0660.0003.SuppStmt.120309

Supporting Statement
U.S. Department of Commerce
National Telecommunications and Information Administration
Public Telecommunications Facilities Program Application Form
OMB Control No. 0660-0003

Section A. Justification
This is a request to extend the Office of Management and Budget approval of this
collection of information.

1.

Explain the circumstances that make the collection of information necessary.

Under the authority of 47 U.S.C. 390-393, 397, 399b (copy attached), the National
Telecommunications and Information Administration (NTIA) administers the Public
Telecommunications Facilities Program (PTFP). Each year approximately 150 grants are
awarded under the program. The purpose of the program is to assist, through matching funds, in
the planning and construction of public telecommunications facilities in order to achieve the
following objectives:
a.) Extend delivery of public telecommunications services to as many citizens in the United
States as possible by the most efficient and economical means, including the use of
broadcast and nonbroadcast technologies;
b.) Increase public telecommunications services and facilities available to, operated by, and
owned by minorities and women; and
c.) Strengthen the capability of existing public radio and television stations to provide
public telecommunications services to the public.
Awards of grants are based on the assessment of information contained on the standard grant
application form (SF-424) and additional information required by NTIA. Each year new
applications and re-submissions of deferred applications are made by those eligible to receive
PTFP grants. The application form presented here for clearance is the only method by which
PTFP can comparatively evaluate 300 proposed projects each fiscal year.

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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.
The PTFP is a competitive grant-making program that operates an annual application review
process. Without the requested information collection it would be impossible to carry out
PTFP=s purposes. At the beginning of a PTFP grant cycle, an announcement is sent to all
organizations that have indicated an interest in applying to PTFP. It notifies them of the
deadline for submitting applications, that applications can be prepared on-line, and that a printed
application form will be sent anyone upon request.
The universe for applicants includes non-commercial educational television and radio stations,
colleges and universities, states and state agencies, Indian Tribes, and non-profit corporations.
They submit proposals which describe unique projects intended to provide broadcasting or
telecommunications services to the general public. The majority of applications are for the
purchase of equipment such as transmitters, TV cameras, recorders, and other hardware for the
transmission and production of TV or radio programs.
Each proposal reflects the unique needs of the applicant organization, but PTFP needs an
organized and uniform method to evaluate one project against another in order to award grants.
The requests always exceed available appropriations, usually by more than 2 to 1.
Standard Forms: In accordance with OMB Circulars and Department of Commerce regulations
on grants management, DOC/NTIA uses standard forms to receive information from applicants.
These forms include the SF-424, SF-424A, SF-424B, SF-LLL, and CD-511. The burden-hours
involved with these forms are not reflected in this request.
The forms contained in the proposed information collection will supplement the Standard Forms
and enable PTFP to review data about:
a. Type of equipment requested, the urgency or need for the equipment, and whether the
requested item(s) will do the job most efficiently and economically;
b. Financial resources of the applicant, to ensure that the organization will be a viable service
provider for the ten-year Federal interest period required by the authorizing legislation and will
have the required local matching funds;
c. Whether, in accordance with the authorizing legislation, Special Consideration should be
given to the applicant for ownership/control by, or programming targeted to, minorities and/or
women;

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d. Proof of eligibility for the program and proof of compliance with applicable Federal laws
and regulations for grant applicants;
e. Information regarding permits issued by the Federal Communications Commissions
required to construct the requested facilities; and
f. Information about other stations which serve the applicant=s coverage area which is used to
determine the application=s Priority under the PTFP Rules.
The PTFP-2 Form requests information about the project to assist in the review process,
including whether any authorizations are required from the Federal Communications
Commission in order for the project to proceed, whether any other public radio or television
stations provide a signal to the applicant=s intended service area, and the number of people that
will be served within the station=s coverage area.
The PTFP-4 Form requests information about the equipment the applicant proposes to purchase
with the requested funds, including the model, number of items, and prices. The PTFP-5 Form
requests information on applicant=s current equipment that will be replaced by the requested
equipment. Both the PTFP-4 and PTFP-5 Forms are used to evaluate the need for the requested
equipment and the appropriate funding level if a grant is offered.
Under Department Commerce procedures for grant management (DAO 203-26), NTIA conducts
a competitive review process that includes evaluation of each application by PTFP Program
Officers, staff engineers, a review panel of representatives of national public broadcasting
organizations, and a review panel of personnel from the professional public telecommunications
field outside the DOC. Each reviewer provides comments and funding recommendations that
are evaluated by PTFP management. Award decisions are made by the Assistant Secretary from
the recommendations developed through this review process. Awards are usually announced
about six to eight months after the application deadline.
The information will not be disseminated to the public.

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.
PTFP has made the application form available for on-line preparation, and approximately twothirds of PTFP applicants use this Internet-based technology. PTFP is also participating in the
grants.gov program and has requested that the forms in this submission be included on the
grants.gov website as quickly as possible after approval.

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4. Describe efforts to identify duplication.
The applications submitted by various organizations in any grant cycle do not duplicate each
other because each is unique to the needs, location, and service of the individual applicant.
PTFP requests information on whether the applicant has sought funds for its project from another
Federal agency or the Corporation for Public Broadcasting.

5. If the collection of information involves small businesses or other small entities,
describe the methods used to minimize burden.
Many PTFP applicants are small entities, and the information requested has been kept to a
minimum to ensure that they are able to comply with the least possible burden. The present
request is for renewal of the existing information collection and no new requirements have been
added.

6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
NTIA must solicit grant applications in every year in which the Congress passes an appropriation
for the program or violate the intent of Congress by not making the funds available. It would be
impossible to make grant awards without the required competitive review process that begins
with the submission of the information in the proposed collection.

7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
NTIA requests an original and five copies of the application form that are submitted in hard
copy. The three additional copies of the application form are to be mailed to reviewers around
the country who will evaluate the applications at their homes or offices. Using this method,
NTIA will be able to expand the pool of reviewers and increase public participation in the PTFP
application process.
The burden on the individual applicant to provide these additional three copies will be minimal.
We anticipate the typical application submitted in response to this collection to consist of 30
pages or fewer. At a cost of 10 cents a page, the cost of photocopying three additional copies
would be less than $10 per applicant (30 pages x 3 copies x .10/copy = $9.00). This amount of
copying would be burdensome for PTFP. We estimate that it would take one staff person almost
two full weeks to disassemble the applications, photocopy over 27,000 pages of material.
(300 applications x 30 pages x 3 copies) and reassemble the applications. The two weeks of
photocopying would also lengthen the application review process, thereby delaying the awarding
of grants.
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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 record keeping, disclosure, or reporting format (if any), and on the data
elements to be recorded, disclosed, or reported.
A notice was published in the Federal Register on September 2, 2009, page 45420, soliciting
public comments on the information collection. No comments were received.
NTIA conducts an annual consultation with the Corporation for Public Broadcasting (CPB) and
other public broadcasting organizations and associations. These entities are free to comment on
any aspect of the grant program on behalf of their constituents. NTIA has not specifically placed
the PTFP application form before these organizations or associations, but many of the public TV
and radio stations, which compose their membership, have received PTFP grants. If those
grantees had problems with the application requirements, the organizations and associations
representing them could have brought those problems to the attention of NTIA/PTFP. NTIA
solicits comments about the application process from potential applicants as part of the
application cycle. NTIA staff members also attend industry meetings, symposia, and seminars
on a regular basis to discuss the program in general.

9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
Not applicable.

10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
NTIA complies with the Privacy Act of 1974 and the Freedom of Information Act. The
information requested by PTFP does not include any sensitive questions applicants need to
answer.

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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.
The information requested by PTFP does not include any sensitive questions applicants need to
answer.

12. Provide an estimate in hours of the burden of the collection of information.
Burden Hours Calculation
On-Line
Responses

Paper
Responses

Total
Burden
Hours

Requirement
No. of
Applicants

Hours/
Applicant

No. of
Applicants

Hours/
Applicant

Original Submission

200

74.5

100

83.5

Resubmissions*

75

4

40

7
Total

23,250
580
23,830

*In every grant cycle. PTFP requires revised information to be submitted by applicants
under serious consideration for awards.
The method of calculating the number of responses NTIA receives each year for each of the
reporting requirements is laid out in the table above. Program officials believe the
calculations accurately reflect the burden imposed by each element in the reporting and the
number of respondents to each element in any one year.

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
Question 12 above).
The cost to respondents will, in most cases, be part of the organization=s normal cost of doing
business. No technical reports, such as audited financial statements requiring outside
preparation, are required as part of the application process.
As stated in Question 7, NTIA will request three additional copies of hard copy applications.
The cost to the applicants is estimated to be $2,700 (300 applicants X $9).

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14. Provide estimates of annualized cost to the Federal government.
The annual budget for administration of the PTFP is $2 million. This includes activities for
application solicitation, review, approval, processing, and monitoring. PTFP staff costs cannot
be broken out separately by function of application processing because individuals supported by
this budget are involved in all of these activities.

15. Explain the reasons for any program changes or adjustments.
A cost burden adjustment increase ($2,700) is required to include the cost of photocopying
additional copies of the application submission.

16. For collections whose results will be published, outline the plans for tabulation and
publication.
Not applicable.

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.
Not applicable.

18. Explain each exception to the certification statement.
Not applicable.

Section B. Collection of Information Employing Statistical Methods
The information collection for the Public Telecommunications Facilities Program does not
employ statistical methods.

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