0157 ss

SUPPORTING STATEMENT
NOAA SPACE-BASED DATA COLLECTION SYSTEM (DCS) AGREEMENTS
OMB CONTROL NO. 0648-0157
A. JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary.
NOAA operates two space-based data collection systems: the Geostationary Operational Environmental
Satellite Data Collection System (GOES DCS) and the Argos Data Collection System (Argos DCS)
which is flown aboard NOAA's Polar-orbiting Operational Environmental Satellites (POES). Both the
GOES DCS and the Argos DCS are operated to support environmental applications, e.g., meteorology,
oceanography, hydrology, ecology, and remote sensing of Earth resources. In addition, the Argos DCS
currently supports applications related to protection of the environment, e.g., hazardous material
tracking, fishing vessel tracking for treaty enforcement, animal tracking, and oil and gas pipeline
monitoring to prevent leakage. Presently, the majority of users of these systems are government
agencies and researchers and, in fact, much of the data collected by both the GOES DCS and the Argos
DCS are provided to the World Meteorological Organization via the Global Telecommunications
System for inclusion in the World Weather Watch Program. Current loading on both of the systems
does not use the entire capacity of that system, so NOAA is able to make its excess capacity available
to other users who meet certain criteria (see #2 below). Accepted applicants use the NOAA DCS to
collect environmental data and in limited cases, non-environmental data via the Argos DCS, to support
other governmental and non-governmental research or operational requirements, such as for law
enforcement purposes.
Regulations explain not only the policy for using the GOES DCS, but also how users may use the
Argos DCS. These regulations ensure that the Government will not allow its space-based data
collection systems to be used where there are commercial services available that fulfill users’
requirements. The regulations contain the minimum information requirements necessary to determine
if a user meets these criteria. NOAA enters into an agreement with accepted applicants and gives
them access to the system.
2. Explain how, by whom, how frequently, and for what purpose the information will be used.
If the information collected will be disseminated to the public or used to support information
that will be disseminated to the public, then explain how the collection complies with all
applicable Information Quality Guidelines.
Applications are made in response to the requirements in 15 CFR 911 (under the authority of 15 U.S. C.
313 and others), and collection forms are used called system use agreements (SUAs). The application
information received is used to determine if the applicant meets the criteria for use of the system. The
system use agreements contain the following information: (1) the period of time the agreement is valid
and procedures for its termination, (2) the authorized use(s) of the DCS, and its priorities for use, (3)
the extent of the availability of commercial services which met the user's requirements and the reasons
for choosing the government system, (4) any applicable government interest in the data, (5) required
equipment standards, (6) standards of operation, (7) conformance with applicable ITU and FCC
agreements and regulations, (8) reporting time and frequencies, (9) data formats, (10) data delivery
systems and schedules and (11) user-borne costs.

For both systems, an important prerequisite in reviewing applications for use is that there are no
commercial space-based services available which meet the users’ requirements in terms of satellite
coverage, accuracy, data throughput, platform power consumption, size and weight, platform
compatibility, service continuity and reliability. The GOES DCS can be used only for environmental
purposes and the user needs to be a government agency or sponsored by one for use, while the Argos
DCS can be used for environmental and some very limited non-environmental purposes. The nonenvironmental use of the Argos system is primarily authorized for government users, for such
applications as humanitarian cargo tracking, law enforcement, or national security purposes. Nongovernmental, environmental use of the Argos system has added a prerequisite that there is a
government interest in the collection of the data. This prerequisite is similar, but not the same, as the
current GOES DCS sponsorship requirement. Moreover, only government and non-profit users may be
allowed to use the Argos DCS for non-environmental uses, except in cases where there is a significant
possibility of the loss of life. However, at no time will non-environmental use of the Argos DCS exceed
five percent of the system’s total use. These criteria are necessary because neither system is intended to
compete with private sector services. Details concerning the use of the data are also necessary to rank
system use. A standard part of the system use agreement with accepted applicants is that the user must
provide free and open access to the data by U.S. Government agencies.
The GOES DCS is managed solely by NOAA; as a result, the collection of information required is
greater than for the Argos DCS, which is managed cooperatively with the Centre National d’Etudes
Spatiales (CNES), the French Government space agency. As a result of the cooperative nature of the
Argos DCS, CNES handles more of the daily administration of the system, and thus NOAA does not
require the same information from users of the Argos DCS that it requires from users of the GOES
DCS.
As explained in the preceding paragraphs, the information gathered has utility. NOAA will retain
control over the information and safeguard it from improper access, modification, and destruction,
consistent with NOAA standards for confidentiality, privacy, and electronic information. See response
#10 of this Supporting Statement for more information on confidentiality and privacy. The information
collection is designed to yield data that meet all applicable information quality guidelines. Prior to
dissemination, the information will be subjected to quality control measures and a pre-dissemination
review pursuant to Section 515 of Public Law 106-554.
3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological techniques or other forms of
information technology.
System use agreements are available from a Web site, and can be e-mailed, or faxed in. An automated
electronic submission system for ingesting use requests has just been completed. This automated
system is already in place for the Argos system, and is expected to be operational for the GOES DCS
within the next 2 months.
4. Describe efforts to identify duplication.
The information collected relates to a unique benefit and no duplication has been identified.

5. If the collection of information involves small businesses or other small entities, describe the
methods used to minimize burden.
While small businesses may be respondents, the collection would not have any significant impact
upon them and the information requested is the minimum needed to make the necessary
determinations.
6. Describe the consequences to the Federal program or policy activities if the collection is not
conducted or is conducted less frequently.
If the collection was not conducted, NOAA could not allow potential users access to the system, which
would be to the detriment of those potential users and the government agency using their data or
services. The term of system use agreements for use of the GOES DCS is five years; for use of the
Argos DCS the term is three years. These terms are necessary to ensure that users will periodically
canvass the marketplace to determine whether commercial services have developed the capabilities to
meet their requirements.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
The collection is consistent with the OMB guidelines.
8. Provide a copy of the PRA Federal Register notice that solicited public comments on the
information collection prior to this submission. Summarize the public comments received in
response to that notice and describe the actions taken by the agency in response to those
comments. Describe the 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.
A Federal Register Notice, published on May 22, 2007, solicited public comment on this collection.
None was received. The program managers for the GOES and Argos DCS consult with users at
conferences held annually at a minimum and usually more frequently

9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts are made to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
No confidentiality is promised or provided.

11. 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.
No sensitive questions are asked.
12. Provide an estimate in hours of the burden of the collection of information.
The estimated burden for the NOAA DCS is calculated as follows:
GOES

Argos

Totals

Number of
respondents

25

365

390

Number of
responses per
respondent

1

1

Total annual
responses

25

365

Time per response

3 hours

1 hour

Total annual
burden hours for
collection

75

365

390

440

Estimating respondent time at $40 an hour, respondent costs would be $17,600.
13. Provide an estimate of the total annual cost burden to the respondents or record-keepers
resulting from the collection (excluding the value of the burden hours in #12 above).
The estimated operational cost for copying and mailing is $488.
14. Provide estimates of annualized cost to the Federal government.
The annual cost to the Federal Government to process the information obtained is estimated at $1,000.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the
OMB 83-I.
No program changes or adjustments were made to the burden hours or costs.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
The results of the collection will not be published.

17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
See answer 18 below.
18. Explain each exception to the certification statement identified in Item 19 of the OMB
83-I.
NOAA requests an exemption from displaying the OMB control number and expiration data on the
Argos DCS System Use Agreement itself, and to include it on an insert that contains the other PRA
information. The Argos DCS is operated through a cooperative program between the United States and
France. The French have requested that the PRA guidance be less conspicuous on the form.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not employ statistical methods.