A.2 NEED FOR AND USE OF THE COLLECTION

A.2.a NEED/AUTHORITY FOR THE COLLECTION

Section 103(a) of the Clean Air Act authorizes EPA to establish “a national research and development program for the prevention and control of air pollution." As part of such a program, EPA is to “conduct and promote the coordination and acceleration of research, investigations, experiments, demonstrations, surveys, and studies relating to the causes, effects (including health and welfare effects), extent, prevention and control of air pollution." Section 103(a)(1).

In addition, as a component of the program, section 103(g) directs the Administrator to "conduct a basic engineering research and technology program to develop, evaluate, and demonstrate nonregulatory strategies and technologies for air pollution prevention." The section calls on the Administrator to provide opportunities for industry, public interest groups, scientists, and other interested persons to participate in strategy development. Section 103(g) further directs EPA to include as elements in the program "improvements in nonregulatory strategies and technologies for preventing or reducing multiple air pollutants including sulfur oxides, nitrogen oxides, heavy metals, PM-10 (particulate matter), carbon monoxide, and carbon dioxide..." The strategies and technologies are to improve various air pollutant reduction and nonregulatory control strategies, including energy conservation.

The ENERGY STAR® Labeling Program is one component of the Administrator's response. ENERGY STAR is a voluntary partnership between the U.S. EPA, the U.S. Department of Energy, product manufacturers, local utilities, and retailers. Partners help promote efficient products by labeling qualifying models with the ENERGY STAR label and educating consumers about the benefits. The label provides an easy way for consumers to identify energy-efficient products that save money on utility bills and reduce air pollution. By using less energy, these products help reduce the demand to create power, which is typically generated by power plants that burn fossil fuels. As such, they help reduce air pollutants such as sulfur oxides, nitrogen oxides, and carbon dioxide that are generated by these stationary sources. The labeling program demonstrates how providing consumer product information can be used as a nonregulatory strategy to prevent and control air pollution.

This information collection is designed to evaluate the efficacy of the ENERGY STAR® Labeling Program as a nonregulatory strategy for preventing air pollution.

A.2.b PRACTICAL UTILITY/USERS OF THE DATA

In order to evaluate and improve the current programs and to develop new initiatives, CPD needs to collect data on the effectiveness of its programs, the awareness and satisfaction of its customers, and the need for new or revised programs. Similarly, electric utilities conduct program evaluations: (1) to determine whether energy-efficiency programs and initiatives are accomplishing their goals, and (2) to gain insights into how to improve program activities and best direct resources.

In 1997, GAO issued a report assessing the results of four of EPA's voluntary air pollution prevention programs. With respect to EPA's energy-efficiency programs, the General Accounting Office (GAO) states, "Production of sound and timely information is one of the most critical functions of government. Program evaluation—along with supporting data collection-is one of the best means available for obtaining it..... [providing] sound information about what programs are actually delivering, how they are being managed, and the extent to which they are effective or cost-effective." The report

raised questions about the magnitude of effects EPA attributed directly to its programs in current and future years. That same year, the EPA Inspector General issued an audit report that included the ENERGY STAR programs. The report recommended an increased focus on the role of market transformation in program assessment and planning.

The proposed information collections are designed to address the concerns of GAO and the EPA Inspector General and provide EPA with critical insights to better monitor and improve program effectiveness and communicate results to program stakeholders. In addition, the collections will respond to the challenges set forth in the Scoping Study, a seminal paper in the field of market transformation evaluation in which the California Demand-Side Measurement Advisory Committee notes that attribution of effects to specific programs and the permanence of effects are the two major challenges facing program analysts.

The collected data will have several significant secondary uses for transforming markets toward energy-efficient technologies, both inside and outside of EPA, such as electric utility companies, regional electricity cooperatives, trade associations, environmental and public interest groups, State energy agencies, and other important stakeholders. A few examples are as follows:

National-level market research data will help other stakeholders in promoting their
efforts to reduce energy consumption.

Feedback from market segments for ENERGY STAR products will help other groups
understand what programs or communication methods achieve effective results.

EPA's coordination and information sharing efforts with stakeholder groups with respect to survey design and data analysis will ultimately minimize the burden on respondent populations, and maximize the use of data collected at local, State, and regional levels by stakeholder groups.

To help CPD maximize the secondary uses of its data collection efforts, it plans to create a database to facilitate information and data sharing, and will distribute data to any group that requests it. For example, CPD estimates that at least 47 utilities representing approximately 30 percent of all households will use the data collected from this effort.

Access to the results of the information collections will be facilitated via posting on EPA's Web site. In addition, to the extent that the information collected is not deemed to be confidential business information by the respondent, the raw data will be available upon written request.

A.3

NONDUPLICATION, CONSULTATIONS, AND OTHER COLLECTION

CRITERIA

The following sections verify that this information collection satisfies OMB's nonduplication and consultation guidelines, and does not duplicate another collection.

A.3.a NONDUPLICATION

To the best of CPD's knowledge, a comprehensive, detailed, national-level of company-, geographic-, and industry-specific information is not available from any other source. Although the Department of Energy collects some related information from households in the Residential Energy Consumption Survey (RECS), RECS does not duplicate the ENERGY STAR Household Survey. A few of the reasons are listed below:

RECS does not ask about how respondents gather information or make purchasing
decisions that is useful to stakeholders.

RECS does not ask questions about the full range of Energy Star products.

RECS does not identify gaps in brand awareness and understanding (i.e., false-positive recognition of the ENERGY STAR label). For example, in 1997, CPD secured a one-time right to include a few questions about the ENERGY STAR label in RECS on an experimental basis. Although these experimental questions yielded some general information about ENERGY STAR brand awareness, it was not clear whether or not respondents could distinguish the difference between the ENERGY STAR label with the Energy Guide label.

RECS does not assess whether or not the brand campaign is effectively communicating its intended messages (i.e. do those who positively recognize the label display an understanding of its meaning?).

In addition, although some utilities and regional electricity cooperatives collect related information on certain aspects of utilization of energy-efficient technologies, these efforts are limited in geographic, market, and product scope and do not directly address the effect EPA's ENERGY STAR Program had on such technology decisions. Moreover, none of the data collected by utilities or DOE contains sufficient detail to produce statistically and meaningful results among strata such as industry and market segments, company size and geographic area, or targeted publicity efforts.

Finally, CPD will ensure that information collected will not duplicate any ongoing recordkeeping or reporting functions required for participation in any of CPD's programs.

A.3.b PUBLIC NOTICE REQUIRED PRIOR TO ICR SUBMISSION TO OMB

To comply with the Paperwork Reduction Act requirement that any agency developing a nonrule-related ICR solicit public comments for a 60-day period, EPA published a Federal Register notice on September 22, 1998, stating its intention to obtain a clearance for CPD programs. A.3.c CONSULTATIONS

As part of its voluntary efforts, CPD has good relations with relevant stakeholders and maintains consistent communications with them on the progress and design of this data collection effort. On three noteworthy occasions, EPA consulted with utility and other representatives in the following manner.

On October 19, 1998, in Chicago, IL, EPA and the Consortium for Energy Efficiency
(CEE) hosted a meeting and teleconference between representatives of utilities, state
governments, and market transformation advocacy groups to present its evaluation plan
and obtain feedback. EPA received useful comments from the various stakeholders in
attendance, and the evaluation plan was well received.

On March 1, 1999, EPA presented its evaluation plan and data collection instruments as part of a panel shared by a utility representative at the 1999 American Council for an Energy Efficient Economy (ACEEE) Market Transformation Workshop. EPA distributed an abstract of the evaluation plan and collection instruments at the panel session and announced it was posting the evaluation plan and collection instruments on a web site that was open for anyone to make comments. In addition, CEE identified interested evaluation professionals and announced the opportunity for comment and peer review. Several influential industry representatives did comment on the collection instruments. EPA subsequently posted its response to comments and integrated numerous changes into its collection instruments.

On August 19, 1999, EPA chaired a panel on market transformation evaluation at the International Energy Program Evaluation Conference (IEPEC) in Denver, and presented the evaluation plan, survey methodology, and collection instruments to utility representatives and market evaluators.

Input was sought from the respective EPA Program Mangers for each respondent group. In addition, EPA Program Managers helped select representative respondents to participate in the pilot test and reconcile comments that resulted from this test. EPA also directed its contractor to interface with the pilot test group to assess the response time and user-friendliness of the collection instrument.

Specifically, the response time for the telephone survey was derived from four pilot tests of HVAC distributors. The maximum time to complete the HVAC distributor collection (12 minutes) was applied to most of the other telephone collections because they are very similar in length and complexity. (Many of the questions are repeated for the other respondent group surveys). Three respondent group collections include a few additional questions. Therefore, the anticipated time of completion is slightly longer (15 minutes). In addition, the mail survey burden was estimated through internal trials. As a result, the burden for the 22-question mail survey was calculated to be 15 minutes at most.

Contractor expertise was sought in the survey design. The contractors (The Cadmus Group, Inc., XENERGY, Inc., and Opinion Dynamics Corporation (ODC)) have decades of experience designing surveys to collect information about Agency or other programs' effectiveness. In fact, ODC and XENERGY are specialized in energy utility market research, conducting similar surveys for numerous market evaluations. Cadmus has supported EPA on numerous large surveys for public utilities and understands the Agency's objectives and criteria for data collection efforts.

A.3.d EFFECTS OF LESS FREQUENT COLLECTION

The surveys or information collections are a single collection and do not involve periodic

reporting or recordkeeping.

A.3.e GENERAL GUIDELINES

The surveys or information collections do not violate any guidelines for information collection activities specified by OMB. Specifically, the respondents are not required to:

Report information to EPA more often than quarterly.

Prepare a written response with fewer than 30 days to reply.

Retain records for more than 3 years.

Maintain or provide information in a format other than that in which it is customarily maintained.

Submit proprietary, trade secret, or other confidential information.

Submit more than one original and two copies of any document.

The information collection:

Contains statistical surveys designed to produce data that can be generalized to the universe of the study (see Section B.2).

Does not provide remuneration to participants.

Will transcribe information collected into an automated format.

Is designed with small entities particularly in mind (see Section A.5.c).

This information collection does not require the respondent to disclose any confidential information. Since the ENERGY STAR labeling partnership is not a regulatory program, respondents are not obliged to respond to this strictly voluntary information collection. Further, respondents could eliminate any information they wish to classify as confidential from their reply.

If respondents choose to submit confidential information under this voluntary survey, EPA will ensure that it is handled appropriately and safeguarded from public disclosure. The opening scripts of all