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EPA's ENERGY STAR Program in the Commercial and Industrial Sectors (Renewal)

OMB: 2060-0347

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ICR SUPPORTING STATEMENT – PART A

EPA’s ENERGY STAR® Program in the Commercial and Industrial Sectors (Renewal).

EPA ICR No.: 1772.09

OMB Control No.: 2060-0347

ABSTRACT

The U.S. Environmental Protection Agency (EPA) created ENERGY STAR as a voluntary program to help businesses and individuals protect the environment through superior energy efficiency. The program focuses on reducing utility-generated emissions by reducing the demand for energy. In 1991, EPA launched the Green Lights program to encourage corporations, state and local governments, colleges and universities, and other organizations to adopt energy-efficient lighting as a profitable means of preventing pollution and improving lighting quality. Since then, EPA has rolled Green Lights into ENERGY STAR for the commercial and industrial sectors and expanded ENERGY STAR to encompass organization-wide energy performance improvement, such as building technology upgrades, product purchasing initiatives, and employee training. At the same time, EPA has streamlined the reporting requirements of ENERGY STAR and focused on providing recognition incentives for improvements (e.g., ENERGY STAR Awards program). EPA also makes tools and resources available over the web to help the public overcome the barriers to evaluating their energy performance and investing in profitable improvements.

For several reasons, the public’s participation in the ENERGY STAR program for commercial and industrial sectors has continued to increase over the past several years, and EPA expects their participation to rise even more in the coming years. For example, a growing number of state and local governments are leveraging ENERGY STAR as a way for the public to respond to rising energy costs and greenhouse gas emissions, including mandatory energy benchmarking and disclosure laws that require buildings within their jurisdiction to use EPA’s ENERGY STAR Portfolio Manager. As of the end of 2022, 45 state and local governments rely on Portfolio Manager as the foundation for their energy benchmarking and transparency policies. The use of Portfolio Manager is also increasing as Building Performance Standards are increasingly being implemented.

Participation in ENERGY STAR has also risen dramatically because of the efforts of trade associations, utilities, and third-party providers in promoting the program to the public. These organizations voluntarily communicate ENERGY STAR messages and promote the use of ENERGY STAR tools and strategies to help companies reduce their energy consumption and find more environmentally friendly ways to conduct business.

As participation has increased, EPA has taken measures to reduce the burden on participants that take advantage of the benefits of ENERGY STAR. For example, EPA has expanded Portfolio Manager Web Services, which is one of several benchmarking data-entry methods available to users.¹ Because Web Services integrates automated data collection and entry, it offers significant time-saving advantages over the other methods. For example, it takes four hours to perform a new benchmark using manual data entry, whereas about one hour using Web Services. A repeat benchmark takes 45 minutes using manual data entry, whereas about six minutes using Web Services.

Over many years, EPA has seen a growing trend of users opting for Web Services and thereby realizing these savings. This is illustrated in the bar graph below, which shows the total number of benchmarks performed annually using Web Services and the other methods. In 2013, 42% of all benchmarks were performed using Web Services. By 2022, this had grown to 84%.

In addition to expanding Web Services, the Agency has continued to enhance other features of Portfolio Manager, allowing participants to enter and retrieve information more quickly. EPA may also sporadically seek feedback to further improve program development or for evaluation purposes.

EPA is always looking for ways to reduce burden and in recent years, EPA has introduced changes to the requirements for certification that reduce both labor and cost for applicants, without impacting the integrity of the ENERGY STAR certification. Furthermore, within the next two years, EPA plans to incorporate a “Lite” benchmarking module into Portfolio Manager to simplify use for single and lower-resourced building owners. Though not factored into the burden estimates at this time, addition of this module is expected to further reduce the burden for many new users of Portfolio Manager.

In the last year alone², the ENERGY STAR program for commercial buildings and industrial plants helped businesses and organizations save 230 billion kilowatt-hours of electricity, avoid $14 billion in energy costs, and achieve 170 million metric tons of greenhouse gas reductions. On average, ENERGY STAR certified buildings use 35% less energy and generate 35% fewer greenhouse gas emissions than their peers.

As of 2022, 33 diverse industrial sectors work with ENERGY STAR to strategically manage their energy use, from cookie and cracker bakeries and pharmaceutical plants to integrated steel mills and petroleum refineries. EPA provides ENERGY STAR certification for 20 types of manufacturing plants. In 2022, 86 industrial plants earned ENERGY STAR certification.

NEED AND AUTHORITY FOR THE COLLECTION

Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

ENERGY STAR is authorized under section 103(g) of the Clean Air Act. The Energy Policy Act of 2005 further provides authorization to EPA and the U.S. Department of Energy (DOE) to establish a voluntary program to identify and promote energy-efficient products and buildings in order to reduce energy consumption, improve energy security, and reduce pollution through voluntary certification of, or other forms of communication about, products and buildings that meet the highest energy conservation standards.

In 2015, Congress directed EPA to develop a recognition program for energy efficient tenant spaces under the ENERGY STAR program. See the Energy Efficiency Improvement Act of 2015 for more information (42 USC § 17085).

Under federal law, federal agencies may not lease space in any building that has not earned the ENERGY STAR in the most recent year. All federally owned buildings are also required to track and report their energy use through ENERGY STAR. See the Energy Independence and Security Act of 2007 (42 USC § 17091).

ENERGY STAR is a voluntary program aimed at preventing pollution rather than controlling it after its creation. Information is needed from organizations joining the program for identification purposes (e.g., contact information) and for establishing their partnership. ENERGY STAR online tools (e.g., Portfolio Manager) are needed for users to benchmark facility energy performance, assess energy management goals over time, and identify strategic opportunities for savings and recognition opportunities. Finally, information is needed from organizations seeking ENERGY STAR recognition so that EPA can evaluate and verify their accomplishments and share their lessons learned with the public.

PRACTICAL UTILITY/USERS OF THE DATA

Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the Agency has made of the information received from the current collection.

EPA uses information from organizations joining the program to ascertain basic identification information about them and verify their commitment to the program. EPA may also use partnership information for program implementation purposes, such as maintaining up-to-date listings of products and services available to the public. Further, ENERGY STAR’s tools (e.g., Portfolio Manager, Energy Performance Indicator) are available online for the public to benchmark facility energy performance and identify opportunities for improvements.³ Finally, EPA uses information from organizations seeking recognition to evaluate and verify their energy performance and accomplishments. For example, EPA offers the public an opportunity to display the ENERGY STAR on their buildings if they meet certain energy performance criteria defined by EPA. To be approved to receive the ENERGY STAR, buildings must demonstrate that they meet specific eligibility requirements as well as industry standards for comfort and indoor air quality. EPA recognition enhances the image of organizations as national leaders in energy performance.

USE OF TECHNOLOGY

Describe whether, and to what extent, the collection of information involved the use of automated, electronic, mechanical, or other forms of technological collection techniques or information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

The information collected under this ICR can all be collected via electronic submission. Twelve of the collection instruments are provided in PDF format, five are provided as individual downloads from the EPA ENERGY STAR Portfolio Manager tool, three are provided via online form, and two are provided via Google Form. EPA chose each means of collection to make each form accessible based on the information requested in that form. Additionally, EPA considers these forms to have a low barrier to entry.

EPA ENERGY STAR’s tools continue to minimize burden for its users and EPA continuously assesses the opportunities to further reduce burden. For example, the Portfolio Manager Web Services tool automates the energy data reporting process for many users across the platform, so that it takes far less time per benchmark compared to manual benchmarking.

EFFORTS TO IDENTIFY DUPLICATION

Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described above.

The information collected under this ICR is not collected by any other EPA office or by any other federal agency. Therefore, there is not a potential for duplication with other federal collections.

MINIMIZING BURDEN ON SMALL ENTITIES

If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

Under ENERGY STAR, EPA has made enhancements to its information collections where possible to streamline the efforts of small businesses in reporting information and deriving energy savings. For example, EPA has a feature in Portfolio Manager, its interactive energy management tool, to better promote opportunities for automated data transfer through Web Services, which is offered as a free service increasingly by many utilities. Web Services is particularly beneficial for small businesses, which are less likely to have resources to manage Portfolio Manager data entry themselves.

Through Web Services, users set up buildings in Portfolio Manager and create a connection with the utility, and then the energy bills are automatically uploaded to Portfolio Manager on a monthly basis. EPA modified Portfolio Manager to notify small business users and others if they are located in a utility service territory that offers free Web Services. The notification includes a link to the provider’s web site to help them connect with the provider and learn about its services.

Additionally, within the next two years, EPA plans to incorporate a “Lite” benchmarking module into Portfolio Manager to simplify use for single and lower-resourced building owners. Though not factored into the burden estimates at this time, addition of this module is expected to further reduce the burden for many new users of Portfolio Manager.

EFFECTS OF LESS FREQUENT COLLECTION

Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

EPA has carefully considered the information collection burden under the ENERGY STAR program. EPA is confident that those activities requested of respondents are necessary, and to the extent possible, the Agency has minimized the burden. A number of the requested activities, for example, will be performed once (e.g., one-time submittal of a Partnership Agreement). In addition, respondents can satisfy many of the collections in this ICR by submitting readily available information. For example, users of Portfolio Manager are asked to enter energy use data (e.g., data from their energy bills). EPA believes strongly that, if the information collections in this ICR are not performed at the requested frequency, EPA’s ability to implement the ENERGY STAR program and the public’s ability to benefit from the program’s tools and resources could be hampered significantly.

GENERAL GUIDELINES

Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

EPA conducts audits on a small percentage of applications for ENERGY STAR certification for quality control purposes. Information requested during an audit is to clarify the initial data submitted to EPA. Respondents are given up to 4 weeks to reply to the request.

There are no additional special circumstances. Information collections performed under this clearance will follow all of OMB’s General Guidelines regarding federal data collection.

PUBLIC COMMENT AND CONSULTATIONS

8a. Public Comment

If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the Agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the Agency in response to these comments. Specifically address comments received on cost and hour burden.

In compliance with the Paperwork Reduction Act of 1995, EPA solicited public comments on this ICR through an announcement in the Federal Register on May 31, 2023 (88 FR 34-855). No comments were received.

CONSULTATIONS

Describe efforts to consult with persons outside the Agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years - even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

In March 2023, EPA contacted several Partner organizations to request their input on the ICR’s burden estimates. The purpose of the consultations was to determine if the burden estimates should be updated or revised in preparing ICR 1772.09. EPA spoke in-depth to three representatives of Partner organizations, including a K-12 school district, a service provider who conducts benchmarking, improvement, and certification for a range of commercial and multifamily building types, and a commercial real estate investment and multifamily management company. EPA selected these organizations because of their substantial experience in carrying out collections under the ENERGY STAR program.

Following is a summary of the organization’s comments and EPA’s responses (e.g., if and how the Agency incorporated the comments into ICR 1772.09):

Partnership Agreement: The ICR estimates that an organization in the commercial and industrial sectors takes 30 minutes on average to read, complete and submit a Partnership Agreement. EPA asked if this is a reasonable estimate. The organizations discussed their experiences preparing the agreement and indicated that 30 minutes is reasonable. EPA did not revise its estimate.
Portfolio Manager: The ICR estimates respondent burden for Portfolio Manager based on three alternative benchmarking methods: manual data entry, data entry with Excel spreadsheet, and Web Services. EPA provided three organizations with the ICR’s burden estimates and asked if they are reasonable.^⁴,
⁵The organizations discussed their experiences and burdens using the tool. One respondent agreed with the ICR’s burden estimates for new benchmarks using manual data entry and two respondents thought that new manual data entry should take less time; to be conservative, EPA did not revise its estimate. Two respondents agreed with the ICR’s burden estimate for repeat manual data entry, while one thought it should take less time. Given their input, EPA did not revise its estimate.

Two respondents agreed with the ICR’s burden estimate for new data entry with Excel spreadsheet, while one thought it should take less time. Given their input, EPA did not revise its estimate. Two respondents agreed with the ICR’s burden estimate for repeat data entry with Excel spreadsheet, while one thought it should take less time. Given their input, EPA did not revise its estimate.

Two respondents agreed with the ICR’s burden estimate for new data entry with Web Services, while one thought it should take less time. Given their input, EPA did not revise its estimate. One respondent agreed with the ICR’s burden estimate for repeat data entry with Web Services, while one thought it should take less time and another thought it should take more time. Given their input, EPA did not revise its estimate.

ENERGY STAR Certification: The ICR estimates the burden for licensed professionals (LPs) to perform facility data reviews under the ENERGY STAR certification program. An applicant’s in-house LP can perform the review or it can contract an external LP. EPA asked the organizations for input on the cost to contract an external LP. Two organizations offered estimates of $1,200, and one offered an estimate of $700. Given their input and EPA’s understanding of industry practices and costs, the Agency believes $1,200 per building is a reasonable estimate and has not changed it in this ICR.⁶

PAYMENTS OR GIFTS TO RESPONDENTS

Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

The EPA ENERGY STAR Program does not provide any payment or gift to respondents.

PROVISIONS FOR PROTECTION OF INFORMATION

Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.

Participation in the ENERGY STAR program is voluntary and may be terminated by participants or EPA at any time. If a claim of confidential business information (CBI) is asserted, EPA will manage that information in accordance with EPA’s provisions on confidentiality. 40 CFR Part 2, Subpart B establishes EPA’s general policy on the public disclosure of information and procedures for handling CBI claims.

JUSTIFICATION FOR SENSITIVE QUESTIONS

Provide additional justification for any questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the Agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

No questions of a sensitive nature are asked of participants under the ENERGY STAR program.

ESTIMATE OF RESPONDENT BURDEN HOURS & LABOR COSTS

Provide estimates of the hour burden of the collection of information. The statement should:

Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Generally, estimates should not include burden hours for customary and usual business practices.
If this request for approval covers more than one form, provide separate hour burden estimates for each form and the aggregate the hour burdens.
Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included as O&M costs under non-labor costs covered under question 13.

The information collections under this ICR are organized into three categories: 1) Joining the ENERGY STAR Program And Related Activities; 2) Benchmarking; and 3) Recognition. Each category is then further subdivided into data items and respondent activities. The section identifies the sector (i.e., private and/or public sector) that is expected to carry out each collection (see the heading introducing each collection). This section also describes the information collections under this ICR, including data items and respondent activities.

1) JOINING THE ENERGY STAR PROGRAM AND RELATED ACTIVITIES

Organizations interested in joining the ENERGY STAR program may be asked to submit a Partnership Agreement. They also may be asked to undertake related activities, as described below.

Commercial and Industrial Sector Partners (Private and Public Sector)

In order to join ENERGY STAR, organizations in the commercial and industrial sectors are asked to complete and submit a Partnership Agreement to EPA.⁷ These Partners agree to measure and track the energy performance of their organization’s facilities where possible by using tools such as those offered through ENERGY STAR; develop and implement a plan consistent with the ENERGY STAR Energy Management Guidelines to achieve energy savings; help spread the word about the importance of energy efficiency to their staff and community; and highlight their achievements with recognition offered through ENERGY STAR.

Data items

A Partnership Agreement that includes the following information:
- Organization’s name;
- Contact information on organization’s Chief Executive;
- Contact information on organization’s Energy Manager;
- Contact information on organization’s Communications Contact (if applicable);
- Description of organization’s primary business or function (i.e., a checklist);
- Total amount of employees employed by the organization in the United States;
- Total number of properties;
- Description of the types of properties managed by the organization;
- Whether or not the organization is a small business;
- Estimated number of new buildings in the next 2 years;
- Total amount of building/facility square footage owned, leased, and/or managed; and
- Brief explanation of how organization learned about ENERGY STAR.

Respondent activities

To join ENERGY STAR, organizations are asked to:

Complete and submit the Partnership Agreement online; and
Respond to EPA follow-up questions, if any.

Service and Product Providers (Private Sector)

An organization must meet certain eligibility requirements before applying to become a Service and Product Provider (SPP) Partner.⁸ Applicants must demonstrate that they have actively used the ENERGY STAR approach to help clients achieve their energy management goals as specified.

SPPs serving the existing commercial buildings market must benchmark at least 10 client commercial buildings in the last 12 months using Portfolio Manager and/or earn the ENERGY STAR certification for at least one client commercial building using Portfolio Manager and meet other program requirements. [Note that this ICR addresses benchmarking activities in the section, “Benchmarking,” under the heading, “Portfolio Manager.” This ICR addresses earning the ENERGY STAR in the section, “Recognition,” under the heading, “ENERGY STAR Certification.”]
SPPs serving the commercial new construction market must submit at least one commercial building design project that achieved Designed to Earn the ENERGY STAR in the last 12 months. [Note that this ICR addresses applying for the Designed to Earn the ENERGY STAR in the section, “Recognition,” under the heading, “Designed to Earn the ENERGY STAR.”]

SPPs serving the industrial market must work with an ENERGY STAR industrial Partner on at least one energy efficiency project or on an ENERGY STAR Plant Certification or Challenge for Industry in the last two years and submit a Teaming Profile to EPA outlining the project scope and resulting savings for that project.

SPPs interested in joining ENERGY STAR are asked to complete and submit a Partnership Agreement to EPA using an online system. The Partnership Agreement requests SPP company information, contact information, and select pieces of information to enable automated verification that Partnership requirements have been met. The Partnership Agreement also lays out Partner commitments, disclaimers, procedures for dispute resolution, and other issues.

On an annual basis, SPPs may be asked to update contact information (i.e., contact name, phone, email) displayed on select Service and Product Provider listings on the web site and to maintain quality of contact mailing lists.

Data items

A Partnership Agreement to be completed and submitted online that includes the following information:

Applicant company name;
Information about the company, such as web address and markets/sectors that the organization serves and services available;
Name, title, and contact information of the primary contact, communications contact, and signatory of the Partnership Agreement; and
For Existing Commercial Buildings SPPs only, information about SPP activities over the past 12 months (i.e., Portfolio Manager building ID numbers to complete automated verification of activity); or
For architecture/engineering firms only, information about Commercial New Construction SPP activities (i.e., Designed to Earn the ENERGY STAR of project achieving Designed to Earn the ENERGY STAR); or
For Industrial SPP only, information about SPP activities (i.e., Teaming Profile outlining the project scope and resulting savings for that project).

Additional communications items that SPP Partner may elect to submit:

One-page success story for web site posting to demonstrate successful projects or relationships with commercial and institutional clients, or exemplary use of ENERGY STAR tools.
Communications about SPP efforts for feature in quarterly newsletters or other medium, at EPA discretion.

Respondent activities

To join ENERGY STAR, organizations are asked to:

Complete and submit the Partnership Agreement online; and
Complete and submit requested materials for the appropriate partnership category (e.g., Statement of Energy Design Intent, Teaming Profile) online.

SPP Partners are asked to:

Update contact information as needed by notifying program account manager of any changes and/or using the “My ENERGY STAR Account” tool; and
Communicate efforts and successes to ENERGY STAR and the broader market through success stories and other communications.

Energy Efficiency Program Sponsors (Private and Public Sector)

Energy Efficiency Program Sponsors (EEPS) interested in joining ENERGY STAR are asked to complete and submit a Partnership Agreement.⁹^,¹⁰ They commit to promote and use ENERGY STAR in a manner consistent with the national ENERGY STAR efforts and specifically agree to follow all applicable terms and conditions governing the use of the ENERGY STAR logos, which are registered trade and service marks. Some Partners will be asked on an annual basis to update organization and contact information displayed on the ENERGY STAR web site and the Directory of Energy Efficiency Programs (DEEP). The Partners also agree to promote energy efficiency as an easy and desirable option for organizations and consumers to prevent pollution, protect the global environment, and save on energy bills.

Data items

Partnership Agreement.
Updates to organization, program, and contact information displayed on the ENERGY STAR web site and the Directory of Energy Efficiency Programs (DEEP).
Information to promote energy efficiency as an easy and desirable option for organizations and consumers to prevent pollution, protect the global environment, and save on energy bills.

Respondent activities

To join ENERGY STAR, organizations are asked to complete and submit a Partnership Agreement.

EEPS also agree to:

Update organization and contact information displayed on the ENERGY STAR web site and the Directory of Energy Efficiency Programs (DEEP) semi-annually; and
Provide information to promote energy efficiency as an easy and desirable option for organizations and consumers to prevent pollution, protect the global environment, and save on energy bills.

2) BENCHMARKING

Assessing energy use is a critical component of the ENERGY STAR program and guidance provided by EPA to Partners. EPA provides tools to track, measure and compare energy use for a range of building types and facilities. Portfolio Manager is the primary tool for undertaking these activities and is available online at https://www.energystar.gov/portfoliomanager.

Portfolio Manager (Private and Public Sector)

Portfolio Manager is an interactive energy management tool that allows users to track and assess energy and water consumption across their entire portfolio of facilities in a secure online environment. Users enter energy consumption and cost data into their Portfolio Manager account to benchmark facility energy performance, assess energy management goals over time and identify strategic opportunities for savings and recognition opportunities. A “benchmark” is defined as a measurement of a facility’s energy performance resulting from entering facility information and at least 12 consecutive months of facility energy data into EPA’s Portfolio Manager. Portfolio Manager offers multiple types of benchmarks: the 1-100 ENERGY STAR energy performance score for select commercial facility types, site and source Energy Use Intensity (EUI) for all commercial facility types, weather normalized energy values, greenhouse gas emissions, water consumption, annual energy and water costs, and materials and waste management.

The ENERGY STAR scale accounts for the impacts of year-to-year weather variations, as well as facility size, location, and several operating characteristics. Portfolio Manager helps the user update and track data over time to continuously monitor performance. The user can use both short- and long-term trends in energy performance to make budget and management decisions regarding investments in energy-related projects.

In addition, EPA intends to collect information from Portfolio Manager users on its usability as a web-based tool and on the effectiveness of Portfolio Manager guidance. Based on this information, EPA will identify and make needed improvements.

Data items

Information entered into Portfolio Manager:

Contact information;
Facility data (e.g., name, address, year constructed);
Facility operating characteristics (e.g., gross facility area, number of occupants, operating hours, number of PCs);
Energy use information (e.g., meter name, usage data);
Water use information – optional (e.g., meter name, usage data); and
Materials and waste management/disposal information – optional (e.g., meter/waste type name, disposal quantity).

Information provided to EPA on the usability of Portfolio Manager and effectiveness of guidance.

Respondent activities

Organizations using the benchmarking feature of the Portfolio Manager system perform the following activities:

Review the instructions of Portfolio Manager and set up account;
Gather facility and energy data; and
Enter the data into Portfolio Manager.

[Note: Users have several options for entering facility and energy data into Portfolio Manager. These options and associated burden are described in Section 6(d) of this document.]

Organizations may be asked to respond to EPA questions on the usability and functionality of Portfolio Manager.
Organizations may be asked to respond to EPA questions about guidance or trainings on benchmarking.

Data Collection for Model Development and Beta Testing (Private and Public Sector)

Occasionally during the development, modification or testing of Portfolio Manager or other tool, EPA may collect information about annual energy use (one year’s worth of energy data), along with basic information about facility operations, such as the operating hours or number of workers.

Data items

Information collected from participating organizations:

Contact information;
Facility data (e.g., name, address, year constructed);
Facility operating characteristics (e.g., gross facility area, number of occupants, operating hours, number of PCs);
Energy use information (e.g., meter name, usage data); and
Water use information (e.g. meter name, usage data).

Respondent activities

Organizations may be asked to:

Review the instructions of Portfolio Manager or spreadsheet;
Gather facility and energy data; and
Enter the data into Portfolio Manager or spreadsheet.

3) RECOGNITION

ENERGY STAR Certification and ENERGY STAR NextGen Certification for Buildings (Private and Public Sector)

EPA offers the public an opportunity to display the ENERGY STAR on their buildings if they meet certain energy performance criteria defined by EPA. The online application for the ENERGY STAR is submitted through EPA’s benchmarking tool, Portfolio Manager. To be approved to receive the ENERGY STAR, buildings must meet specific eligibility requirements as well as industry standards for comfort and indoor air quality. A Professional Engineer or Registered Architect must verify that these requirements have been met and the Application for ENERGY STAR Certification (stamped/embossed and signed) is submitted. [Note that this ICR addresses applicant benchmarking activities in the section, “Benchmarking,” under the heading, “Portfolio Manager.”

In addition, EPA conducts audits on a small percentage of applications for quality control purposes. EPA confirms, for example, the accuracy of the information provided in the application for the ENERGY STAR and may request facility documentation.

EPA also expects to periodically contact representatives of buildings that have earned the ENERGY STAR to collect information about the characteristics of buildings that lead to top energy performance and their reasons for benchmarking. This includes information on the buildings’ construction, equipment used in the buildings, building management, and involvement in ENERGY STAR. EPA will use this information to better understand the specific design, construction, and operating characteristics of ENERGY STAR certified buildings and how these characteristics contributed to the buildings’ top energy performance. In addition, EPA intends to collect information about the qualification process to measure how easy it is for organizations to use. EPA needs this information to identify and make improvements to the process that buildings use to qualify for the ENERGY STAR.

EPA has proposed a new recognition offering, called ENERGY STAR NextGen Certification, and plans to make it available to U.S. commercial buildings in 2024. ENERGY STAR NextGen will add criteria for use of renewable energy and electrification to the energy performance criteria for ENERGY STAR certification.

Data items

Application for ENERGY STAR (/NextGen) Certification.
Audit information requested by EPA as part of its application review or quality control audit:

ENERGY STAR (/NextGen) Certification Audit Form;
Indoor Environmental Quality Measurement Form for ENERGY STAR Building Verification Site Visit; and
ENERGY STAR (/NextGen) Certification Use Detail Verification Form

Information provided to EPA for analysis of ENERGY STAR (/NextGen) certified buildings.

Respondent activities

Organizations applying for the ENERGY STAR or ENERGY STAR NextGen perform the following:

Engage a Professional Engineer or Registered Architect to conduct a facility data review, complete and stamp the application;¹¹and
Complete and submit the online application to EPA and respond to EPA questions if any.

Some organizations may be asked to complete forms as part of a quality control audit performed by EPA on a percentage of applications.
ENERGY STAR (/NextGen) certified buildings may be asked to respond to EPA questions for analysis of ENERGY STAR (/NextGen) certified buildings.

ENERGY STAR Certification for Plants (Private Sector)

Industrial companies have an opportunity to earn the ENERGY STAR certification for specific types of plants that meet EPA’s energy efficiency criteria. To measure efficiency and improve energy use in the company, a company enters basic information about its plant (e.g., energy consumption data) into a spreadsheet tool called the Energy Performance Indicator (EPI), which can be downloaded from EPA’s ENERGY STAR web site. The EPI produces a plant percentile score between 1 and 100 and compares that score to the most energy-efficient plants in the industry and to the previous performance for the plant.

If the plant’s EPI score is in the top quartile of the industry’s energy performance scale, the company can apply for the ENERGY STAR certification by printing out a Statement of Energy Performance (SEP). A Professional Engineer (PE) verifies, signs, and stamps the SEP, and completes the PE Verification Checklist. The EPI, certified SEP, PE Verification Checklist, Plant Award Specification Sheet, and Plant Award Application Letter are sent to EPA. If the submittal contains confidential business information (CBI), the company sends the information to EPA’s contractor to verify energy performance results. If approved by EPA, the plant receives the ENERGY STAR certification.

Some companies may submit a profile of their certified plant that describes how the plant improved its energy performance and obtained recognition. This submission is optional.

Data items

Information entered into the EPI or alternative tracking system:

Plant characteristics; and
Energy consumption.

Statement of Energy Performance.
PE Verification Checklist.
Plant Award Specification Sheet.
Plant Award Application Letter.

Profile of certified plant. This is optional.

Respondent activities

Organizations seeking plant certification perform the following:

Enter information into the EPI or alternative system; and
Complete and submit the application materials to EPA.

Some organizations may also prepare and submit a profile of a certified plant. This is optional.

ENERGY STAR Challenge for Industry (Private Sector)

EPA has established a tool, the ENERGY STAR Challenge for Industry (Challenge), which encourages companies to pledge to reduce the energy intensity of their sites by 10% within five years and track their progress towards this goal using a tracking system (e.g., company in-house tracking systems, Portfolio Manager, EPA’s Energy Tracking Tool). Sites that achieve a 10% reduction in energy intensity within five years of their baseline have the opportunity to apply for recognition from EPA.

Companies are asked to register their sites’ baseline energy intensity to participate in the Challenge. Sites that have not achieved recognition in the past (e.g., first-time participants) are asked to complete the online Challenge for Industry Registration Form. Sites that have achieved recognition can re-register by checking a box on the online Challenge for Industry Recognition Application. They do not need to complete the registration form again.

Each site completes the online Challenge for Industry Recognition Application and fills out a Statement of Energy Improvement (SEI). A Professional Engineer (PE) verifies, prints, signs, and stamps the SEI and completes a PE Verification Checklist, which are both then sent via email to EPA. If approved by EPA, the site receives recognition (e.g., a certificate, congratulatory letter to the CEO).

EPA may ask follow-up questions of companies whose sites achieved recognition (e.g., for program evaluation).

Data items

Challenge for Industry Registration Form.
Challenge for Industry Recognition Application.
Statement of Energy Improvement (SEI).
PE Verification Checklist.

Responses to EPA follow-up questions, if any.

Respondent activities

Organizations seeking recognition under the ENERGY STAR Challenge for Industry perform the following:

Prepare and submit the online Challenge for Industry Registration Form if necessary;
Track energy use;
Prepare and submit the online Challenge for Industry Recognition Application, SEI and PE Verification Checklist; and
Respond to EPA follow-up questions, if any.

Designed to Earn the ENERGY STAR (Private Sector)

To seek Designed to Earn the ENERGY STAR (DEES) recognition, an organization is asked to become an ENERGY STAR Partner as an initial step. [Note that this ICR addresses organizations’ becoming a Partner in the section, “Joining the ENERGY STAR Program and Related Activities,” under the heading, “Commercial and Industrial Sector Partners.”] Then, an organization can enter information into EPA’s online tool, Portfolio Manager, and follow simple user prompts to save and generate information needed for the application. The tool can be used to obtain an ENERGY STAR score of 1 – 100 to determine if the design project’s estimated annual energy use meets criteria for DEES recognition.

The organization then generates a Statement of Energy Design Intent (SEDI). The SEDI is printed, stamped, and signed by a Registered Architect or Professional Engineer and Architect of Record (AOR) and building owner/developer representatives. It is then submitted to EPA for recognition. Once the application is approved, EPA will email instructions to organizations that meet the DEES recognition criteria so they can download the DEES graphic.

Data items

Data entered into Portfolio Manager (e.g., property use data).
Statement of Energy Design Intent.

[Note: Organizations seeking recognition for commercial new construction design projects are asked to submit the data items above. Organizations seeking recognition for multifamily new construction design projects are asked to submit the data items above, as well as to submit additional documents that are addressed in EPA ICR 2193, “EPA’s ENERGY STAR Program in the Residential Sector” (OMB Control No. 2060-0586).]

Respondent activities

Organizations submitting a DEES application perform the following activities:

Review application instructions and create account in Portfolio Manager, if needed;
Gather design data and estimated annual energy use data;
Enter the data into Portfolio Manager; and
Complete and submit DEES application consisting of SEDI and, for commercial design projects, Letters of Intent from the Architect of Record (AOR) and building owner to EPA.

ENERGY STAR Awards (Private and Public Sector)

Organizations interested in receiving recognition for their efforts in improving their energy performance may apply for an ENERGY STAR Award. EPA currently issues awards to Commercial and Industrial (C&I) Sector Partners, Service and Product Providers (SPPs), and Energy Efficiency Program Sponsors (EEPS).

Data items

Information provided by C&I Partners:

General information (e.g., contact information, address, signed/dated); and
Description of the following:

Management practices (e.g., best practices for managing energy).
Organization-wide improvements in energy performance.
Efforts in promoting and communicating success.
Organization efforts towards building decarbonization.

Information provided by SPPs:

General information (e.g., contact information, address, and signed/dated certification); and
Description of the following:

Organization and Business Practices.
Benchmarking and Certification (Existing Buildings).
Energy Efficiency Design (Design Projects).
Integration of ENERGY STAR into Client Services.
Marketing and Recognition.

Information provided by EEPS:

General information (e.g., contact information, address, and signed/dated certification); and
Description of the following:

Category(-ies) that the EEPS program is designed to address (e.g., energy improvements in the C&I sector).
Program design (e.g., in terms of goals).
How ENERGY STAR has been incorporated into the Partner’s initiative.
Market effects resulting from Partner’s efforts.
Data sources used to support market claims.

Respondent activities

Organizations that apply for an award are asked to:

Review the instructions; and
Complete and submit the information online.

Tenant Recognition Program (Private Sector)

In April 2015, Congress passed the Energy Efficiency Improvement Act of 2015. This legislation mandates EPA to develop a voluntary recognition program for commercial tenants in buildings. Tenants are encouraged to design, build and operate their spaces to be energy efficient. EPA recognizes tenants who meet EPA’s energy efficiency criteria for the design, build-out and operation of energy efficient tenant spaces.

To apply for recognition, a tenant establishes an account in Portfolio Manager. [Note that this ICR addresses setting up Portfolio Manager accounts in the section, “Benchmarking,” under the heading, “Portfolio Manager.”] The tenant then gathers and enters data (e.g., space characteristics, lighting inventory) into the tool. If the energy efficiency criteria are met, an application is generated by the tool. A Professional Engineer or Registered Architect reviews, verifies and stamps the application. It then can be signed and uploaded to EPA. The Agency reviews it and provides recognition if warranted. Some participants may be contacted by EPA to answer questions about their submission, if needed.

Data items

Information entered in Portfolio Manager:

Space characteristics (e.g., operating hours, number of workers);
Equipment inventory (e.g., types of equipment);
Copy of organization’s procurement policy;
Lighting inventory (e.g., type, number and wattage of lighting fixtures); and
Information on energy meters.

Responses to EPA follow-up questions, if any.

Respondent activities

Tenants seeking recognition perform the following:

Gather and enter data into Portfolio Manager;
Complete and submit an application for recognition if applicable criteria are met; and
Respond to EPA follow-up questions, if any.

Collection Schedule

No information collection in this ICR requires collection more frequently than quarterly. Many collections are implemented on a one-time or annual basis. Respondents may voluntarily submit information more frequently.

Estimating Labor Costs

Exhibits 1-3 represent the three primary categories introduced above and estimate the annual respondent burden hours and costs for information collection activities associated with the ENERGY STAR program in the commercial and industrial sectors. Table 1 presents the total annual hours and costs to respondents under all activities. Specific cost assumptions are discussed below.

EPA estimates an average hourly respondent labor cost ($2022) of $120.39/hr for legal staff, $93.73/hr for managerial staff, $51.54/hr for technical staff, and $33.41/hr for clerical staff. To derive these hourly estimates, EPA referred to the May 2021 National Occupational Employment and Wage Estimates published by the U.S. Bureau of Labor Statistics.¹² This publication summarizes the unloaded (base) hourly rate for major occupational groups.¹³ EPA then applied the standard government overhead factor of 1.6 to the unloaded rate to derive loaded hourly rates. Finally, EPA updated the loaded hourly rates to December 2022 levels using Employment Cost Indexes developed by the U.S. Bureau of Labor Statistics.¹⁴

Estimating the Respondent Universe

In this section, EPA describes its estimates of the number of respondents carrying out the information collections under the ENERGY STAR program in the commercial and industrial (C&I) sectors. In developing its estimates, EPA referred to its databases and other documentation in order to understand historical trends in the number of new and existing respondents. Based on this understanding, EPA has estimated the average annual number of respondents associated with each of the information collections under the program.

In total, EPA estimates 42,020 organizations participate under the ENERGY STAR program in the commercial and industrial sectors annually. In deriving this estimate, EPA ascertained the annual number of users of its online tool, Portfolio Manager (41,500 organizations). EPA notes that most respondents in this ICR use the tool during the year and are therefore captured in this estimate. For example, organizations seeking recognition (e.g., under ENERGY STAR certification for buildings) benchmark their buildings in Portfolio Manager and are therefore reflected in the estimate. Therefore, to avoid double-counting, EPA next identified organizations not captured in the 41,500-organization estimate. EPA estimates that 520 organizations carry out collections that do not involve the tool. Most of the 520 organizations are industrial plants that use the EPI or other tool instead of Portfolio Manager to track their energy performance.

EXHIBIT 1: JOINING THE ENERGY STAR PROGRAM AND RELATED ACTIVITIES

Commercial and Industrial Sector Partners

EPA estimates that, on average, 150 organizations in the commercial and industrial sectors will submit a Partnership Agreement to EPA each year, of which 15 to 20 will be industrial organizations. EPA may ask Partners follow-up questions.

Service and Product Providers

EPA estimates that, on average, 35 SPPs will submit a Partnership Agreement to EPA each year through an online system. These SPPs will also submit requested materials for their appropriate category (e.g., Teaming Profiles from Industrial SPPs). In addition, EPA estimates that, on average, 200 existing SPPs will update their contact information and 75 existing SPPs will communicate their efforts and successes to EPA annually.

Energy Efficiency Program Sponsors

EEPS are given the opportunity to join one or more programs within ENERGY STAR (e.g., C&I, Products) when they complete and submit their Partnership Agreement. The ICR, “EPA’s ENERGY STAR® Product Labeling” (EPA ICR No. 2078, OMB Control Number 2060-0528), consolidates the burden for the EEPS Partnership Agreement across all ENERGY STAR programs. As such, this ICR (EPA ICR 1772.09) does not estimate the burden for EEPS Partnership Agreements.

EPA estimates that, on average, 60 existing EEPS will actively participate in the program, update contact information on the ENERGY STAR web site and DEEP and provide information to promote energy efficiency as an easy and desirable option for organizations and consumers to prevent pollution, protect the global environment, and save on energy bills.

Exhibit 1*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Joining the ENERGY STAR Program and Related Activities

	Hours and Costs Per Respondent per Activity								Total Hours and Costs
	Legal	Managerial	Technical	Clerical	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Information Collection Activity	$120.39	$93.73	$51.54	$33.41	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Commercial and Industrial Sector Partners
Partnership Agreement
Complete and submit the Partnership Agreement online	0.00	0.25	0.25	0.00	0.50	$36.32	$0.00	$0.00	150.00	75.00	$5,448.00
Respond to EPA follow-up questions, if any	0.00	0.00	0.25	0.00	0.25	$12.89	$0.00	$0.00	25.00	6.25	$322.25
Subtotal (for Commercial and Industrial Sector Partners)	0.00	varies	varies	0.00	varies	varies	$0.00	$0.00	varies	81.25	$5,770.25
Service and Product Providers
Partnership Agreement
Complete and submit the Partnership Agreement online	0.00	0.50	0.50	0.00	1.00	$72.64	$0.00	$0.00	35.00	35.00	$2,542.40
Complete and submit requested materials for appropriate partnership category	0.00	0.00	0.07	0.00	0.07	$3.61	$0.00	$0.00	35.00	2.45	$126.35
Subtotal	0.00	0.50	0.57	0.00	1.07	$76.25	$0.00	$0.00	70.00	37.45	$2,668.75
Related Activities
Update contact information as needed	0.00	0.00	0.16	0.00	0.16	$8.25	$0.00	$0.00	200.00	32.00	$1,650.00
Communicate efforts and successes	0.00	0.50	0.50	0.00	1.00	$72.64	$0.00	$0.00	75.00	75.00	$5,448.00
Subtotal	0.00	varies	varies	0.00	varies	varies	$0.00	$0.00	varies	107.00	$7,098.00
Subtotal (for Service and Product Providers)	varies	varies	varies	varies	varies	varies	$0.00	$0.00	varies	144.45	$9,766.75
Energy Efficiency Program Sponsors
Partnership Agreement
Organizations Submitting Entire Partnership Agreement
Complete and submit the Partnership Agreement	0.50	0.25	0.75	0.00	1.50	$122.28	$0.00	$0.00	0.00	0.00	$0.00
Organizations Submitting Updated Participation Forms Only
Update and submit Participation Forms online	0.00	0.00	0.00	0.08	0.08	$2.67	$0.00	$0.00	0.00	0.00	$0.00
Subtotal	varies	varies	varies	varies	varies	varies	$0.00	$0.00	0.00	0.00	$0.00
Related Activities
Update organization and contact information displayed on the Web site and DEEP	0.00	0.00	0.00	0.08	0.08	$2.67	$0.00	$0.00	60.00	4.80	$160.20
Provide information to promote ENERGY STAR in the commercial and/or industrial markets	0.00	0.10	2.00	0.15	2.25	$117.46	$0.00	$0.00	60.00	135.00	$7,047.60
Subtotal	0.00	0.10	2.00	0.23	2.33	$120.13	$0.00	$0.00	120.00	139.80	$7,207.80
Subtotal (for Energy Efficiency Program Sponsors)	varies	varies	varies	varies	varies	varies	$0.00	$0.00	varies	139.80	$7,207.80
TOTAL	varies	varies	varies	varies	varies	varies	$0.00	$0.00	varies	365.50	$22,744.80

*Exhibit contains rounding.

EXHIBIT 2: BENCHMARKING

Portfolio Manager

To estimate Portfolio Manager’s burden, EPA collected and analyzed historical data about the tool, including the annual number of new and active accounts and buildings benchmarked.¹⁵ EPA collected data on the three benchmarking methods offered by the tool: manual data entry, data entry with Excel spreadsheet, and data entry using Electronic Web Services. EPA entered the data into an Excel -based model to estimate total annual burden. Table 1 below presents the annual number of new and active accounts and benchmarked buildings estimated over the next three years.

Table 1

The model used the data in Table 2 to estimate the burden of each benchmarking method, as discussed below:

Manual Data Entry. EPA estimates that, each year, 22,200 users will read the instructions and set up an account in Portfolio Manager to benchmark their buildings manually. In addition, EPA estimates that 44,000 buildings will be manually benchmarked annually, on average. Of these, EPA estimates that users will benchmark 50% (22,000) by gathering facility and energy data for their buildings not using standard industry practices. EPA estimates that users will benchmark 50% (22,000) by gathering facility and energy data for their buildings using standard industry practices (i.e., usual and customary business practices that would be conducted even in the absence of ENERGY STAR). These practices could include, for example, compiling and keeping readily available, centralized paper and/or electronic records (e.g., invoices, facility data) for their portfolio of buildings. Users who employ such standard industry practices would generally incur a lower incremental burden than others to gather data for Portfolio Manager. All users will enter the data into Portfolio Manager to benchmark their buildings. Finally, of the 44,000 buildings benchmarked, EPA estimates that 16% (7,040) are new benchmarks (i.e., buildings benchmarked for the first time) and 84% (36,960) are repeats.

Exhibit 2 includes weighted-average burden estimates for gathering and entering data into Portfolio Manager to account for standard business practices as well as new and repeat benchmarks. See the table below for the inputs used in these weighted-average calculations.

Table 2

Data Entry with Excel Spreadsheet. EPA estimates that, each year, 300 new accounts will be created to provide their data to EPA through an Excel spreadsheet. The data will be uploaded into Portfolio Manager. In addition, EPA estimates that 16,000 buildings will be benchmarked annually using this method. Of these, EPA estimates that 44% (7,040) are new benchmarks (i.e., buildings benchmarked for the first time) and 56% (8,960) are repeats.

Table 3

Exhibit 2 includes weighted-average burden estimates for gathering and entering data into Portfolio Manager to account for new and repeat benchmarks. See the table below for the inputs used in these weighted-average calculations.

Data Entry using Electronic Web Services. EPA expects that 85 new providers will use this benchmarking method each year. EPA estimates that new accounts also will be established for 1,200 customers each year. In addition, EPA estimates that information will be gathered and entered into Portfolio Manager for 305,000 buildings annually. Of these, EPA estimates that 12% (36,600) are new benchmarks (i.e., buildings benchmarked for the first time) and 88% (268,400) are repeats.

Table 4

Further, EPA estimates that, each year, it will ask 50 users of Portfolio Manager about the usability of the tool. It will also ask 50 users for feedback about the guidance or training on the tool each year.

Data Collection for Model Development and Beta Testing

EPA expects to expand Portfolio Manager or the Energy Performance Indicator (EPI) downloadable spreadsheet tools by adding new facility types and revising existing types. In doing so, the Agency may need to gather information for model development and/or beta testing to make sure the tool produces relevant results. EPA expects that organizations will submit information on 950 properties annually.

Exhibit 2*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Benchmarking

	Hours and Costs Per Respondent per Activity								Total Hours and Costs
	Legal	Managerial	Technical	Clerical	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Information Collection Activity	$120.39	$93.73	$51.54	$33.41	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Portfolio Manager
Set Up of New Accounts
New Accounts using Manual Entry – Review instructions in Portfolio Manager and set up account	0.00	0.00	0.50	0.00	0.50	$25.77	$0.00	$0.00	22,200.00	11,100.00	$572,094.00
New Accounts using Spreadsheet upload – Review instructions in Portfolio Manager and set up account	0.00	0.00	1.00	0.00	1.00	$51.54	$0.00	$0.00	300.00	300.00	$15,462.00
New Providers using Data Exchange – Review instructions and set up account and automated process	0.00	0.00	250.00	0.00	250.00	$12,885.00	$0.00	$0.00	85.00	21,250.00	$1,095,225.00
New Accounts using Data Exchange – Conduct initial customer set-up	0.00	0.00	1.40	0.00	1.40	$72.16	$0.00	$0.00	1,200.00	1,680.00	$86,592.00
Subtotal	0.00	0.00	varies	0.00	varies	varies	$0.00	$0.00	varies	34,330.00	$1,769,373.00
Manual Data Entry (per building)
Gather facility and energy data	0.00	0.00	0.80	0.00	0.80	$41.23	$0.00	$0.00	44,000.00	35,200.00	$1,814,120.00
Enter data into Portfolio Manager	0.00	0.00	0.30	0.00	0.30	$15.46	$0.00	$0.00	44,000.00	13,200.00	$680,240.00
Subtotal	0.00	0.00	varies	0.00	varies	varies	$0.00	$0.00	44,000.00	48,400.00	$2,494,360.00
Data Entry using Excel Spreadsheet (per building)
Gather facility and energy data	0.00	0.00	1.00	0.00	1.00	$51.54	$0.00	$0.00	16,000.00	16,000.00	$824,640.00
Enter Data in Portfolio Manager/Spreadsheet	0.00	0.00	0.20	0.00	0.20	$10.31	$0.00	$0.00	16,000.00	3,200.00	$164,960.00
Subtotal	0.00	0.00	varies	0.00	varies	varies	$0.00	$0.00	16,000.00	19,200.00	$989,600.00
Data Entry using Electronic Web Services (per building)
Gather facility and energy data	0.00	0.00	0.10	0.00	0.10	$5.15	$0.00	$0.00	305,000.00	30,500.00	$1,570,750.00
Submit information to EPA monthly and retrieve/relay scores to customers	0.00	0.00	0.10	0.00	0.10	$5.15	$0.00	$0.00	305,000.00	30,500.00	$1,570,750.00
Subtotal	0.00	0.00	varies	0.00	varies	varies	$0.00	$0.00	305,000.00	61,000.00	$3,141,500.00
Evaluation of Portfolio Manager
Respond to questions about usability of tool	0.00	0.00	0.25	0.00	0.25	$12.89	$0.00	$0.00	50.00	12.50	$644.50
Respond to questions about training on tool	0.00	0.00	0.17	0.00	0.17	$8.76	$0.00	$0.00	50.00	8.50	$438.00
Subtotal	0.00	0.00	varies	0.00	varies	varies	$0.00	$0.00	varies	21.00	$1,082.50
Subtotal (for Portfolio Manager)	0.00	0.00	varies	0.00	varies	varies	$0.00	$0.00	varies	162,951.00	$8,395,915.50
Data Collection for Model Development and Beta Testing
Review instructions of Portfolio Manager or spreadsheet	0.00	0.00	0.14	0.00	0.14	$7.22	$0.00	$0.00	950.00	133.00	$6,859.00
Gather facility and energy data	0.00	0.00	1.79	0.00	1.79	$92.26	$0.00	$0.00	950.00	1,700.50	$87,647.00
Enter data into Portfolio Manager or spreadsheet	0.00	0.00	0.32	0.00	0.32	$16.49	$0.00	$0.00	950.00	304.00	$15,665.50
Subtotal (for Information for Model Development and Beta Testing)	0.00	0.00	2.25	0.00	2.25	$115.97	$0.00	$0.00	950.00	2,137.50	$110,171.50
TOTAL	0.00	varies	varies	varies	varies	varies	$0.00	$0.00	varies	165,088.50	$8,506,087.00

*Exhibit contains rounding.

EXHIBIT 3: RECOGNITION

ENERGY STAR Certification and ENERGY STAR NextGen Certification for Buildings

EPA estimates that organizations will submit 7,500 applications for either ENERGY STAR Certification or ENERGY STAR NextGen Certification each year, with 12.5% (938) being applications for ENERGY STAR NextGen Certification. These organizations must benchmark the building, engage a Professional Engineer or Registered Architect to conduct a facility data review, and submit an online Application for ENERGY STAR Certification or ENERGY STAR NextGen Certification to EPA [Note that this ICR burdens participants for benchmarking in the section, “Benchmarking,” under the heading, “Portfolio Manager.” See Exhibit 2.] EPA estimates that 85% will contract a Professional Engineer or Registered Architect and 15% will use an in-house Professional Engineer or Registered Architect to perform the facility review.^¹⁶ Further, in the spring of 2018, EPA clarified that on-site property reviews can be performed every other year (instead of annually) for buildings that apply for ENERGY STAR Certification in consecutive years. For ENERGY STAR NextGen Certification, however, on-site property reviews should be performed annually for buildings that apply in consecutive years. Because of this, EPA estimates that 4,200 facility reviews will be performed by a contracted Professional Engineer or Registered Architect and 750 property reviews by an in-house Professional Engineer or Registered Architect annually.

In addition, EPA estimates that, each year, it will ask for additional information from up to 210 applications for ENERGY STAR Certification, and 30 applications for ENERGY STAR NextGen Certification as part of its quality control audits, for a total of 240 requests.

EPA also expects to contact representatives of buildings that have earned ENERGY STAR Certification to collect information about the characteristics of buildings that lead to top energy performance. EPA will also collect information about the qualification process to measure how easy it is for organizations to use. EPA intends to contact no more than 80 representatives annually.

ENERGY STAR Certification for Plants

EPA estimates that industrial companies will seek ENERGY STAR certification for 115 plants annually, on average, during the 3-year life of this ICR. EPA expects all companies, except petroleum companies, to use the Energy Performance Indicator (EPI) to track plant energy performance and generate the Statement of Energy Performance (SEP). EPA estimates this will be done for 115 non-petroleum plants annually.

EPA expects petroleum companies to use a third-party consulting service to measure the energy efficiency of their plants. To request a plant score from the consulting service, a petroleum company is estimated to spend 10 minutes and $3,480 as a flat fee per plant. EPA estimates this will be done for 10 petroleum plants annually.

EPA expects these non-petroleum and petroleum companies to complete the application materials (e.g., Plant Award Specification Sheet, Plant Award Application Letter, PE Checklist, Statement of Energy Performance) and submit them to EPA (115 plants/yr).

EPA estimates that four profiles of certified plants will be submitted annually. Profiles are optional.

ENERGY STAR Challenge for Industry

Companies are asked to register their sites to participate in the Challenge for Industry. EPA estimates that 60 sites will complete the online Challenge for Industry Registration Form annually. A site is asked to complete this form if it has not achieved recognition in the past (e.g., first-time participants). A site that has achieved recognition in the past and is applying again can re-register by checking a box on the online Challenge for Industry Recognition Application. They do not need to complete the registration form again. EPA estimates that 40 sites will re-register using the recognition application annually.

EPA estimates that 40 sites will seek recognition each year by preparing and submitting the application materials. There are two options for completing the Statement of Energy Improvement (SEI). One option is to track energy using an in-house system and then complete the SEI. EPA estimates that these sites use their existing in-house system to track their energy performance as a standard industry practice (i.e., usual and customary business practices that would be conducted even in the absence of ENERGY STAR). EPA does not expect them to incur any incremental burden in tracking their energy performance under the ENERGY STAR Challenge for Industry. EPA estimates that 39 sites will use this option annually.

Another option is to use EPA’s Energy Tracking Tool (ETT) to generate the SEI. Unlike sites that use their existing in-house systems as a standard industry practice, sites using the ETT will incur incremental burden to set up and use the system. EPA estimates that one site will use this option annually.

In addition, all 40 sites are asked to complete the online Challenge for Industry Recognition Application and PE Verification Checklist.

Finally, EPA estimates that, each year, it will contact 33 companies with sites that have achieved the Challenge for Industry, e.g., for program evaluation purposes.

Designed to Earn the ENERGY STAR

EPA estimates that 15 Designed to Earn the ENERGY STAR (DEES) applications will be submitted to EPA each year by organizations seeking recognition for commercial or multifamily high rise (MFHR) new construction design projects. The application process involves reviewing the DEES application instructions and setting up a new account in Portfolio Manager if needed. EPA estimates six first-time applicants will need to perform these activities. In addition, it involves gathering and entering design data into the tool and preparing a DEES application package consisting of a Statement of Energy Design Intent (SEDI). The application is emailed to EPA. [Note: In addition to these documents, organizations with MFHR projects are asked to submit additional documents which are not addressed in this ICR. Rather, they are addressed in EPA ICR 2193, “EPA’s ENERGY STAR Program in the Residential Sector” (OMB Control No. 2060-0586).]

ENERGY STAR Awards

EPA estimates that under the C&I branch, 75 buildings Partners, 20 SPPs, and 15 EEPS will apply for an ENERGY STAR Award each year. Of the 75 C&I Partners, EPA estimates that 39 will apply for a Sustained Excellence Award, which recognizes sustained excellence in energy management in partnership with ENERGY STAR. They submit streamlined application materials.

Tenant Recognition Program

EPA estimates that 300 organizations will establish an account in Portfolio Manager to participate in the program annually. [Note that this ICR addresses setting up Portfolio Manager accounts in the section, “Benchmarking,” under the heading, “Portfolio Manager.”] These organizations will gather and enter data (e.g., equipment and lighting inventory data) into the tool. If the energy efficiency criteria are met, an application is generated by the tool, which is completed by the organization (e.g., reviewed/stamped by a Professional Engineer or Registered Architect) and uploaded to EPA. EPA estimates that 200 applications will be completed and submitted annually. In addition, around 20 participants may be contacted by EPA to answer questions about their submission, if needed.

Exhibit 3*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Recognition

	Hours and Costs Per Respondent per Activity								Total Hours and Costs
	Legal	Managerial	Technical	Clerical	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Information Collection Activity	$120.39	$93.73	$51.54	$33.41	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
ENERGY STAR Certification
Buildings
Contract a Professional Engineer or Registered Architect to conduct a facility data review	0.00	0.00	2.06	0.00	2.06	$106.17	$0.00	$1,200.00	4,200.00	8,652.00	$5,485,914.00
Engage an internal Professional Engineer or Registered Architect to conduct a facility data review	0.00	0.00	3.06	0.00	3.06	$157.71	$0.00	$0.00	750.00	2,295.00	$118,282.50
Complete and submit the online application to EPA and respond to EPA questions if any	0.00	0.00	0.00	1.00	1.00	$33.41	$0.00	$0.00	7,500.00	7,500.00	$250,575.00
Provide additional information to EPA as part of quality control audit, if requested	0.00	0.00	2.00	0.00	2.00	$103.08	$0.00	$0.00	240.00	480.00	$24,739.20
Provide additional information to EPA as part of use detail verification, if requested	0.00	0.00	1.00	0.00	1.00	$51.54	$0.00	$0.00	375.00	375.00	$19,327.50
Respond to EPA questions for the analysis of ENERGY STAR certified buildings, if requested	0.00	0.00	0.40	0.00	0.40	$20.62	$0.00	$0.00	80.00	32.00	$1,649.60
Subtotal (for Buildings)	0.00	0.00	varies	varies	varies	varies	$0.00	varies	varies	19,334.00	$5,900,487.80
Plants
Non-Petroleum Plants
Enter information into the EPI	0.00	0.00	0.30	0.00	0.30	$15.46	$0.00	$0.00	115.00	34.50	$1,777.90
Complete and submit materials to EPA	0.00	0.08	0.50	0.17	0.75	$38.95	$0.00	$0.00	115.00	86.25	$4,479.25
Petroleum Plants
Generate energy-efficiency results	0.00	0.00	0.17	0.00	0.17	$8.76	$0.00	$3,480.00	10.00	1.70	$34,887.60
Complete and submit materials to EPA	0.00	0.08	0.50	0.17	0.75	$38.95	$0.00	$0.00	10.00	7.50	$389.50
All Plants (optional profiles)
Prepare and submit profile of certified plant	0.08	0.08	0.34	0.00	0.50	$34.65	$0.00	$0.00	4.00	2.00	$138.60
Subtotal (for Plants)	varies	varies	varies	varies	varies	varies	$0.00	varies	varies	131.95	$41,672.85
Subtotal (for ENERGY STAR Certification)	varies	varies	varies	varies	varies	varies	$0.00	varies	varies	19,465.95	$5,942,160.65
ENERGY STAR Challenge for Industry
Prepare and submit online Challenge for Industry Registration Form if necessary	0.00	0.00	0.17	0.00	0.17	$8.76	$0.00	$0.00	60.00	10.20	$525.60
Track energy use – in-house systems	0.00	0.00	0.17	0.00	0.17	$8.76	$0.00	$0.00	39.00	6.63	$341.64
Track energy use – ETT	0.00	0.00	2.00	0.50	2.50	$119.79	$0.00	$0.00	1.00	2.50	$119.79
Prepare and submit online Challenge for Industry Recognition Application, SEI and PE Verification Checklist	0.00	0.08	0.42	0.17	0.67	$34.82	$0.00	$0.00	50.00	33.50	$1,741.00
Respond to EPA follow-up questions if any	0.00	0.00	0.17	0.00	0.17	$8.76	$0.00	$0.00	33.00	5.61	$289.08
Subtotal (for ENERGY STAR Challenge for Industry)	0.00	varies	varies	varies	varies	varies	$0.00	$0.00	varies	58.44	$3,017.11
Designed to Earn the ENERGY STAR
Review instructions and create an account in Portfolio Manager	0.00	0.00	0.75	0.00	0.75	$38.66	$0.00	$0.00	6.00	4.50	$231.96
Gather building data and estimated energy use data	0.00	0.00	1.50	0.00	1.50	$77.31	$0.00	$130.00	15.00	22.50	$3,109.65
Enter data into Portfolio Manager	0.00	0.00	0.25	0.00	0.25	$12.89	$0.00	$0.00	15.00	3.75	$193.35
Complete and submit DEES application to EPA	0.00	0.00	0.25	0.25	0.50	$21.24	$0.00	$0.00	15.00	7.50	$318.60
Subtotal (for Designed to Earn the ENERGY STAR)	0.00	0.00	varies	varies	varies	varies	$0.00	varies	varies	38.25	$3,853.56


Exhibit 3 (continued)*
Estimated Annual Respondent Burden and Cost
ENERGY STAR Program: Recognition

	Hours and Costs Per Respondent per Activity								Total Hours and Costs
	Legal	Managerial	Technical	Clerical	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Information Collection Activity	$120.39	$93.73	$51.54	$33.41	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
ENERGY STAR Awards
Commercial and Industrial Sector Partners
Review the instructions	0.00	0.50	0.50	0.00	1.00	$72.64	$0.00	$0.00	36.00	36.00	$2,615.04
Complete and submit the information online	0.00	3.00	7.00	3.00	13.00	$742.20	$0.00	$0.00	36.00	468.00	$26,719.20
Sustained Excellence
Review the instructions	0.00	0.50	0.50	0.00	1.00	$72.64	$0.00	$0.00	39.00	39.00	$2,832.96
Complete and submit the information online	0.00	2.00	3.00	2.00	7.00	$408.90	$0.00	$0.00	39.00	273.00	$15,947.10
Subtotal	0.00	varies	varies	varies	varies	varies	$0.00	$0.00	75.00	816.00	$48,114.30
Service and Product Providers
Review the instructions	0.00	0.50	0.50	0.00	1.00	$72.64	$0.00	$0.00	20.00	20.00	$1,452.80
Complete and submit the information online	0.00	3.00	7.00	3.00	13.00	$742.20	$0.00	$0.00	20.00	260.00	$14,844.00
Subtotal	0.00	3.50	7.50	3.00	14.00	$814.84	$0.00	$0.00	20.00	280.00	$16,296.80
Energy Efficiency Program Sponsors
Review the instructions	0.00	0.50	0.50	0.00	1.00	$72.64	$0.00	$0.00	15.00	15.00	$1,089.60
Complete and submit the information online	0.00	1.00	2.00	1.00	4.00	$230.22	$0.00	$0.00	15.00	60.00	$3,453.30
Subtotal	0.00	1.50	2.50	1.00	5.00	$302.86	$0.00	$0.00	15.00	75.00	$4,542.90
Subtotal (for ENERGY STAR Awards)	0.00	varies	varies	varies	varies	varies	$0.00	$0.00	110.00	1,171.00	$68,954.00
Tenant Recognition Program
Gather and enter data into Portfolio Manager	0.00	0.00	3.00	0.00	3.00	$154.62	$0.00	$0.00	300.00	900.00	$46,386.00
Prepare and submit documentation for recognition	0.00	0.00	0.40	0.10	0.50	$23.96	$0.00	$1,060.00	200.00	100.00	$216,792.00
Respond to EPA questions, if needed	0.00	0.00	0.50	0.00	0.50	$25.77	$0.00	$0.00	20.00	10.00	$515.40
Subtotal (for Tenant Recognition)	0.00	0.00	varies	0.00	varies	varies	$0.00	1,060.00	varies	1,010.00	$263,693.40
TOTAL	varies	varies	varies	varies	varies	varies	0.00	varies	varies	21,743.64	$6,281,678.72

*Exhibit contains rounding.

Respondent Tally

EPA estimates the total annual hour and cost burden to respondents to be 187,198 hours and $9,521,761, as demonstrated by Table 5.

Table 5

Respondent Annual Cost (Non-Labor)

Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).

The cost estimate should be split into two components: (a) a total capital and start-up cost

component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should consider costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling, and testing equipment; and record storage facilities.

If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate.

Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

_____________________________________________

Estimating Capital and Start-up Costs

There are no capital or start-up costs associated with any activities related to the ENERGY STAR program in the commercial and industrial sectors.

Estimating Operations and Maintenance (O&M) Costs

Operation and maintenance (O&M) costs are those costs associated with a paperwork requirement incurred continually over the life of the ICR. They are defined by the Paperwork Reduction Act of 1995 as “the recurring dollar amount of costs associated with O&M or purchasing services.” This ICR includes lump-sum costs that respondents pay for contractor support in the completion of various collections, as listed below ($2022):

$1,200 for a respondent to obtain support from an external Professional Engineer or Registered Architect to conduct a facility data review in applying for ENERGY STAR certification or NextGen certification for a building.
$3,480 for a petroleum company to obtain support from a consulting service to generate energy-efficiency results of its plant for ENERGY STAR certification for a plant.
$130 for a respondent to obtain support from an external Registered Architect or Professional Engineer in completing (e.g., reviewing, signing) the Statement of Energy Design Intent (SEDI) for DEES recognition.
$1,060 for a respondent to obtain third-party verification of the submittal for recognition under the Tenant Recognition program.

As shown in Table 6, EPA estimates the total annual capital costs and O&M costs to respondents to be $5,288,750.

Table 6

AGENCY BURDEN ESTIMATES

Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

Estimating Labor Costs

Exhibits 4 through 6 estimate the annual agency burden hours and costs for information collection activities associated with the ENERGY STAR program in the commercial and industrial sectors.

The hourly Agency labor rates used in this ICR were obtained from the 2022 Salary Tables for federal civilian employees, which are published by the Office of Personnel Management.^¹⁷EPA estimates an average hourly labor cost of $86.54/hr for legal staff, $80.93/hr for managerial staff, $59.34/hr for technical staff, and $23.82/hr for clerical staff. The labor costs are based on the following GS levels and steps: legal labor rates were based on GS Level 15, Step 1, managerial labor rates were based on GS Level 14, Step 4, technical labor rates were based on GS Level 12, Step 5, and clerical labor rates were based on GS Level 5, Step 1. To derive hourly estimates, EPA multiplied hourly rates by the standard government overhead factor of 1.6. Agency burden and costs are estimated in Exhibits 4 through 6 and Table 7.

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

For certain information collections, EPA sends items to respondents using the U.S. postal service and incurs $0.63 for postage. This includes decals and other items that cannot be sent electronically.

Agency Tally

As shown in Table 7, EPA estimates the total annual hour and cost burden to the Agency to be 12,395 hours and $665,415.

Table 7

Exhibit 4*
Estimated Annual Agency Burden and Cost
ENERGY STAR Program: Joining the ENERGY STAR Program and Related Activities
	Agency Hours and Costs per Activity								Total Hours and Costs
	Legal	Managerial	Technical	Clerical	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Information Collection Activity	$86.54	$80.93	$59.34	$23.82	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Partnership Letter or Agreement/Related Activities
Partnership Letter, Partnership Agreements and Related Materials
Review the completed Partnership Letters, Partnership Agreements and related materials from C&I, SPP and EEPS Partners	0.00	0.00	0.50	0.00	0.50	$29.67	$0.00	$0.00	185.00	92.50	$5,488.95
Follow up with Partners, if needed	0.00	0.00	0.25	0.00	0.25	$14.84	$0.00	$0.00	25.00	6.25	$371.00
Send emails, passwords, and welcome aboard kits	0.00	0.00	0.08	0.00	0.08	$4.75	$0.00	$0.63	185.00	14.80	$995.30
Update and maintain the ENERGY STAR Web site	0.00	0.00	30.00	0.00	30.00	$1,780.20	$0.00	$0.00	1.00	30.00	$1,780.20
Subtotal (for Buildings)	0.00	0.00	varies	0.00	varies	varies	$0.00	varies	varies	143.55	$8,635.45
Additional SPP Related Activities
Request updated contact information annually	0.00	0.00	0.50	0.00	0.50	$29.67	$0.00	$0.00	1.00	0.50	$29.67
Receive and enter updated contact information into database	0.00	0.00	0.00	0.08	0.08	$1.91	$0.00	$0.00	200.00	16.00	$382.00
Receive and process efforts and successes	0.00	0.00	0.17	0.00	0.17	$10.09	$0.00	$0.00	75.00	12.75	$756.75
Receive and process other requested materials	0.00	0.00	0.00	0.20	0.20	$4.76	$0.00	$0.00	70.00	14.00	$333.20
Subtotal	0.00	0.00	varies	varies	varies	varies	$0.00	$0.00	varies	43.25	$1,501.62
Additional EEPS Related Activities
Receive annual updates from EEPS and update the Directory of Energy Efficiency Programs	0.00	0.00	0.00	0.08	0.08	$1.91	$0.00	$0.00	60.00	4.80	$114.60
Subtotal	0.00	0.00	0.00	0.08	0.08	$1.91	$0.00	$0.00	60.00	4.80	$114.60
TOTAL	0.00	0.00	varies	varies	varies	varies	$0.00	varies	varies	191.60	$10,251.67
*Exhibit contains rounding.

Exhibit 5*
Estimated Annual Agency Burden and Cost
ENERGY STAR Program: Benchmarking

	Agency Hours and Costs Per Activity								Total Hours and Costs
	Legal	Managerial	Technical	Clerical	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Information Collection Activity	$86.54	$80.93	$59.34	$23.82	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Portfolio Manager
Maintenance and Use of Portfolio Manager
Upgrade to enhance functionality	0.00	200.00	850.00	200.00	1,250.00	$71,389.00	$0.00	$0.00	1.00	1,250.00	$71,389.00
Maintain secure database infrastructure	0.00	0.00	500.00	0.00	500.00	$29,670.00	$0.00	$0.00	1.00	500.00	$29,670.00
Perform system maintenance	0.00	0.00	600.00	0.00	600.00	$35,604.00	$0.00	$0.00	1.00	600.00	$35,604.00
Collect data submitted through Excel spreadsheet and enter data into Portfolio Manager	0.00	0.00	0.08	0.00	0.08	$4.75	$0.00	$0.00	14,000.00	1,120.00	$66,500.00
Subtotal	0.00	varies	varies	varies	varies	varies	$0.00	$0.00	varies	3,470.00	$203,163.00
Evaluation of Portfolio Manager
Solicit feedback from respondents	0.00	0.00	150.00	0.00	150.00	$8,901.00	$0.00	$0.00	1.00	150.00	$8,901.00
Review answers to questions	0.00	0.00	3.00	0.00	3.00	$178.02	$0.00	$0.00	100.00	300.00	$17,802.00
Design and develop software changes	0.00	0.00	1,250.00	0.00	1,250.00	$74,175.00	$0.00	$0.00	1.00	1,250.00	$74,175.00
Subtotal	0.00	0.00	varies	0.00	varies	varies	$0.00	$0.00	varies	1,700.00	$100,878.00
Subtotal (for Portfolio Manager)	0.00	varies	varies	0.00	varies	varies	0.00	0.00	varies	5,170.00	$304,041.00
Data Collection for Model Development and Beta Testing
Conduct the data collections	0.00	0.00	0.17	0.00	0.17	$10.09	$0.00	$0.00	950.00	161.50	$9,585.50
Subtotal (for Data Collection for Model Development and Beta Testing)	0.00	0.00	0.17	0.00	0.17	$10.09	$0.00	$0.00	950.00	161.50	$9,585.50
TOTAL	0.00	varies	varies	varies	varies	varies	$0.00	varies	varies	5,331.50	$313,626.50
*Exhibit contains rounding.

Exhibit 6*
Estimated Annual Agency Burden and Cost
ENERGY STAR Program: Recognition

	Agency Hours and Costs Per Activity								Total Hours and Costs
	Legal	Managerial	Technical	Clerical	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Information Collection Activity	$86.54	$80.93	$59.34	$23.82	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
ENERGY STAR Certification
Buildings
Review of Applications
Review applications and follow up with organizations if questions	0.00	0.10	0.25	0.25	0.60	$28.88	$0.00	$0.00	7,500.00	4,500.00	$216,600.00
Send a letter of denial/acceptance (and certificate and decal if accepted)	0.00	0.00	0.00	0.08	0.08	$1.91	$0.00	$0.63	7,500.00	600.00	$19,050.00
Quality Control Audits of Applications
Collect information from applicants in performing quality control audits	0.00	0.00	4.00	0.00	4.00	$237.36	$0.00	$0.00	240.00	960.00	$56,966.40
Evaluation of ENERGY STAR Certified Buildings
Solicit feedback from respondents	0.00	0.00	0.40	0.00	0.40	$23.74	$0.00	$0.00	80.00	32.00	$1,899.20
Review answers to questions	0.00	0.00	0.25	0.00	0.25	$14.84	$0.00	$0.00	80.00	20.00	$1,187.20
Take follow-up action	0.00	0.00	0.25	0.00	0.25	$14.84	$0.00	$0.00	80.00	20.00	$1,187.20
Subtotal (for Buildings)	0.00	varies	varies	varies	varies	varies	$0.00	varies	varies	6,132.00	$296,890.00

Exhibit 6 (continued)*
Estimated Annual Agency Burden and Cost
ENERGY STAR Program: Recognition

	Hours and Costs Per Respondent per Activity								Total Hours and Costs
	Legal	Managerial	Technical	Clerical	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Information Collection Activity	$86.54	$80.93	$59.34	$23.82	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
ENERGY STAR Certification
Plants
Enhance functionality of and maintain the EPI and other tools and information on the Web site	0.00	0.00	24.00	0.00	24.00	$1,424.16	$0.00	$0.00	1.00	24.00	$1,424.16
Review and evaluate the submissions	0.00	0.00	0.67	0.00	0.67	$39.76	$0.00	$0.00	115.00	77.05	$4,572.40
Give permission to display the ENERGY STAR Certification logo	0.00	0.00	0.06	0.00	0.06	$3.56	$0.00	$0.63	115.00	6.90	$481.85
Review and post profiles of certified plants on the Web site	0.00	0.00	0.17	0.00	0.17	$10.09	$0.00	$0.00	4.00	0.68	$40.36
Subtotal (for Plants)	0.00	0.00	varies	varies	varies	varies	$0.00	varies	varies	108.63	$6,518.77
Subtotal (for ENERGY STAR Certification)	0.00	varies	varies	varies	varies	varies	$0.00	varies	varies	6,240.63	$303,408.77
ENERGY STAR Challenge for Industry
Review online Challenge for Industry Registration Form	0.00	0.00	0.25	0.00	0.25	$14.84	$0.00	$0.00	60.00	15.00	$890.40
Review online Challenge for Industry Recognition Application, SEI and PE Verification Checklist and provide recognition	0.00	0.25	0.75	0.00	1.00	$64.74	$0.00	$0.00	50.00	50.00	$3,237.00
Ask follow-up questions if any	0.00	0.00	0.17	0.00	0.17	$10.09	$0.00	$0.00	33.00	5.61	$332.97
Subtotal (for ENERGY STAR Challenge for Industry)	173.08	0.25	varies	varies	varies	varies	$0.00	$0.00	varies	$70.61	$4,460.37
Designed to Earn the ENERGY STAR
Evaluate the DEES applications	0.00	0.00	1.00	0.00	1.00	$59.34	$0.00	$0.00	15.00	15.00	$890.10
Update the ENERGY STAR Web site to reflect the information collected	0.00	0.00	6.00	0.00	6.00	$356.04	$0.00	$0.00	1.00	6.00	$356.04
Subtotal (for Designed to Earn the ENERGY STAR)	0.00	0.00	varies	0.00	varies	varies	$0.00	$0.00	varies	21.00	$1,246.14
Exhibit 6 (continued)*
Estimated Annual Agency Burden and Cost
ENERGY STAR Program: Recognition

	Hours and Costs Per Respondent per Activity								Total Hours and Costs
	Legal	Managerial	Technical	Clerical	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
Information Collection Activity	$86.54	$80.93	$59.34	$23.82	Total Hours/ Activity	Labor Costs/ Activity	Capital Startup Costs/ Activity	O&M Costs/ Activity	Number of Activities/ Year	Total Hours/Year	Total Cost/Year
ENERGY STAR Awards
Commercial and Industrial Sector Partners
Develop the awards criteria	0.00	1.00	4.00	1.00	6.00	$342.11	$0.00	$0.00	1.00	6.00	$342.11
Receive and review the information submitted	0.00	2.00	3.00	1.00	6.00	$363.70	$0.00	$0.00	36.00	216.00	$13,093.20
Take follow-up action (e.g., send letter of award or loss)	0.00	0.08	0.00	0.08	0.16	$8.38	$0.00	$0.63	36.00	5.76	$324.36
Sustained Excellence
Develop the awards criteria	0.00	1.00	4.00	1.00	6.00	$342.11	$0.00	$0.00	1.00	6.00	$342.11
Receive and review the information submitted	0.00	1.00	2.00	0.50	3.50	$211.52	$0.00	$0.00	39.00	136.50	$8,249.28
Take follow-up action (e.g., send letter of award or loss)	0.00	0.08	0.00	0.08	0.16	$8.38	$0.00	$0.63	39.00	6.24	$351.39
Subtotal	0.00	varies	varies	varies	varies	varies	$0.00	varies	varies	376.50	$22,702.45
Service and Product Providers
Develop the awards criteria	0.00	1.00	4.00	1.00	6.00	$342.11	$0.00	$0.00	1.00	6.00	$342.11
Receive and review the information submitted	0.00	2.00	3.00	1.00	6.00	$363.70	$0.00	$0.00	20.00	120.00	$7,274.00
Take follow-up action (e.g., send letter of award or loss)	0.00	0.08	0.00	0.08	0.16	$8.38	$0.00	$0.63	20.00	3.20	$180.20
Subtotal	0.00	varies	varies	varies	varies	varies	$0.00	varies	varies	129.20	$7,796.31
Energy Efficiency Program Sponsors
Develop the awards criteria	0.00	0.50	1.00	0.50	2.00	$111.72	$0.00	$0.00	1.00	2.00	$111.72
Receive and review the information submitted	0.00	0.50	1.00	0.50	2.00	$111.72	$0.00	$0.00	15.00	30.00	$1,675.80
Take follow-up action (e.g., send letter of award or loss)	0.00	0.08	0.00	0.08	0.16	$8.38	$0.00	$0.63	15.00	2.40	$135.15
Subtotal	0.00	varies	varies	varies	varies	varies	$0.00	varies	varies	34.40	$1,922.67
Subtotal (for ENERGY STAR Awards)	0.00	varies	varies	varies	varies	varies	$0.00	varies	varies	540.10	$32,421.43
TOTAL	173.08	varies	varies	varies	varies	varies	0.00	varies	varies	6,872.34	$341,536.71


*Exhibit contains rounding.

This section describes EPA’s activities in the three categories described earlier: 1) Joining the ENERGY STAR Program And Related Activities; 2) Benchmarking; and 3) Recognition under ENERGY STAR.

JOINING THE ENERGY STAR PROGRAM AND RELATED ACTIVITIES

Partnership Agreements and Related Activities

EPA performs the following activities in regard to Partnership Agreements and related materials for all Partners:
- Review the completed Partnership Agreements and related materials;
- Follow up with Partners, if needed;
- Send emails, passwords (for MESA access), and welcome aboard kits; and
- Update and maintain the ENERGY STAR web site.
EPA performs the following additional activities in regard to SPPs:
- Request updated contact information regularly;
- Receive and enter updated contact information into database;
- Receive and process efforts and successes; and
- Receive and process other requested materials for appropriate Partnership category.
EPA receives annual updates from EEPS and updates the Directory of Energy Efficiency Programs.

BENCHMARKING

Portfolio Manager

EPA performs the following activities related to the benchmarking process:

Upgrade Portfolio Manager to enhance functionality (easier data entry, more sharing options, more reporting metrics, etc);
Maintain secure database infrastructure, including maintaining a firewall and monitoring system activity;
Perform system maintenance activities, such as deploying software patches, correcting defects, etc.; and
Collect data submitted through Excel spreadsheets and enter data into Portfolio Manager.

EPA performs the following activities in evaluating the usability of Portfolio Manager and the effectiveness of guidance and trainings on benchmarking in the tool:

Solicit feedback from respondents;
Review answers to questions; and
Design and develop Portfolio Manager software changes, as applicable, to make the tool more effective.

Data Collection for Model Development and Beta Testing

EPA conducts the data collections.

RECOGNITION

ENERGY STAR Certification and ENERGY STAR NextGen Certification (collectively “ENERGY STAR Certification”) for Buildings

EPA performs the following activities for buildings applying for ENERGY STAR Certification:
- Review applications and follow up with organization if questions; and
- Send a letter of denial or acceptance.
EPA collects information from ENERGY STAR certified buildings in performing periodic quality control audits.
EPA performs the following activities in evaluating ENERGY STAR certified buildings:
- Solicit feedback from respondents;
- Review answers to questions; and
- Take follow-up action.

ENERGY STAR Certification for Plants

EPA performs the following activities for companies seeking the ENERGY STAR Certification for their plants:
- Enhance the functionality of and maintains the EPI and other tools and information on the web site;
- Review and evaluate the submissions;
- Give permission to display the ENERGY STAR Certification logo; and
- Review and post profiles of certified plants on the web site.

ENERGY STAR Challenge for Industry

EPA performs the following activities under the ENERGY STAR Challenge for Industry:
- Review online Challenge for Industry Registration Form;

Review online Challenge for Industry Recognition Application, SEI and PE Verification Checklist and provide recognition; and
Ask follow-up questions if any.

Designed to Earn the ENERGY STAR

EPA performs the following activities for the graphic:

Evaluate the DEES applications; and
Update the ENERGY STAR website to reflect the information collected.

ENERGY STAR Awards

EPA performs the following activities to administer the awards process:
- Develop the awards criteria;
- Receive and review the information submitted; and
- Take follow-up action (e.g., send letters of award or loss).

Tenant Recognition Program

EPA performs the following activities under the Tenant Recognition program:
- Review applications and provide recognition if warranted; and
- Contact participants and ask questions, if needed.

Collection Methodology and Management
EPA gives respondents the ability to fill out forms (e.g., Partnership Agreements) and tools electronically. In addition, respondents can submit the information electronically (e.g., via web forms, email), without the use of postal mail. EPA reviews the submittals to ensure their accuracy and completeness.

CHANGE IN BURDEN

Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost estimates.

EPA estimates a total annual respondent burden in this ICR, 1772.09, of 187,198 hours. This is a decrease of 23,107 hours from the currently approved burden of 210,306 hours in ICR 1772.08.

Table 8 explains this decrease. Specifically, the table presents the total annual hours estimated in ICR 1772.08 and ICR 1772.09 for each information collection (see columns 1-3). The table then compares their respective hours for each collection to derive the change in hours, and indicates whether this hour-change resulted from a program change and/or adjustment (see column 4). The table also briefly describes the program change and/or adjustment (see column 5). Finally, the table sums up all hour-changes to derive the total annual change in hours for all collections (see the bottom row of the table).

The table shows that there was a 325-hour increase due to program changes and a 23,432-hour decrease due to adjustments. This resulted in a total decrease of 23,107 hours in ICR 1772.09.

Program Changes

The increase due to program changes is because of changes to activities within ENERGY STAR Certification for Buildings. EPA plans to implement a new recognition offering, called ENERGY STAR NextGen Certification, designed to encourage top energy performance, use of renewable energy, and electrification of U.S. commercial and multifamily buildings. This increases the estimates related to Joining the ENERGY STAR Program and Related Activities by an estimated 300 hours. Also related to ENERGY STAR Certification for Buildings, EPA will be requesting additional information to verify respondent use details, which increases the estimate by around 384 hours. EPA will no longer be asking partners to submit information related to National Treasure Hunt activities, which reduced the estimate by 360 hours.

Adjustments

There is a decrease in the burden hours estimate due to adjustments in the way respondents engage in benchmarking. Portfolio Manager data indicate an increasing percentage of users are opting for Web Services over other benchmarking methods. Whereas EPA estimated 73% of buildings would be benchmarked using Web Services in ICR 1772.08, it estimates 84% in this ICR.^¹⁸ Web Services offers greater economies of scale and time-savings efficiencies than the other methods. For example, it takes four hours to perform a new benchmark using manual data entry, whereas about one hour using Web Services.

Portfolio Manager data also indicate that the percentage of repeat benchmarks performed in the tool has increased over new benchmarks. Whereas EPA estimated that 83% of buildings benchmarked are repeats in ICR 1772.08, it estimates 86% in this ICR. Repeat benchmarks take significantly less time than new ones, regardless of the method used. Under Web Services, for example, it takes about one hour to perform a new benchmark, whereas about six minutes for a repeat benchmark.

The use of Portfolio Manager is rising as Building Performance Standards are increasingly being implemented throughout the country, therefore increasing this burden hours estimate. Portfolio Manager is EPA’s voluntary online tool for energy management. Based on its data analysis, EPA estimates that 365,000 buildings will be benchmarked annually in this ICR, whereas it estimated 299,000 in ICR 1772.08.

In summary, Portfolio Manager data indicate that users are spending less time per building benchmarked, on average, than in the past. EPA reflected these data in ICR 1772.09, which resulted in a decrease in total hours burden.^¹⁹

Table 8

Table 8 continued

PUBLICATION OF DATA

For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

The EPA ENERGY STAR Commercial & Industrial Branch publishes directories of Partner organizations, as well as other tools and resources related to the information collected in Portfolio Manager as an on-going part of providing support to ENERGY STAR Partners. Information included in online tools and resources is created from aggregated summary data and not attributable to any individual organization or building.

DISPLAY OF OMB CONTROL NUMBER AND EXPIRATION DATE ON INSTRUMENTS

If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The agency plans to display the expiration date for OMB approval of the information collection on all instruments.

CERTIFICATION STATEMENT

Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

This information collection complies with all provisions of the Certification for Paperwork Reduction Act Submissions.

1 See Portfolio Web Services at https://portfoliomanager.energystar.gov/webservices/home.

2 See full metrics here: https://www.energystar.gov/buildings/about-us

3 See Portfolio Manager at https://www.energystar.gov/portfoliomanager and the Energy Performance Indicator at https://www.energystar.gov/industrial_plants/measure-track-and-benchmark/energy-star-energy. Additional tools and resources can be found at https://www.energystar.gov/buildings/tools-and-resources.

4 EPA provided the POCs with the burden inputs used in the weighted-average calculations that determined respondent burden for each benchmarking method. For additional information on these inputs, see Section 6(d) of this document under the heading, “Benchmarking,” and subheading, “Portfolio Manager.”

5 POCs were asked to provide input on benchmarking methods with which they had experience.

6 EPA is aware, for example, that some properties receive special rates from LPs, as low as $500 per building, especially if they are certifying multiple buildings. In addition, it is becoming increasingly common for LPs to include the cost of building certification in their energy efficiency consulting services for the building, which helps to keep costs low.

7 This participant group includes businesses and other organizations in such fields as commercial and corporate real estate, education, entertainment, government, healthcare and senior care facilities, hospitality, manufacturing and industry, multifamily housing, retail, wastewater and drinking water treatment, and associations.

8 This participant group includes companies that provide energy efficiency services and/or products in the commercial and industrial markets.

9 This participant group includes regulated utilities, publicly owned utilities, and energy delivery companies; national, regional, state, or local government entities; and other organizations involved in coordinating and/or administering energy-efficiency or environmental education programs that promote ENERGY STAR, including ENERGY STAR certified commercial and industrial buildings.

10 EEPS are given the opportunity to join one or more programs within ENERGY STAR when they complete and submit their Partnership Agreement (e.g., C&I, Products).

11 The on-site portion of the facility review can be conducted every other year if applying in consecutive years.

12 U.S. Bureau of Labor Statistics (BLS), Occupational Employment Statistics (OES), May 2022 National Occupational Employment and Wage Estimates. Available online at: https://www.bls.gov/oes/current/oes_nat.htm.

13 For purposes of this analysis, the following occupational groups of the U.S. Bureau of Labor Statistics (BLS) were used: Legal staff, SOC 23-1011, Lawyers; managerial staff, BLS SOC Code 11-1021, General and Operations Managers; technical staff, BLS SOC Code 17-3027, Mechanical Engineering Technicians; and clerical staff, BLS SOC Code 43-6014, Secretaries and Administrative Assistants, Except Legal, Medical, and Executive.

14 Bureau of Labor Statistics, Economic News Release, “Table 2. Seasonally adjusted: Employment Cost Index for wages and salaries, by occupational group and industry.” Available online at: https://www.bls.gov/news.release/eci.t02.htm.

15 As used in this ICR, the number of “buildings benchmarked annually” equals the number of “annual benchmarks” (i.e., the terms represent the same quantity).

16 EPA conducted limited industry consultations in preparing this ICR and improved its estimate of the cost to hire an external LP. EPA adjusted the cost from $1,665 to $1,200 per property based on industry input. Refer to Section 3(c) for a summary of the consultations.

17 See 2022 General Schedule (Base), “SALARY TABLE 2022-GS INCORPORATING THE 2.2% GENERAL SCHEDULE INCREASE EFFECTIVE JANUARY 2022,” available at: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2022/GS_h.pdf.

18 As discussed in the abstract of this document, this trend has been continuing for many years.

19 EPA performed limited industry consultations in preparing this ICR and verified the accuracy of its burden estimates for the tool.

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1772ss09

1772ss09.docx

EPA's ENERGY STAR Program in the Commercial and Industrial Sectors (Renewal)

OMB: 2060-0347

ICR SUPPORTING STATEMENT – PART A

ABSTRACT

NEED AND AUTHORITY FOR THE COLLECTION

PRACTICAL UTILITY/USERS OF THE DATA

USE OF TECHNOLOGY

EFFORTS TO IDENTIFY DUPLICATION

MINIMIZING BURDEN ON SMALL ENTITIES

EFFECTS OF LESS FREQUENT COLLECTION

GENERAL GUIDELINES

PUBLIC COMMENT AND CONSULTATIONS

8a. Public Comment

CONSULTATIONS

PAYMENTS OR GIFTS TO RESPONDENTS

PROVISIONS FOR PROTECTION OF INFORMATION

JUSTIFICATION FOR SENSITIVE QUESTIONS

ESTIMATE OF RESPONDENT BURDEN HOURS & LABOR COSTS

Respondent Annual Cost (Non-Labor)

AGENCY BURDEN ESTIMATES

CHANGE IN BURDEN

PUBLICATION OF DATA

DISPLAY OF OMB CONTROL NUMBER AND EXPIRATION DATE ON INSTRUMENTS

CERTIFICATION STATEMENT