals, make continuous improvements, and report data in order to remain an active Partner in the program (Attachment O).  Organizations that fulfill their partnership commitments are considered active partners and receive benefits including access to the online data management system, name in the Partner listing on the WasteWise Web site, and ability to use the WasteWise logo. Organizations that do not meet their commitments have their access to the online data management system revoked, name removed from the Partner listing on the WasteWise Web site, and are not allowed to use the WasteWise logo.

            Partners can establish reporting protocols as a single entity or include multiple reporting sites within their organization.  Partners are allowed up to two months to provide baseline data and self-identified goals in the areas of waste prevention; recycling; buy-recycled and/or manufacturing products with recycled content via the Partner Annual Assessment Form (Attachments F-J). Partners can add additional users to their online account by submitting a New Contact Form (Attachment K).  The first year of membership is the only time during which partners are asked to submit baseline data. Partners use the same annual assessment form to submit annual data for every year that they are active in the WasteWise Program. By comparing the baseline data to subsequent annual data, EPA is able to determine a partner's waste reduction achievements over time.

            The WasteWise program currently has 568 active partners (as of April 1, 2011). EPA expects WasteWise membership to increase by 76 active partners during each year of this ICR. While there is no cost to join as a WasteWise Partner, the information collection activities are estimated on average to cost each partner organization approximately $2,706 the first year they are in the program and $2,631 each subsequent year. However, EPA also expects that for many of the organizations, these costs will be off-set to realize substantial cost savings through implementation of their waste reduction initiatives reported under WasteWise. In fact, information provided to the Agency shows that savings of hundreds of thousands, or even millions, of dollars is common for a large corporation, while even for small companies, significant savings can be realized.

            WasteWise Endorsers

            WasteWise also includes another component called the WasteWise Endorser Program. Various organizations, including non-profit organizations, and federal, state, and local governments, become WasteWise Endorsers and commit to recruiting their members and other constituents to become WasteWise Partners. Many WasteWise Endorsers go on to provide ongoing promotional and/or technical waste reduction information.

            Joining the WasteWise Endorser Program involves submitting the online Endorser Registration Form (Attachment L), which provides general contact information, the number of business members the organization has, the primary business sectors represented, and the activities that the endorser will conduct. This form and all information submitted are housed in Re-TRAC (see below).  Endorsers can add additional users to their online account by submitting a New Contact Form (Attachment K).  A a new requirement for the Endorser Program starting in 2011, will be for Endorsers to submit an Endorser Agreement Form (Attachment P) which commits them to identify specific goals and actions they plan to take in the following year.  WasteWise will also require Endorsers to submit an Endorser Annual Assessment Form (Attachment M) by March 31 each year, reporting their promotional, outreach, and other endorser-related efforts (first submissions will be March 31, 2012). Organizations that fulfill their Endorser commitments are considered active Endorsers and receive benefits including access to the online data management system, name in the Endorser listing on the WasteWise Web site, and ability to use the WasteWise logo. Organizations that do not meet their commitments have their access to the online data management system revoked, name removed from the Endorser listing on the WasteWise Web site, and are not allowed to use the WasteWise logo.

            EPA will track the information from the Endorser forms to establish participation in the program, understand the activities being undertaken by each endorser, and identify opportunities to assist them in their efforts (e.g., providing materials and/or a speaker). Some WasteWise Partners may also choose to enroll in the program as Endorsers.  In these instances, the organization must submit separate registration forms, agreement forms, and all related reporting forms required for both Partners and Endorsers.

            The WasteWise Endorser Program currently has 86 active endorsers (as of April 1, 2011). EPA expects membership in the WasteWise Endorser Program to increase by 11 active endorsers during each year of this ICR. While there is no cost to join as a WasteWise Endorser, the information collection activities are estimated on average to cost each endorser organization approximately $593 in their first year in the program and $375 each subsequent year. While Endorsers are unlikely to realize cost savings from their WasteWise activities, Partners that join the program as a result of WasteWise Endorser activities are expected to realize substantial cost savings.

            The WasteWise Program also allows Endorsers who have members to create a WasteWise Affiliate Network. Through the affiliate network, Endorsers can use WasteWise to track their members' progress in their organization's waste reduction initiatives. Affiliate organizations' members join WasteWise as Partners and the Endorser is then given access to the member organizations reported data. This allows the Endorser to better organize its members' waste reductions efforts.

            WasteWise Re-TRAC

            In 2008, EPA began developing a customized portal in Re-TRAC, an existing waste management database, for the WasteWise program after identifying a need to streamline data collection, efficiently report on the program, and provide additional support for the  Waste Wise Partners. The system has been completed and since 2010, EPA has collected and stored WasteWise Partner and Endorser information in the online data management and reporting system.  EPA uses the information collected under the WasteWise program to track the activities of individual organizations participating in the program, recognize partner accomplishments, and identify effective waste reduction strategies to share with the other organizations. Approved paper information collection forms were translated into a user-friendly online format. For example, the online system walks WasteWise  Partners through the Partner Annual Assessment Form page-by-page until all of the data is entered. Also, users are able to select from convenient drop-down menus that are populated with the most commonly observed data and "other" options as needed (e.g. most commonly recycled materials). Users can access Re-TRAC at no charge at their convenience, save information and return to it later, and add additional contacts using the New Contact Form.

            In addition to collecting information from WasteWise Partners and Endorsers, Re-TRAC also provides members with internal tracking and customized reporting functions. EPA headquarters and regional offices have various reporting functions as well for improved program management.

      1(c)	Existing Terms of Clearance

            EPA received ICR renewal approval for the WasteWise Program on June 24, 2008 (ICR reference Number 2007007-2050-001). This approval expires on June 30, 2011. A copy of this approval is included as Attachment A. Under the ICR's Terms of Clearance, EPA was required to evaluate the Program and develop a statistical methodology that could quantify the Program's impact on partner behavior using randomized control trials (RCTs), subject the methodology to peer review, incorporate peer review comments, and include the methodology with this ICR renewal. Specifically the Terms required the methodology to address the following issues: appropriate baseline; appropriate entity boundaries for reporting; conditions for self-selection bias; and low response rates from the partners and low item response rates from the partners.  EPA was also asked to provide the following information: overall response rates from the participants; item non-response rates for each question in Section II of the approved Registration Form and Sections II through IV in the approved Assessment Form; descriptive statistics (including, but not limited to, mean, median, and mode) of the responses for each question in Section II of the approved Registration Form and Sections II through IV in the approved Assessment Form.

      1(d)	EPA Actions to Comply with Terms of Clearance

            After the 2008 ICR approval, EPA conducted two research projects in an effort to evaluate the use of RCTs and other econometric approaches for the WasteWise Program. The results of these efforts are discussed below.

            (i) WasteWise Program Evaluation

            EPA's Office of Policy (OP) and the Office of Resource Conservation and Recovery (ORCR) commissioned a study of the WasteWise Program under OP's Program Evaluation Competition. The findings were published in July of 2010. The evaluation examined the WasteWise Program in the context of OMB's Terms of Clearance requiring the development and submission of a peer-reviewed econometric-based methodology for assessing the Program's impact on partner behavior. In general, the Evaluation found that RCTs and other econometric approaches are unlikely to be either practical or robust for partnership programs, due to data limitations and the complexity of the program interventions that make it difficult to isolate a control group. Specifically, the Program Evaluation found that:

               * RCTs and other statistical methodologies that compare participants to non-participants do not appear to be feasible or theoretically valid approaches for estimating the benefits of partnership programs. These methods are problematic due to the extensive resources required and confounding impact of program designs that emphasize dissemination of information to non-participants;
               * The literature suggests that links exist between certain external factors and the decision by firms to enter partnerships programs, but the specific impact of these factors is difficult to predict. Input from partners in literature reviews, evaluations, and case studies suggest that partnership programs may in some cases be complementary with existing strategies. In these cases, the programs may not be the root cause of new behaviors in organizations, but may help advance or broaden the adoption of new behaviors in non-linear ways. This further complicates efforts to isolate `program" impacts, even when it appears that program participation has provided significant value; and
               * Limited available data and the limited applicability of RCT methods suggest that robust trend analysis considering behavioral changes over time among participants may be the most tractable methods for estimating program impacts.

            The full results of this evaluation are included as Attachment B.

            (ii) Discussion Paper on Attribution

            EPA obtained the services of Resources for the Future (RFF) to analyze the challenges and options of attributing benefits to partnership programs. The result of that effort was a discussion paper entitled, Attributing Benefits to Voluntary Program's in EPA's Office of Resource Conservation and Recovery (March 2011).

            Like the WasteWise Program Evaluation, the RFF study concluded that specific features of partnership programs make it difficult, and often impractical, to use full scale statistical analysis (like RCTs) to assess the direct influence of programs on partner behavior. Specifically, the paper identifies the following obstacles as reasons why quantifying direct causality can be difficult:  sample bias; breadth of confounding factors; non-uniform interventions and outcomes; ambiguous intervention events; and spillover effects.

            The discussion paper and all results are included as Attachment C.

            (iii) Response Rates and Descriptive Statistics

            The 2008 Terms of Clearance also required EPA to submit various response rate statistics for the three year duration of the ICR. Specifically, the Terms of Clearance requested:
                *                    Overall response rate from WasteWise participants;
                *                    Non-response rates for specific questions in the Registration and Annual Assessment forms; and
                *                    Descriptive statistics (including, but not limited to mean, median, and mode) of the responses to specific questions in the Registration and Annual Assessment Forms.

            EPA has compiled and evaluated all partner reporting activities and reported data from 2008 through 2010.  EPA has included this statistical information in Attachment D.

2.	NEED FOR AND USE OF THE COLLECTION

      2(a)	Need and Authority for the Collection

            As stated by Congress (42 U.S.C. #13101-13103. 1990) and EPA (The Solid Waste Dilemma:  An Agenda for Action. 1989 530-SW-89-019. pp. 16-21), there are significant opportunities for businesses to reduce or prevent pollution at the source through cost-effective changes in production, operation, and raw material use. The Agency has developed a hierarchy asserting that waste should be prevented or reduced at the source whenever feasible and waste that cannot be prevented should be recycled where possible. The Resource Conservation and Recovery Act (RCRA) directs EPA to "...promote the protection of human health and the environment and to conserve valuable materials and energy resources ..."(42 section 6902(a)) and "...promote the demonstration, construction, and application of solid waste management, resource recovery, and resource conservation systems which preserve and enhance the quality of air, water, and land resources ..."(42 section 6902(a)(10)). In addition, "The Congress finds that (1) significant savings could be realized by conserving materials in order to reduce the volume or quantity of material which ultimately becomes wastes: (2) solid waste contains valuable energy and material resources which can be recovered and used thereby conserving increasingly scarce and expensive fossil fuels and virgin materials;..."(Section 4001(a)). The WasteWise program and associated information collection activities will assist EPA in meeting the aforementioned objectives of RCRA by facilitating the prevention and recycling of wastes by participating organizations.

            EPA collects initial information in the Partner Registration Form to formally establish participation in the WasteWise program.  Partners also submit a Partner Agreement Form committing to take certain actions to remain in the program.  These forms obtain general information on new WasteWise partners; identify the facilities committed to implementing the WasteWise initiatives relating to waste prevention, recycling, and buy/manufacture recycled-content products; and gain insight on new partners' areas of interests/priorities.

            EPA also needs to collect annual information in the Partner Annual Assessment Form to better understand and assist each partner's waste reduction efforts and progress and to identify effective waste reduction strategies to share with others. Furthermore, as mentioned earlier, by compiling partners' baseline waste reduction data, WasteWise will be able to more accurately determine the progress made by its partners in their waste reduction efforts.

            The New Contact Form is used by a Partner or Endorser when granting a new user (within their organization) access to the online data management and reporting system.

            For the WasteWise Endorser Program, EPA needs to collect initial information in the Endorser Registration Form to establish participation in the Endorser Program and to obtain general contact and membership information, as applicable. EPA also plans to collect information in the Endorser Annual Assessment Form on recruitment and ongoing activities to remain apprised of Endorser activities that bring new partners into the WasteWise program (see Sections 4(b)(v) and 5(a)(v)).

      2(b)	Practical Utility/Users of the Data

            The information collected by the WasteWise program is not required for regulatory purposes by ORCR or other EPA offices. These data are reported by individual WasteWise members as a condition to remain active in the program. The data represent members' progress they make towards waste reduction goals, including waste prevention, recycling collection, and buying or manufacturing recycled-content products activities. EPA does not conduct facility audits of WasteWise members; however, a quality assurance process is in place to review member data for accuracy. Details of this process are discussed in Section 5(a)(ii).  EPA provides tools, technical assistance, and mentoring opportunities to assist members in planning, developing, and implementing their waste reduction program efforts.  Often this assistance allows members to set higher waste reduction goals and achieve greater results than originally anticipated.

            Specifically, EPA uses the information collected in the Partner Registration Form to track organization status, prepare reports and mailing lists, and determine the focus of future WasteWise outreach efforts (based on partners' identified priorities).  Additional contacts for any organization can be added using the New Contact Form.

            EPA uses the information collected in the Partner Annual Assessment Form to record the participant's activities and progress in the WasteWise data management and reporting system; identify, develop, and disseminate case studies and other materials on key waste reduction practices; identify areas where additional technical assistance or information would be useful for individual Partners or more generally for program participants (e.g., high recycling figures for corrugated containers might indicate an opportunity for transport packaging reductions); recognize organizations with significant waste reduction accomplishments; evaluate opportunities for improving the WasteWise program, and measure the program's progress as well as progress towards sustainable materials management goals. Information on Partner results may be published in an annual report, however, this report has not been published since 2008.

            EPA uses the general information collected in the Endorser Registration Form to track organization status and prepare reports and mailing lists. EPA will use the information collected in the Endorser Annual Assessment Form to learn about promotional activities and share successful strategies with other Endorsers, and offer assistance for these activities, such as providing materials for mailings or speakers for conferences (see Sections 4(b)(v) and 5(a)(v)).

3.	NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION CRITERIA

      3(a)	Non-duplication

            The information obtained under this ICR is not duplicative nor is it currently collected by EPA or any other federal agency. Other non-federal organizations sponsor partnership programs that promote recycling collection or buying recycled products, but they do not offer a comprehensive waste reduction program that emphasizes the cost saving and environmental benefits of waste reduction. ORCR continues to work with these non-federal organizations to ensure that efforts are not duplicative.

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

            In compliance with the Paperwork Reduction Act of 1995, EPA issued a public notice in the Federal Register on February 23, 2011 (76 FR 10022).  The public comment period ended on April 25, 2011.  EPA received no comments on this ICR in response to the Federal Register notice.

      3(c)	Consultations

            Since the last ICR approval, EPA has implemented an online data management and reporting system for use by Partners and Endorsers. Prior to launching this new system, EPA consulted with long-standing WasteWise members to beta-test the online system. WasteWise staff also conducted personal interviews with specific program members to discuss the utility of the registration forms, annual assessment forms, and other online features. Interviews were conducted with the following WasteWise members:

                                     Name
                                 Organization
                                E-Mail Address
Kirby Kraft
Anheuser-Bush
<EMAIL_ADDRESS>Bruce Norton
Constellation Energy
<EMAIL_ADDRESS>John Bradburn
General Motors
<EMAIL_ADDRESS>Tom Costantino
PSEG
<EMAIL_ADDRESS>Charlie Vidich
USPS
<EMAIL_ADDRESS>Don Curran
Virco Mfg
<EMAIL_ADDRESS>Vicki Bushnell
Kitsap County, WA
<EMAIL_ADDRESS>Kathleen Tobin
Verizon
<EMAIL_ADDRESS>Kinley Deller
King County, WA
<EMAIL_ADDRESS>
            WasteWise also conducted webinars to allow members to test the system. We created test accounts so members could input data and trial the system. We evaluated time, functionality of the system, utility, ease of use, and maneuverability within the system. The feedback received allowed us to make key enhancements to the automated system in an effort to improve access and facilitate data entry. In addition, EPA headquarters consulted with regional offices to identify types of reports needed to improve partner support and outreach. WasteWise then built the necessary capabilities within the online system to satisfy their needs.

            Once EPA launched the new online system, we held a series of webinars for existing and potential WasteWise members. From these webinars, additional enhancements were made. EPA has taken great care to make the transition to our online automated system as seamless and workable as possible for our members.

            According to unsolicited feedback that we have received from Partners, the new online data management and reporting system has had a positive effect on the program. Many participating partners use the online system for internal tracking and reporting purposes, and appreciate the ability to sort their data and run customized reports. Of particular benefit is the system's ability to allow Partners and Endorsers to enter data for individual reporting locations within their organization.

      3(d)	Effects of Less Frequent Collection

            The Partner Registration Form and Endorser Registration Form are one-time submissions for organizations wishing to participate in the WasteWise program. The New Contact Form is used to add additional users to an existing Partner or Endorser account

            Within two months of registering, Partners submit the online Partner Annual Assessment Form with waste reduction baseline data and goals. This is also a one-time submission. Once baseline data is collected, Partners submit annual waste reduction data using the Partner Annual Assessment Form by March 31 of each year for the proceeding calendar year, for as long as they remain active in the program.

            Endorsers will submit the Endorser Annual Assessment Form by March 31 of each year for the proceeding calendar year, detailing their annual recruitment and promotional activities for as long as they remain active in the program.

            WasteWise believes that the frequency of data collection is appropriate and mirrors existing organization's internal annual reporting. Less frequent collection of annual assessment reports would hinder any WasteWise efforts to:
               * Analyze program data to develop timely and successful strategies for engaging with members to achieve greater waste reductions;
               * Review Partner activities in order to publicly recognize significant waste reduction activities; and
               * Generate relevant and timely case studies and success stories that are helpful to members.

      3(e)	General Guidelines

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

      3(f)	Confidentiality

            No information collected by EPA under the WasteWise program comprises confidential business information.

      3(g)	Sensitive Questions

            No questions asked by EPA under the WasteWise program are of a sensitive nature.

4.	THE RESPONDENTS AND THE INFORMATION REQUESTED

      4(a)	Respondents

            The WasteWise program targets a broad audience, including small, medium, and large size businesses, nonprofit organizations, schools, colleges, universities, and federal, state, local, and tribal governments.

            The WasteWise Endorser Program targets trade associations, membership organizations, and federal, state, local, and tribal organizations in this supporting statement.

	4(b)	Information Requested

            When a member organization joins the WasteWise program as a Partner or Endorser, they register via the online Partner Registration Form or Endorser Registration Form. New partners are required to provide WasteWise with baseline waste reduction data within two months of registration using the Partner Annual Assessment Form. By March 31 of each year, all existing members and new members that joined the program before August 1 of the preceding year must report on the progress made toward achieving their goals using the online Partner Annual Assessment Form or Endorser Annual Assessment Form.  Partners can add additional users to their online account by submitting a New Contact Form.

            (i) Partner Registration Form

            Program participants complete and submit to EPA a standard online Partner Registration Form that provides the following information:

      	Data items:

                     *                   Organization name, parent organization name (if applicable), and industry sector;
                     *                   Organization contact information including address, and website;
                     *                   Names and location of participating facilities;
                     *                   Aggregate number of employees at all participating facilities;
                     *                   How the member heard about the WasteWise program;
                     *                   Organization's primary contact's name; title; address, phone, fax and alternate number; and email address;
                     *                   Goals and activities; and
                     *                   Affiliate Networks, if any.

      	Respondent activities:

                     *                   Review the WasteWise materials and requirements;
                     *                   Select a primary contact person for the WasteWise program;
                     *                   Gather current waste management data to develop a baseline of waste reduction activities;
                     *                   Create a password for access to Re-TRAC;
                     *                   Accept participation requirements detailed in the Partnership Agreement included on the Partner Registration Form; and
                     *                   As part of the registration process, partners are required to submit baseline data. This data is submitted using the Partner Annual Assessment Form as detailed below.

            (ii) Partner Annual Assessment Form

            WasteWise Partners are required to submit baseline data one time via the online Annual Assessment Form and within 60 days of registering with the Program. WasteWise Partners are required to submit annual program results. Partner Annual Assessment Forms are due by March 31 of each year for data from the preceding calendar year data. The online Partner Annual Assessment Form contains both qualitative information and quantitative data.

      	Data items:

                  *                   Municipal Solid Waste Disposed
                        o                        Weight of waste disposed via landfill and/or incineration (pounds and/or tons); and
                        o                        Activity description and/or goals for upcoming year.
                  *                   Waste Prevention and Recycling
                        o                        Type of material;
                        o                        Weight of waste prevented and/or material recycled (pounds and/or tons); and
                        o                        Activity description and/or goals for upcoming year.
                  *                   Buying or Manufacturing Recycled-Content Products
                        o                        Type of product purchased or manufactured;
                        o                        Current and previous recycled content percentages;
                        o                        Amount purchased or manufactured (pounds and/or tons); and
                        o                        Comments and/or goals.
                  *                   Cost Savings and/or Revenue
                        o                        Dates for cost savings and/or revenue;
                        o                        Total waste prevention revenue generated;
                        o                        Total recycling revenue generated;
                        o                        Total avoided purchasing costs due to waste prevention; and
                        o                        Total avoided disposal costs due to recycling and waste prevention.
                  *                   Comments
                        o                        A partner may provide additional information on its waste reduction activities (e.g., external promotion of WasteWise, employee education, etc.) or comments about the WasteWise program.

            WasteWise expects that the information needed for the Partner Annual Assessment Form is kept as a common business practice by companies implementing waste reduction programs. Therefore, recordkeeping activities associated with reporting are not included in this ICR.

      	Respondent activities:

                  *                   Conduct a waste assessment or account for annual waste reduction efforts;
                  *                   Review waste management records to assess progress during the reporting year;
                  *                   Set new self-identified waste reduction goals;
                  *                   Complete and submit the online Annual Assessment Form;
                  *                   Respond to EPA questions about reported data; and
                  *                   As noted above (under Partner Registration Form), partners use the Annual Assessment Form to submit baseline data online and within 60 days of registering for the program.

            (iii) Endorser Registration Form

            Endorsers complete and submit an online Endorser Registration Form that provides basic information and describes recruitment and promotional activities.

		Data items:

                  *                   Organization name;
                  *                   Name, title, address, phone number, fax number, and email address of the endorser's principal contact person;
                  *                   Approximate number of business members in the organization;
                  *                   List of primary business sectors represented by the organization (e.g., NAICS codes);
                  *                   Description of proposed recruitment campaign to encourage the organization's members (e.g., local businesses) to become WasteWise Partners; and
                  *                   Description of proposed ongoing activities to promote WasteWise and/or provide information to organization members on waste reduction strategies.

      	Respondent activities:

                  *                   Review the WasteWise Endorser Program information;
                  *                   Identify ongoing promotional and support activities;
                  *                   Select a primary contact person for the WasteWise Endorser Program; and
                  *                   Complete and submit the online Endorser Registration Form.

            (iv) Endorser Annual Assessment Form

            In 2011, WasteWise plans to develop a form that will allow Endorsers to track and report their annual achievements. Endorsers will be required to complete and submit the Endorser Annual Assessment Form by March 31 of each year for the preceding year's activities (first submission will be March 31, 2012). The online Endorser Annual Assessment Form will contain information on the Endorsers' annual recruitment and promotional activities, as well as new goals for the following year.

      Data items:

                  *                   Promotional Activities
                        o                        Description of activities conducted to promote waste reduction and WasteWise; and
                        o                        Frequency of promotional efforts.
                  *                   Promotional Results
                        o                        Number of organizations and/or people reached with promotional efforts;
                        o                        New organizations joining WasteWise following promotional efforts; and
                        o                        Number of WasteWise Partners that the Endorser provided with tracking and reporting assistance.
                  *                   Comments
                        o                        The Endorser may provide any additional information on its recruitment and promotional activities and promotional goals for the upcoming year.

            Endorsers can use the online data management and reporting system as the sole method to record, track, and report their endorsement activities.  Therefore, no separate "recordkeeping" activities will be required. As a result, activities associated with separate recordkeeping, beyond data entry into the system, are not included in this ICR.

      	Respondent activities:

                  *                   Review recruitment and promotional activities to assess progress during the reporting year;
                  *                   Set new recruiting and promotional goals; and
                  *                   Complete and submit the online Endorser Annual Assessment Form.

            (v) New Contact  Form

            Partners and Endorsers may elect to have multiple users access the online data management and reporting system in order to facilitate reporting at different locations. The New Contact Form is used by members when granting a new user (within their organization) access to the online data management and reporting system. There are two versions of this form, one for individuals to request access for themselves to the WasteWise online data management and reporting system and one for account administrators to add additional users. The only difference between the two versions is that the account administrators have two additional fields to assign and/or restrict each user's rights within the WasteWise online data management and reporting system. Burden estimates for this form are included in estimates provided for the Partner Registration Form and Endorser Registration Form since this is an extension of registration information.

            Data items:
                     *                   Organization name, reporting location, and state;
                     *                   Contact's name; title; address, phone, fax and alternate number; and email address;
                     *                   User access level: Primary or Reporting (For account administrators only); and

                     *                   User location access: Establish/Restrict a user's access to one or more locations (For account administrators only).

            Respondent activities
                     *                   Create a password for access to Re-TRAC.

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

      5(a)	Agency Activities

            Under the WasteWise program, EPA engages in various activities related to the following five forms:

            (i) Partner Registration Form

               * Maintain Partner Registration Forms in the online data management and reporting system and public WasteWise website;
               * Answer questions posed by potential participants regarding program membership;
               * Review and approve new partner registration forms;
               * Place welcome calls to new partners; and
               * Email welcome letters to new partners containing participation information and links to program resources.

            (ii) Partner Annual Assessment Form

               * Maintain the online data management and reporting system containing annual assessment data entered by members. This online system is also a tool to assist partners in measuring and tracking waste reduction progress;
               * Provide tools to assist partners with measuring, tracking, and reporting progress. These tools range from resources posted to the program website, a staffed helpline, and periodic webinars;
               * Email partners to remind them to submit data by due dates:
                     o                        New partners must submit baseline waste reduction data and goals within two months of registering for the program;
                     o                        Existing Partners must submit waste reduction data and new goals by March 31 of each year for the proceeding calendar year; and
               * Answer questions regarding the Partner Annual Assessment Form, and once received, review it for consistency and completeness, making follow-up inquiries as needed.
                     o                        Reported Data Quality. The WasteWise program employs a quality assurance process that involves reviewing the data submitted by each Partner and determining whether the reported results appear consistent with the volumes reported by the Partner in previous years for similar activities. If newly submitted data appear to be the exact same as data submitted in previous years or appear to be cumulative rather than simply for the current reporting year period, the Partner is contacted to clarify the reported results. For reported amounts above 1,000,000 pounds, Partners are contacted to confirm the order of magnitude and to prevent any errors of interpretation. In addition, data are reviewed to ensure that only acceptable WasteWise materials and activities are included in the amounts reported. Once this thorough review is complete, the data is verified. Only data verified through the quality assurance process is included in official program data.
                     *                   Develop Climate Change profiles, for each Partner, which provides annual summaries of verified data and related greenhouse gas impacts using EPA's WaRM.

            (iii) Endorser Registration Form
               * Maintain Endorser Registration Forms on the public WasteWise website;
               * Answer questions posed by potential Endorsers regarding membership in the program;
               * Review and approve new Endorser Registration Forms;
               * Place a welcome call to new Endorsers; and
               * Email welcome letters to new Endorsers containing participation information and links to program resources.

            (iv) Endorser Annual Assessment Form

            As noted above, this is a newly developed form. WasteWise anticipates undertaking the following activities in association with this form:
               * Maintain the online data management and reporting system containing annual assessment data entered by members. This web based system is also a tool to assist Endorsers in measuring and tracking promotional and recruiting activities;
               * Provide tools to assist Endorsers with their promotional and recruitment efforts. These tools range from resources posted to the program website, a staffed helpline, and periodic webinars;
               * Email Endorsers to remind them to submit data by due dates:
                     o                        Endorsers must submit the previous year's promotional and recruiting data and new goals by March 31 of each year for the proceeding calendar;
               * Answer any questions regarding the Endorser Annual Assessment Form and once received, review it for consistency and completeness, making follow-up inquiries, as needed;
                     o                        Reported Data Quality. The WasteWise program reviews the data submitted by each Endorser and determines whether the information reported appears consistent with the activities and goals reported in previous years. If newly submitted data appear to be the exact same as submitted in previous years or appears to be cumulative rather than simply for the current reporting year period, the Endorser is contacted to clarify the reported results. In addition, reported information is reviewed to ensure that only acceptable WasteWise activities are included. Once this thorough review is complete, the data is verified. Only verified data is included in official program data.

            (v) New Contact Form

               * Maintain New Contact Form in the online data management and reporting system;
               * Email contacts on the form that they have access to the online data management and reporting system; and
               * When requested, provide newly activated contacts with assistance in accessing the online system.

      5(b)	Collection Methodology and Management

            EPA relies on its online forms and database to collect, store, and evaluate the data submitted by Partners. EPA reviews each submission to ensure the collected information is reasonable and complete. The data are used to identify prominent waste reduction strategies, develop and publish case studies of significant accomplishments, and steer the program's priorities for the upcoming year. In addition, members can use the online data management and reporting system to benchmark data and evaluate trends.

            The data collected under this ICR is reported by individual WasteWise members as a condition to remain active in the program. The data represent members' quantified progress that they made towards waste reduction goals (in areas such as waste prevention, recycling collection, and buying or manufacturing recycled-content products). EPA does not conduct facility audits of WasteWise members; however, a quality assurance process is in place to review reported data for accuracy and adherence to goals as described in Section 5(a)(ii).

            WasteWise uses the collected data to record participant's activities and progress made in waste prevention and recycling, identify technical assistance needs for each participant, and develop case studies and mentoring opportunities that can be used by participants to enhance their waste reduction programs.

            Data are also used to report the overall results of members involved in the program. Any time data is aggregated and/or disseminated, EPA follows the existing Terms of Clearance and qualifies its results to ensure attribution (i.e., program's impact on Partner achievements) is not implied. EPA will work with OMB to develop a methodology to better characterize the program's influence on Partner behavior and results. Once a methodology is developed, EPA would like to disseminate and use the program results from WasteWise with attribution.

      5(c)	Small Entity Flexibility

            Some of the participants in the WasteWise program will be small entities. EPA designed its online reporting forms to be highly flexible and dependent on activities in order to minimize respondent burden, while obtaining sufficient and accurate information. Organizations can also choose the number of facilities to include in the program and choose their own goals based on resources. In addition, the burden associated with the WasteWise program is greatly reduced for small entities in particular because the program offers direct one-on-one mentoring and a helpline that provides support especially valuable for small organizations allowing them to fully participate in the program.

      5(d)	Collection Schedule

            Organizations may join the WasteWise program by submitting the online Partner Registration Form at any time. New Partners submit baseline waste reduction data and goals via the online Partner Annual Assessment Form within two months of joining the program. All existing Partners' online Partner Annual Assessment Forms are due to EPA by March 31 of every year for the proceeding calendar year that the partner participates in the program.

            Trade associations and other membership-based organizations may join the program by submitting the online Endorser Registration Forms at any time. All existing Endorsers' online Endorser Annual Assessment Forms will be due to EPA by March 31 of every year for the proceeding calendar year that the Endorser participates in the program.

6.	ESTIMATING THE BURDEN AND COST OF THE COLLECTION

      6(a)	Estimating Respondent Burden

            Tables 4-6 present the burden hours, costs per respondent, and total for all respondents during each of the three years covered under this ICR. WasteWise members are divided into three sectors representing: Private, State/Local, and Federal.

            The Partner Registration Form contains basic questions, and thus the burden is expected to be minimal. The overall burden, as shown in the tables, is estimated to be one hour per participant. This burden level is an estimate based on 17 years of WasteWise program experience. The burden estimate for the Partner Registration Form is for completing and submitting the form only.

            Completing the Partner Annual Assessment Form entails assessment, reporting, and recordkeeping activities. The overall annual labor burden for Partners is expected to average 34.5 hours per participant; this estimate is based on 17 years of WasteWise program experience. Burden hours for the Partner Annual Assessment Form are for conducting a waste assessment, collecting data, entering data into the online data management and reporting system, and reporting activities.

            In the first year of membership, new Partners are estimated to spend 35.5 hours (one hour on the Partner Registration Form and 34.5 hours on the Partner Annual Assessment Form, i.e. providing baseline data) on the information collection activities. It is estimated that Partners spend 34.5 hours (on the Partner Annual Assessment Form) for subsequent years in the program.  Estimates for submitting information associated with the New Contact Form are included in the burden estimates for the Partner Registration Form and Endorser Registration Form since this information is an extension of registration.

            The Endorser Registration Form asks for basic information and requests brief descriptions of promotional activities, and thus the burden is expected to be minimal. The overall burden, as shown in Tables 4-6, is estimated to be three hours per participant; this estimate is based on 17 years of WasteWise program experience. All burden hours for the Endorser Registration Form are for reporting only.

            Completing the Endorser Annual Assessment Form entails assessment, reporting, and recordkeeping activities. The overall annual labor burden for Endorsers is expected to average five hours per participant. Burden hours for the Endorser Annual Assessment Form are for accounting for annual efforts, assessing progress, entering data into the online data management and reporting system, and reporting activities.

      6(b)	Estimating Respondent Costs

            Currently, WasteWise has 568 active Partners and 86 active Endorsers. WasteWise anticipates receiving 343 new Partner Registration Forms and 54 new Endorser Registration Forms each year under this ICR. Of these new registrants, WasteWise anticipates 76 Partners and 11 Endorsers will fulfill their membership requirements and submit Annual Assessment Forms each year. The membership breakdown by sector over the next three years is shown in the following table.

		Table 1. WasteWise Membership

                       WasteWise Partners (by category)

                                    Federal
                                  State/Local
                                    Private
                                     Total
                                    Current
                                      21
                                      45
                                      502
                                      568
                                    Year 1
                                      24
                                      51
                                      569
                                      644
                                    Year 2
                                      27
                                      57
                                      636
                                      720
                                    Year 3
                                      30
                                      63
                                      703
                                      796
                       WasteWise Endorsers (by category)

                                    Federal
                                  State/Local
                                    Private
                                     Total
                                    Current
                                       2
                                      12
                                      72
                                      86
                                    Year 1
                                       2
                                      14
                                      81
                                      97
                                    Year 2
                                       2
                                      16
                                      90
                                      108
                                    Year 3
                                       2
                                      18
                                      99
                                      119

            EPA used the May 2009 Occupational Employment Statistics (OES) Survey from the Bureau of Labor Statistics, Department of Labor to estimate average hourly private respondent labor. This survey provides unloaded labor rates for a number of job categories in various sectors. EPA believes (based on 17 years of program experience) that responses will require time from one manager and one technical staff person. For managers, EPA used labor category 11-9199 (Managers, All Others) which has an average unloaded labor rate of $47.67/hour. For technical staff, EPA used labor category 19-2041 (Environmental Scientists) which has an unloaded labor rate of $32.38/hour. These hourly rates were multiplied by a standard private sector overhead calculation factor of 2.3 to obtain the loaded labor rates for private sector respondents shown in Table 2. All rates have been rounded up to the nearest dollar. No capital or operations and management costs are incurred by respondents under this ICR.

      Table 2. Hourly Labor Rates  -  Private Sector

                                Labor Category
                          Hourly Rate Plus Overhead
                                  Management
                                     $110
                                   Technical
                                      $74

            For federal, state, and local respondents, EPA used the General Schedule Salary Tables for 2011 issued by the Office of Personnel Management (OPM) to estimate hourly labor rates. EPA believes (based on program experience) that responses will require time from one manager (GS 14, Step 3) and one technical staff person (GS 11, Step 10). To estimate national labor rates for each of these job categories, EPA summed the unloaded hourly rates of all 36 locality tables and averaged the rates for GS 14, Step 3 and GS 11, Step 10. Based on these calculations, the average unloaded rates for GS 14, Step 3 is $51.86 and for GS 11, Step 10 is $37.53. EPA multiplied these basic hourly rates by the standard government overhead factor of 1.6 to obtain the loaded labor rates shown in Table 3. All figures have been rounded up to the next full dollar.

      Table 3.  Local, State, and Federal Labor Rates

                                Labor Category
                          Rate Plus Overhead ($/hour)
                                  Management
                                      $84
                                   Technical
                                      $61

Table 4.  Annual Estimated Respondent Burden and Cost  -  Private Sector Respondents

                              Partner Respondents

          Individual Respondent Burden Hours & Cost for All Years
                                 Year 1 Costs
                                 Year 2 Costs
                                 Year 3 Costs

                       Hours per Respondent per Activity
                               Cost per Activity
                                  Total Hours
                                  Total Cost
                                  Total Hours
                                  Total Cost
                                  Total Hours
                                  Total Cost

Management
Technical
                                  Total Hours

Partner Registration Form (includes New Contact Form)
Review Form
                                                                           0.25
                                                                           0.50
                                                                           0.75
                                                                            $65
                                                                            227
                                                                        $19,479
                                                                            227
                                                                        $19,479
                                                                            227
                                                                        $19,479
Complete/Transmit Form
                                                                           0.00
                                                                           0.25
                                                                           0.25
                                                                            $19
                                                                             76
                                                                         $5,587
                                                                             76
                                                                         $5,587
                                                                             76
                                                                         $5,587
SUBTOTAL
                                                                           0.25
                                                                           0.75
                                                                           1.00
                                                                            $83
                                                                            302
                                                                        $25,066
                                                                            302
                                                                        $25,066
                                                                            302
                                                                        $25,066
Annual Assessment Form
Collect records and conduct a waste assessment OR account for annual efforts
                                                                           7.00
                                                                          14.00
                                                                          21.00
                                                                         $1,806
                                                                         11,949
                                                                     $1,027,614
                                                                         13,356
                                                                     $1,148,616
                                                                         14,763
                                                                     $1,269,618
Review records to assess progress
                                                                           0.25
                                                                           0.25
                                                                           0.50
                                                                            $46
                                                                            285
                                                                        $26,174
                                                                            318
                                                                        $29,256
                                                                            352
                                                                        $32,338
Set Goals
                                                                           2.50
                                                                           7.50
                                                                          10.00
                                                                           $830
                                                                          5,690
                                                                       $472,270
                                                                          6,360
                                                                       $527,880
                                                                          7,030
                                                                       $583,490
Complete/Transmit Form
                                                                           0.25
                                                                           1.75
                                                                           2.00
                                                                           $157
                                                                          1,138
                                                                        $89,333
                                                                          1,272
                                                                        $99,852
                                                                          1,406
                                                                       $110,371
Respond to EPA Questions
                                                                           0.25
                                                                           0.75
                                                                           1.00
                                                                            $83
                                                                            569
                                                                        $47,227
                                                                            636
                                                                        $52,788
                                                                            703
                                                                        $58,349
SUBTOTAL
                                                                          10.25
                                                                          24.25
                                                                          34.50
                                                                         $2,922
                                                                         19,631
                                                                     $1,662,618
                                                                         21,942
                                                                     $1,858,392
                                                                         24,254
                                                                     $2,054,166
Costs to Partners
Total Cost to All Partners

                                                                         19,933
                                                                     $1,687,684
                                                                         22,244
                                                                     $1,883,458
                                                                         24,556
                                                                     $2,079,232
                             Endorser Respondents

          Individual Respondent Burden Hours & Cost for All Years
                                 Year 1 Costs
                                 Year 2 Costs
                                 Year 3 Costs

                       Hours per Respondent per Activity
                               Cost per Activity
                                 Total Hours
                                  Total Cost
                                 Total Hours
                                  Total Cost
                                 Total Hours
                                  Total Cost

Management
Technical
                                  Total Hours

Endorser Registration Form (includes New Contact Form)
Review Form
                                                                           0.25
                                                                           0.50
                                                                           0.75
                                                                            $65
                                                                             34
                                                                         $2,903
                                                                             34
                                                                         $2,903
                                                                             34
                                                                         $2,903
Determine Activities
                                                                           0.25
                                                                           1.50
                                                                           1.75
                                                                           $139
                                                                             79
                                                                          6,233
                                                                             79
                                                                         $6,233
                                                                             79
                                                                         $6,233
Complete/Transmit Form
                                                                           0.00
                                                                           0.50
                                                                           0.50
                                                                            $37
                                                                             23
                                                                          1,665
                                                                             23
                                                                         $1,665
                                                                             23
                                                                         $1,665
SUBTOTAL
                                                                           0.50
                                                                           2.50
                                                                           3.00
                                                                           $240
                                                                            135
                                                                         10,800
                                                                            135
                                                                        $10,800
                                                                            135
                                                                        $10,800
Endorser Annual Assessment Form
Account for annual efforts
                                                                           0.50
                                                                           1.50
                                                                           2.00
                                                                           $166
                                                                            162
                                                                        $13,446
                                                                            180
                                                                        $14,940
                                                                            198
                                                                        $16,434
Review records to assess progress
                                                                           0.25
                                                                           0.25
                                                                           0.50
                                                                            $46
                                                                             41
                                                                         $3,726
                                                                             45
                                                                         $4,140
                                                                             50
                                                                         $4,554
Set Goals
                                                                           0.25
                                                                           1.00
                                                                           1.25
                                                                           $102
                                                                            101
                                                                         $8,222
                                                                            113
                                                                         $9,135
                                                                            124
                                                                        $10,049
Complete/Transmit Form
                                                                           0.00
                                                                           0.50
                                                                           0.50
                                                                            $37
                                                                             41
                                                                         $2,997
                                                                             45
                                                                         $3,330
                                                                             50
                                                                         $3,663
Respond to EPA Questions
                                                                           0.25
                                                                           0.50
                                                                           0.75
                                                                            $65
                                                                             61
                                                                         $5,225
                                                                             68
                                                                         $5,805
                                                                             74
                                                                         $6,386
SUBTOTAL
                                                                           1.25
                                                                           3.75
                                                                           5.00
                                                                           $415
                                                                            405
                                                                        $33,615
                                                                            450
                                                                        $37,350
                                                                            495
                                                                        $41,085
Costs to Endorsers
Total Cost to All Endorsers

                                                                            540
                                                                        $44,415
                                                                            585
                                                                        $48,150
                                                                            630
                                                                        $51,885
Assumptions

Management rate: $110/hr

Technical rate: $74/hr

New partners: 302/yr

Reporting partners: Y1=569, Y2=636, Y3=703

New Endorsers: 45/yr

Reporting Endorsers: Y1=81, Y2=90, Y3=99

Table 5.  Annual Estimated Respondent Burden and Cost  -  State/Local Respondents

                              Partner Respondents

          Individual Respondent Burden Hours & Cost for All Years
                                 Year 1 Costs
                                 Year 2 Costs
                                 Year 3 Costs

                       Hours per Respondent per Activity
                               Cost per Activity
                                  Total Hours
                                  Total Cost
                                  Total Hours
                                  Total Cost
                                  Total Hours
                                  Total Cost

Management
Technical
                                  Total Hours

Partner Registration Form (includes New Contact Form)
Review Form
                                                                           0.25
                                                                           0.50
                                                                           0.75
                                                                            $52
                                                                             25
                                                                         $1,700
                                                                             25
                                                                         $1,700
                                                                             25
                                                                         $1,700
Complete/Transmit Form
                                                                           0.00
                                                                           0.25
                                                                           0.25
                                                                            $15
                                                                              8
                                                                           $503
                                                                              8
                                                                           $503
                                                                              8
                                                                           $503
SUBTOTAL
                                                                           0.25
                                                                           0.75
                                                                           1.00
                                                                            $67
                                                                             33
                                                                         $2,203
                                                                             33
                                                                         $2,203
                                                                             33
                                                                         $2,203
Annual Assessment Form
Collect records and conduct a waste assessment OR account for annual efforts
                                                                           7.00
                                                                          14.00
                                                                          21.00
                                                                         $1,442
                                                                          1,071
                                                                        $73,542
                                                                          1,197
                                                                        $82,194
                                                                          1,323
                                                                        $90,846
Review records to assess progress
                                                                           0.25
                                                                           0.25
                                                                           0.50
                                                                            $36
                                                                             26
                                                                         $1,849
                                                                             29
                                                                         $2,066
                                                                             32
                                                                         $2,284
Set Goals
                                                                           2.50
                                                                           7.50
                                                                          10.00
                                                                           $668
                                                                            510
                                                                        $34,043
                                                                            570
                                                                        $38,048
                                                                            630
                                                                        $42,053
Complete/Transmit Form
                                                                           0.25
                                                                           1.75
                                                                           2.00
                                                                           $128
                                                                            102
                                                                         $6,515
                                                                            114
                                                                         $7,282
                                                                            126
                                                                         $8,048
Respond to EPA Questions
                                                                           0.25
                                                                           0.75
                                                                           1.00
                                                                            $67
                                                                             51
                                                                         $3,404
                                                                             57
                                                                         $3,805
                                                                             63
                                                                         $4,205
SUBTOTAL
                                                                          10.25
                                                                          24.25
                                                                          34.50
                                                                         $2,340
                                                                          1,760
                                                                       $119,353
                                                                          1,967
                                                                       $133,394
                                                                          2,174
                                                                       $147,436
Costs to Partners
Total Cost to All Partners

                                                                          1,793
                                                                       $121,556
                                                                          2,000
                                                                       $135,597
                                                                          2,207
                                                                       $149,639
                             Endorser Respondents

          Individual Respondent Burden Hours & Cost for All Years
                                 Year 1 Costs
                                 Year 2 Costs
                                 Year 3 Costs

                       Hours per Respondent per Activity
                               Cost per Activity
                                 Total Hours
                                  Total Cost
                                 Total Hours
                                  Total Cost
                                 Total Hours
                                  Total Cost

Management
Technical
                                  Total Hours

Endorser Registration Form (includes New Contact Form)
Review Form
                                                                           0.25
                                                                           0.50
                                                                           0.75
                                                                            $52
                                                                              6
                                                                           $412
                                                                              6
                                                                           $412
                                                                              6
                                                                           $412
Determine Activities
                                                                           0.25
                                                                           1.50
                                                                           1.75
                                                                           $113
                                                                             14
                                                                           $900
                                                                             14
                                                                           $900
                                                                             14
                                                                           $900
Complete/Transmit Form
                                                                           0.00
                                                                           0.50
                                                                           0.50
                                                                            $31
                                                                              4
                                                                           $244
                                                                              4
                                                                           $244
                                                                              4
                                                                           $244
SUBTOTAL
                                                                           0.50
                                                                           2.50
                                                                           3.00
                                                                           $195
                                                                             24
                                                                         $1,556
                                                                             24
                                                                         $1,556
                                                                             24
                                                                         $1,556
Endorser Annual Assessment Form
Account for annual efforts
                                                                           0.50
                                                                           1.50
                                                                           2.00
                                                                           $134
                                                                             28
                                                                         $1,869
                                                                             32
                                                                         $2,136
                                                                             36
                                                                         $2,403
Review records to assess progress
                                                                           0.25
                                                                           0.25
                                                                           0.50
                                                                            $36
                                                                              7
                                                                           $508
                                                                              8
                                                                           $580
                                                                              9
                                                                           $653
Set Goals
                                                                           0.25
                                                                           1.00
                                                                           1.25
                                                                            $82
                                                                             18
                                                                         $1,148
                                                                             20
                                                                         $1,312
                                                                             23
                                                                         $1,476
Complete/Transmit Form
                                                                           0.00
                                                                           0.50
                                                                           0.50
                                                                            $31
                                                                              7
                                                                           $427
                                                                              8
                                                                           $488
                                                                              9
                                                                           $549
Respond to EPA Questions
                                                                           0.25
                                                                           0.50
                                                                           0.75
                                                                            $52
                                                                             11
                                                                           $721
                                                                             12
                                                                           $824
                                                                             14
                                                                           $927
SUBTOTAL
                                                                           1.25
                                                                           3.75
                                                                           5.00
                                                                           $334
                                                                             70
                                                                         $4,673
                                                                             80
                                                                         $5,340
                                                                             90
                                                                         $6,008
Costs to Endorsers
Total Cost to All Endorsers

                                                                             94
                                                                         $6,229
                                                                            104
                                                                         $6,896
                                                                            114
                                                                         $7,564
Assumptions

Management Rate: $84/hr

Technical Rate: $61/hr

New Partners: 33/yr

Reporting Partners: Y1=51, Y2=57, Y3=63

New Endorsers: 8/yr

Reporting Endorsers: Y1=14, Y2=16, Y3=18

  Table 6.  Annual Estimated Respondent Burden and Cost  -  Federal Respondents

                              Partner Respondents

          Individual Respondent Burden Hours & Cost for All Years
                                 Year 1 Costs
                                 Year 2 Costs
                                 Year 3 Costs

                       Hours per Respondent per Activity
                               Cost per Activity
                                  Total Hours
                                  Total Cost
                                  Total Hours
                                  Total Cost
                                  Total Hours
                                  Total Cost

Management
Technical
                                  Total Hours

Partner Registration Form (includes New Contact Form)
Review Form
                                                                           0.25
                                                                           0.50
                                                                           0.75
                                                                            $52
                                                                              6
                                                                           $412
                                                                              6
                                                                           $412
                                                                              6
                                                                           $412
Complete/Transmit Form
                                                                           0.00
                                                                           0.25
                                                                           0.25
                                                                            $15
                                                                              2
                                                                           $122
                                                                              2
                                                                           $122
                                                                              2
                                                                           $122
SUBTOTAL
                                                                           0.25
                                                                           0.75
                                                                           1.00
                                                                            $67
                                                                              8
                                                                           $534
                                                                              8
                                                                           $534
                                                                              8
                                                                           $534
Annual Assessment Form
Collect records and conduct a waste assessment OR account for annual efforts
                                                                           7.00
                                                                          14.00
                                                                          21.00
                                                                         $1,442
                                                                            504
                                                                        $34,608
                                                                            567
                                                                        $38,934
                                                                            630
                                                                        $43,260
Review records to assess progress
                                                                           0.25
                                                                           0.25
                                                                           0.50
                                                                            $36
                                                                             12
                                                                           $870
                                                                             14
                                                                           $979
                                                                             15
                                                                         $1,088
Set Goals
                                                                           2.50
                                                                           7.50
                                                                          10.00
                                                                           $668
                                                                            240
                                                                        $16,020
                                                                            270
                                                                        $18,023
                                                                            300
                                                                        $20,025
Complete/Transmit Form
                                                                           0.25
                                                                           1.75
                                                                           2.00
                                                                           $128
                                                                             48
                                                                         $3,066
                                                                             54
                                                                         $3,449
                                                                             60
                                                                         $3,833
Respond to EPA Questions
                                                                           0.25
                                                                           0.75
                                                                           1.00
                                                                            $67
                                                                             24
                                                                         $1,602
                                                                             27
                                                                         $1,802
                                                                             30
                                                                         $2,003
SUBTOTAL
                                                                          10.25
                                                                          24.25
                                                                          34.50
                                                                         $2,340
                                                                            828
                                                                        $56,166
                                                                            932
                                                                        $63,187
                                                                          1,035
                                                                        $70,208
Costs to Partners
Total Cost to All Partners

                                                                            836
                                                                        $56,700
                                                                            940
                                                                        $63,721
                                                                          1,043
                                                                        $70,742
                             Endorser Respondents

          Individual Respondent Burden Hours & Cost for All Years
                                 Year 1 Costs
                                 Year 2 Costs
                                 Year 3 Costs

                       Hours per Respondent per Activity
                               Cost per Activity
                                 Total Hours
                                  Total Cost
                                 Total Hours
                                  Total Cost
                                 Total Hours
                                  Total Cost

Management
Technical
                                  Total Hours

Endorser Registration Form (includes New Contact Form)
Review Form
                                                                           0.25
                                                                           0.50
                                                                           0.75
                                                                            $52
                                                                              1
                                                                            $52
                                                                              1
                                                                            $52
                                                                              1
                                                                            $52
Determine Activities
                                                                           0.25
                                                                           1.50
                                                                           1.75
                                                                           $113
                                                                              2
                                                                           $113
                                                                              2
                                                                           $113
                                                                              2
                                                                           $113
Complete/Transmit Form
                                                                           0.00
                                                                           0.50
                                                                           0.50
                                                                            $31
                                                                              1
                                                                            $31
                                                                              1
                                                                            $31
                                                                              1
                                                                            $31
SUBTOTAL
                                                                           0.50
                                                                           2.50
                                                                           3.00
                                                                           $195
                                                                              3
                                                                           $195
                                                                              3
                                                                           $195
                                                                              3
                                                                           $195
Endorser Annual Assessment Form
Account for annual efforts
                                                                           0.50
                                                                           1.50
                                                                           2.00
                                                                           $134
                                                                              4
                                                                           $267
                                                                              4
                                                                           $267
                                                                              4
                                                                           $267
Review records to assess progress
                                                                           0.25
                                                                           0.25
                                                                           0.50
                                                                            $36
                                                                              1
                                                                            $73
                                                                              1
                                                                            $73
                                                                              1
                                                                            $73
Set Goals
                                                                           0.25
                                                                           1.00
                                                                           1.25
                                                                            $82
                                                                              3
                                                                           $164
                                                                              3
                                                                           $164
                                                                              3
                                                                           $164
Complete/Transmit Form
                                                                           0.00
                                                                           0.50
                                                                           0.50
                                                                            $31
                                                                              1
                                                                            $61
                                                                              1
                                                                            $61
                                                                              1
                                                                            $61
Respond to EPA Questions
                                                                           0.25
                                                                           0.50
                                                                           0.75
                                                                            $52
                                                                              2
                                                                           $103
                                                                              2
                                                                           $103
                                                                              2
                                                                           $103
SUBTOTAL
                                                                           1.25
                                                                           3.75
                                                                           5.00
                                                                           $334
                                                                             10
                                                                           $668
                                                                             10
                                                                           $668
                                                                             10
                                                                           $668
Costs to Endorsers
Total Cost to All Endorsers

                                                                             13
                                                                           $862
                                                                             13
                                                                           $862
                                                                             13
                                                                           $862
Assumptions

Management Rate = $84/hr

Technical Rate = $61/hr

New Partners = 8/yr

Reporting Partners: Y1=24, Y2=27, Y3=30

New Endorsers = 1/yr

Reporting Endorsers: Y1=2, Y2=2, Y3=2

      6(c)	Estimating Agency Burden and Costs

            Table 8 (below) presents the estimated Agency burden hours and costs associated with the information collection activities under this ICR. Other direct costs (copying, printing, telephone, and mailing expenses) are also included. EPA based its burden estimates on 17 years of experience managing the WasteWise program and interacting with partners.

            EPA used the General Schedule Salary Tables for 2011 issued by the Office of Personnel Management (OPM) to estimate hourly labor rates for the Agency. The Agency expects most activities under this ICR to be performed by managerial staff (GS 14, Step 3) and technical staff (GS 11, Step 10). To estimate national labor rates for each of these job categories, EPA summed the unloaded hourly rates of all 36 locality tables and averaged the rates for GS 14, Step 3 and GS 11, Step 10. Based on these calculations, the average unloaded rates for GS 14, Step 3 is $51.86 and for GS 11, Step 10 is $37.53. EPA multiplied these basic hourly rates by the standard government overhead factor of 1.6 to obtain the loaded labor rates shown in Table 7. All figures have been rounded up to the next full dollar.

            EPA still expects to have contractor support for various activities associated with the information collection under this ICR and has included contractor costs in the estimates. Contractor hourly rates, estimated based on the rates for the current contractor, ERG, are $150.58 for managerial staff (Project Manager) and $78.00 for technical staff (Program Analyst 2) so the average hourly rates are proportional to the percentage of contractor support on a given task.

            Table 7.  Agency Labor Rates

                             EPA/ Contractor Share
                                  Mgmt.
Rate
                                Technical Rate
                                    Mgmt.
%
                                  Technical %
                                 Average Rate
100% EPA
                                                                           $83
                                                                           $60
                                                                            25%
                                                                            75%
                                                                           $66
0% Contractor
                                                                            $0
                                                                            $0
                                                                             0%
                                                                             0%
                                                                            $0
Total

                                                                           $66
25% EPA
                                                                           $21
                                                                           $15
                                                                            25%
                                                                            75%
                                                                           $17
75% Contractor
                                                                          $113
                                                                           $59
                                                                            25%
                                                                            75%
                                                                           $73
Total

                                                                           $90
0% EPA
                                                                            $0
                                                                            $0
                                                                             0%
                                                                             0%
                                                                            $0
100% Contractor
                                                                          $151
                                                                           $78