Supporting Statement for Information Collection Aug 6 2009

DEPARTMENT OF TRANSPORTATION

SUPPORTING STATEMENT FOR INFORMATION COLLECTION

14 CFR Part 205

APPLICANT BACKGROUND QUESTIONNAIRE

A. Justification

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

This collection supports DOT’s organizational excellence goal by ensuring that employment data is available for the analysis and modification of DOT hiring initiatives. The Department of Transportation (DOT) is mandated by 5 U.S.C. 7201, Civil Service Reform Act of 1978 and 43 FR 38297 to determine adverse impact in selection or promotion procedures as well as determine the efficacy of outreach efforts. In addition DOT is required to provide a variety of information to the EEOC including statistics and the status of initiatives and programs.

2. Indicate how, by whom, and for what purpose the information is to be used.

The information is maintained electronically in either the Hiring Manager staffing system or in the Department of the Interior’s (DOI) Federal Personnel Payroll System (FPPS). This information is available to Human Resource Specialists and Civil Rights Specialists for reporting purposes as well as for analysis of complaints of discrimination and organizational diversity and outreach planning.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology.

As mentioned above, the data on applicants will be maintained in the Hiring Manager database while information on employees will be maintained in FPPS. The information will be collected electronically approximately 99% of the time.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose(s) described in Item 2 above.

Previous government wide collection forms have expired. The Department has OMB approval to gather this information via OMB 2105-0557. This request is for extension of that approval.

Prior to August 2005 most agencies used SF-181, Ethnicity and Race Identification, to collect data from both the applicants and their employees, thus meeting the requirement to provide employee data to OPM and applicant data to the EEOC. However, in August 2005, OPM forbid the use of SF-181 for the collection of applicant data. Agencies were then forced to obtain permission from OMB for a separate collection. DOT has permission via OMB 2105-0557. This request is for an extension of that approval.

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

Information will not be collected from small businesses.

6. Describe the consequence to federal program or policy activities if the collection is not conducted or is conducted less frequently.

The Department would be unable to meet its reporting requirements under Section 717 of Title VII and Section 501 of the Rehabilitation Act if this collection is not conducted. The Department must be able to collect the information from applicants at the time of initial application as well as from employees upon first hire in order to establish a database that will permit us to meet reporting requirements.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

Requiring respondents to report information to the agency more often than quarterly;

Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

Requiring respondents to submit more than an original and two copies of any document;

Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid or tax records for more than three years;

In connection with a statistical data classification that has not been reviewed and approved by OMB;

That includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

Requiring respondents to submit proprietary trade secret or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

Data would never be collected in that manner.

8. 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 received and describe actions taken by the agency in response to these comments. 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 date elements to be recorded, disclosed, and reported.

A 60-day Federal Register Notice was published on June 12, 2009, (FR Vol 74, No. 112, page 28090). No comments were received.

An attempt was made to obtain consensus on a multi-agency form in 2006 and 2007 and to submit that form to OMB for approval. The initiative however, failed and each agency must continue to maintain separate OMB authorization.

9. Explain decision to provide any payment or gifts to respondents, other than remuneration of contractors or grantees.

No payments or gifts were provided to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.

Responses are protected in accordance with the Privacy Act and can be retrieved using a confidential password issued only to specific personnel.

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

There are no questions of this sensitivity.

12. Provide estimates of the hour burden of collection of information, including:

Number of respondents: approximately 93,000

Number of annual responses: approximately 93,000

Frequency of response: once

Annual hour burden: 4,650 hours

Annualized cost to respondents: None

Explain how the burden was estimated: As our population ages the DOT anticipates a requirement to fill approximately 2,000 positions per year with approximately 100 applicants per position. As the applicant collection system is automated, many of the applicants will apply for more than one position. DOT’s automated hiring system has been in existence since 2005 and we have found that approximately 46% of our applicants each year are new entrants. DOT therefore anticipates that 93,000 new candidates using a form that requires about 5 minutes to complete, the 4,650 hour figure is derived from this average. As there is no charge to the applicant for use of the system, the respondent’s contribution to the effort is in time only.

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection.

1. Total capital and start-up cost component: No additional cost. DOT’s contracts with Hiring Manager and DOI allow for the entry and collection of this type of data.

2. Total operation and maintenance and purchase of services component: None.

14. Provide estimates of annualized cost to the Federal government. Also provide a description of the method used to estimate cost, which should include quantification of hours, operational expense, and any other expense that would not have been incurred without this collection of information.

No additional staff or systems will be needed to complete this effort.

15. Explain reasons for any program changes or adjustments reported.

There was an adjustment to the total estimated number of responses because we were able to determine distinct applicants instead of overall application numbers; therefore, the number of applicants decreased from 120,000 to 93,000. 

16. Publication of results of data collection. For collection of information whose results will be published, outline the plans for tabulation and publication.

Not applicable. The Department of Transportation doesn’t directly publish employee demographic information.

17. Approval for not displaying the expiration date of OMB approval.

Not required.

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

DOT has not identified any exceptions to the certification statement.