SuppStmt.BTOP. Baseline_MarQtr.040510

SUPPORTING STATEMENT
U.S. Department of Commerce
National Telecommunications and Information Administration
Broadband Technology Opportunities Program
Post-Award Baseline Report and March 2010 Performance Progress Report
OMB Control No. 0660-XXXX

A. JUSTIFICATION
This emergency review request is required for NTIA to collect performance information from
grant recipients through reporting and monitoring to comply with Recovery Act, OMB, and
DOC statutory and regulatory requirements.
The requested due date is April 12, 2010.
1. Explain the circumstances that make the collection of information necessary.
The American Recovery and Reinvestment Act of 2009 (Recovery Act) establishes and provides
$4.7 billion for the Broadband Technology Opportunities Program (BTOP) and directs that these
funds be awarded by September 30, 2010. Of these funds, at least $200 million will be made
available for competitive grants to expand public computer center capacity; at least $250 million
will be made available for competitive grants for innovative programs to encourage sustainable
adoption of broadband service; 1 and up to $350 million will be made available to fund the State
Broadband Data and Development Grant Program (Broadband Mapping Program) authorized by
the Broadband Data Improvement Act. 2 The Broadband Mapping Program is designed to
support the development and maintenance of a nationwide broadband map for use by
policymakers and consumers. 3
Section 6001 of the Recovery Act establishes five core purposes to be advanced by projects
funded under BTOP:
(1) To provide access to broadband service to consumers residing in unserved areas of the
country;
(2) To provide improved access to broadband service to underserved areas of the country;
(3) To provide broadband access, education, and support to community anchor institutions (e.g.,
schools, libraries, medical facilities), or organizations and agencies serving vulnerable

1

See American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-5, 123 Stat. 115, 128 (2009). 

2

Pub. L. No. 110-385, 122 Stat. 4096 (to be codified at 47 U.S.C. § 1301 et seq.). 

3

See State Broadband Data and Development Grant Program, Notice of Funds Availability and Solicitation of
Applications, 74 Fed. Reg. 32545 (July 8, 2009).  

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populations (e.g., low-income, unemployed, aged), or job-creating strategic facilities located in
state or federally designated economic development areas;
(4) To improve access to, and use of, broadband service by public safety agencies; and
(5) To stimulate the demand for broadband, economic growth, and job creation. 4
In addition, the Recovery Act stipulates that The Assistant Secretary of Commerce for
Communications and Information:
“…shall create and maintain a fully searchable database, accessible on the
Internet at no cost to the public, that contains at least a list of each entity that has
applied for a grant under this section, a description of each application, the status
of each such application, the name of each entity receiving funds made available
pursuant to this section, the purpose for which such entity is receiving such funds,
each quarterly report submitted by the entity pursuant to this section, and such
other information sufficient to allow the public to understand and monitor grants
awarded under the program.” 5
The Office of Management and Budget also requires agencies administrating grant programs to
implement post-award financial and performance reporting for those programs. 6 Finally, the
Department of Commerce Uniform Administrative Requirements for Grants authorizes NTIA to
require performance reports from BTOP grant recipients. 7
A general description of the performance reporting requirements for recipients of BTOP grants
was included in the Notice of Funds Availability (NOFA) published on July 9, 2009 for the first
round of funding and in the NOFA published on January 26, 2010, for the second round of
funding. 8 NTIA needs performance reporting information specific to Infrastructure and
Comprehensive Community Infrastructure (CCI), Public Computer Center (PCC), and
Sustainable Broadband Adoption (SBA) projects in order to effectively monitor, manage and
evaluate the program.

4

See American Recovery and Reinvestment Act of 2009, Pub. L. 111-5, Stat.115 (2009), § 6001(a)-(b). 

5

 See American Recovery and Reinvestment Act of 2009, Pub. L. 111-5, Stat.115 (2009), §6001 (i)(5) (emphasis
added). 

6
 See OMB Circular A-102, Grants and Cooperative Agreements with State and Local Governments, (REVISED
10/7/94, As Further Amended 8/29/97), §2(a); OMB Circular A-110, Uniform Administrative Requirements for
Grants and Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations,
(REVISED 11/19/93, As Further Amended 9/30/99), Subpart C, §21; OMB Circular A-136, Financial Reporting
Requirements, (REVISED 6/10/09), §II.3.

7
Department of Commerce Uniform Administrative Requirements for Grants, §14.51. 
8

 See Broadband Initiatives Program and Broadband Technology Opportunities Program, Notice of Funds
Availability (NOFA) and Solicitation of Applications, 74 Fed. Reg. 33122-33124 (July 9, 2009); and Broadband
Technology Opportunities Program, Notice of Funds Availability (NOFA) and Solicitation of Applications, 75 Fed.
Reg. 3810-3811 (January 22, 2010). 

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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.
NTIA will collect information on the performance of individual BTOP awards through baseline,
quarterly and annual performance reports. The baseline report, submitted once at the end of the
first quarter of the project’s period of performance, provides grant recipients an opportunity to
update baseline project information that may have changed from their original application.
The quarterly performance reports, submitted at the end of each quarter of the year, ask a series
of questions that broadly address project progress and monitoring needs of program personnel by
getting baseline (planned) and actual information on quarterly and cumulative project and
milestone progress, and potential project barriers, if any. The annual performance report,
submitted at the end of the federal fiscal year, asks a series of questions that broadly address
BTOP programmatic objectives and outcomes, NOFA requirements, and the information needs
of external audiences, such as OMB. This includes information on:


Broadband Infrastructure and CCI – Subscribers passed and served, improved vs. new
access for subscribers, pricing plans and broadband speeds available to subscribers, and
community anchor institutions served.



PCC – Hours of operation, speed of broadband service, average number of users per
week, training provided, equipment deployed, workstations available.



SBA – Awareness campaigns, training provided, equipment deployed, broadband
subscription rates. 9

NTIA administers the BTOP grant awards focusing on programmatic and policy issues. NTIA
coordinates with the grants management offices of the National Oceanic and Atmospheric
Administration (NOAA) and the National Institute of Standards and Technology (NIST) to
conduct grants administration. NOAA will be responsible for all Infrastructure and CCI awards
and NIST for PCC and SBA awards. BTOP program and grant managers across these agencies
will use grant recipient performance reports to:


Monitor the progress of all awards towards achieving project goals as well as one or more
statutory purposes of ARRA. 10



Assess the overall project management health of each BTOP award. For example: Are
recipients meeting their goals and objectives as stated in the grant award? Are recipients
on track to meet key milestones and complete the project on schedule? 11

9

BTOP Award Recipient Reporting Guidance, p. 6. 

10

Ibid. 

11

Ibid, p. 6. 

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

Determine the level of monitoring and – if necessary – assistance required for funded
projects. 12

Finally, NTIA will make performance reporting information available to the public through a
searchable online database, pursuant to the Recovery Act and the BTOP NOFA. Applicants’
proprietary information will remain confidential and will not be included in this database. 13
NTIA has taken special steps to ensure the maximum utility, accuracy, integrity, and objectivity
of the information to be collected in accordance with NTIA’s published Information Quality
Guidelines. 14 Program Officers and Grants Officers will verify the accuracy of performance
reporting information submitted by recipients through monitoring activities. These activities will
include frequent communication with recipients and may, under certain circumstances, also
include desk reviews of reports and/or site visits.

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.
NTIA intends for grant recipients to submit their performance progress reports through a postaward monitoring database/document transfer system. This system will be up and running by
June. Until then, all BTOP recipients will submit their reports directly to their Program Officers
via e-mail.
The post-award monitoring system will allow grant recipients to submit program-specific
performance and financial reports.15 It will interface with the BTOP application database as well
as NIST and NOAA’s grants management systems. Using data from these sources, it will
populate relevant sections of grant recipient reports so that grant recipients will not be forced to
re-enter information that exists elsewhere. Once the post-award monitoring system is online,
grant recipients will also be able to download PDF versions of reporting forms. The forms will
have fillable fields and may save the forms and submit them electronically.
Until the post-award monitoring system is available, Infrastructure and CCI recipients will
submit reports through the Grants Online systems and PCC and SBA recipients will email
reports to their Program Officers.

12

 Ibid, p. 8.

13

 See American Recovery and Reinvestment Act of 2009, Pub. L. 111-5, Stat.115 (2009), §6001 (i)(5); Broadband
Technology Opportunities Program, Notice of Funds Availability (NOFA) and Solicitation of Applications, 75 Fed.
Reg. 3811 (January 22, 2010); and Department of Commerce Uniform Administrative Requirements for Grants,
§14.53(f). 

14
See Section 515 Standards: Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and
Integrity of Information Disseminated by the National Telecommunications and Information Administration,
www.ntia.doc.gov/ntiahome/occ/ntiaiqguidelines_09252002.htm (Sept. 25, 2002).  
15

 Recovery Act reports will have to be submitted separately. 

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If any grant recipients have difficulty submitting their reports online, NTIA will work with them
to find alternative methods of submission (e.g., by mail).

4. Describe efforts to identify duplication.
NTIA has taken care to ensure that reporting forms will not ask for information already
submitted by grant recipients in their applications. Also, as previously mentioned, the post-award
monitoring system will populate relevant fields of reports with information NIST and NOAA’s
grant management systems as well as the BTOP application database.
BTOP performance reports ask specific questions relating to BTOP awards and their operational
performance. The main objective of the performance report is to capture key data and
information that are specific to BTOP and each recipient award. 16 This information can only be
collected from recipients, and is not available elsewhere.

5. If the collection of information involves small businesses or other small entities,
describe the methods used to minimize the burden.
BTOP grant recipients include a variety of small entities, including schools, local governments,
libraries, and for-profit and non-profit companies. All BTOP grant recipients are under the same
performance reporting obligations. If necessary, however, NTIA may grant deadline extensions.
Recipients will need to work with their Program and Grants Officers to seek approval for a
reporting extension.

6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
If it does not require quarterly reports from BTOP grant recipients, NTIA will not be able to
fulfill regulatory and statutory requirements imposed by OMB, the Recovery Act, and
Department of Commerce Uniform Administrative Requirements. 17 In addition, NTIA is
obligated by the Recovery Act to make post-award performance information available to the
public through an online database. 18

16

BTOP Award Recipient Reporting Guidance, p. 6. 

17

 See American Recovery and Reinvestment Act of 2009, Pub. L. 111-5, Stat.115 (2009), §6001 (i)(5); OMB
Circular A-102, Grants and Cooperative Agreements with State and Local Governments, (REVISED 10/7/94, As
Further Amended 8/29/97), §2(a); OMB Circular A-110, Uniform Administrative Requirements for Grants and
Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, (REVISED
11/19/93, As Further Amended 9/30/99), Subpart C, §21; OMB Circular A-136, Financial Reporting Requirements,
(REVISED 6/10/09), §II.3; and Department of Commerce Uniform Administrative Requirements for Grants,
§14.51. 

18
 See American Recovery and Reinvestment Act of 2009, Pub. L. 111-5, Stat.115 (2009), §6001 (i)(5); Broadband
Initiatives Program and Broadband Technology Opportunities Program, Notice of Funds Availability (NOFA) and
Solicitation of Applications, 74 Fed. Reg. 33122-33124 (July 9, 2009); Broadband Technology Opportunities

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In addition, NTIA must conduct this collection in order to gather specific information on BTOP
recipients’ use of funds, the impact of their projects on their service areas, and the effectiveness
of the BTOP program as a whole. Reviewing grant recipient reports for timeliness and accuracy
is an essential part of the monitoring process: BTOP program and grants managers use
information from reports to determine the level of monitoring and, if necessary, corrective action
required for individual grants.

7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
This information collection will be conducted in a manner consistent with the Office of
Management and Budget (OMB) guidelines.

8. Provide information for 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.
Due to the time constraints of this emergency review request, the Federal Register Notice was
waived by OMB.
NOAA and NIST are assisting NTIA with the development and implementation of program and
grants management for BTOP. In addition, NTIA engaged the services of Booz Allen Hamilton
to support the development of the post-award management process, including the associated
forms (the quarterly and annual performance reports), and to calculate burden estimates for the
program.

9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or recipients.
NTIA will not provide gifts or payments to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
NTIA will protect confidential and proprietary information in performance and financial reports
from public disclosure to the fullest extent authorized by applicable law, including the “Freedom

Program, Notice of Funds Availability (NOFA) and Solicitation of Applications, 75 Fed. Reg. 3811 (January 22,
2010); and Department of Commerce Uniform Administrative Requirements for Grants, §14.53(f). 

6 

of Information Act,” as amended (5 U.S.C. § 552 et seq.), the “Trade Secrets Act,” as amended
(18 U.S.C. § 1905 et seq.), and the “Economic Espionage Act of 1996,” as amended (18 U.S.C. §
1831 et seq.).

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.
This collection of information does not contain any questions of a sensitive nature.

12. Provide an estimate in hours of the burden of the collection of information.
NTIA developed burden estimates for the baseline, quarterly and annual reports in each funding
category (Infrastructure and CCI, PCC, and SBA) based on an activity breakdown analysis of the
reporting forms. A team of consultants reviewed the forms in detail. Each individual on the team
estimated how much time it would take for them to perform the following activities:







Reviewing instructions;
Collecting and processing information;
Adjusting existing practices to comply with the rules of the information collection;
Searching data sources;
Completing and reviewing the response (on a field-by-field basis); and
Transmitting or disclosing the information.

The analysis team then averaged out their hour burden estimates for each activity to produce a
final activity breakdown, which added up to the hour burden for individual forms in each funding
category. NTIA estimates that it will award roughly 300 grants in total, with awards – and
subsequently respondents to this collection – being divided among the three funding categories
as outlined in the tables below. 19

19

 These estimates describe individual and aggregate burden on an annual basis, not for the entire period of 
performance. 

7 

First Year*: Infrastructure and Comprehensive Community Infrastructure
(150 respondents)*
Annual
Responses
Required

Total Responses
Expected

Hour Burden Per
Response

Aggregate Hour
Burden

Baseline Report

1

150

3

450

First Quarter 2010
Report

1

150

1 hr 30 mins

225

TOTAL

2

300

---

675

Type of Form

*The first year of the grant period for all Round 1 awards will have a baseline report. The first quarter 2010 report will be an
abbreviated report. A separate information collection request will be submitted for the subsequent regular quarterly reports
and one annual report to be submitted by each grantee for the period of the grant.

First Year*: Public Computer Center (75 respondents)
Annual
Responses
Required

Total Responses
Expected

Hour Burden Per
Response

Aggregate Hour
Burden

Baseline Report

1

75

2 hrs 30 mins

187 hrs 30 mins

First Quarter 2010
Report

1

75

1 hr 30 mins

112 hrs 30 mins

TOTAL

2

150

---

300

Type of Form

*The first year of the grant period for all Round 1 awards will have a baseline report. The first quarter 2010 report will be an
abbreviated report. A separate information collection request will be submitted for the subsequent quarterly reports and one
annual report to be submitted by each grantee for the period of the grant.

First Year*: Sustainable Broadband Adoption (75 respondents)
Annual
Responses
Required

Total Responses
Expected

Hour Burden Per
Response

Aggregate Hour
Burden

Baseline Report

1

75

2 hrs 6 mins

157 hrs 30 mins

First Quarter 2010
Report

1

75

1 hr 30 mins

112 hrs 30 mins

TOTAL

2

150

---

270

Type of Form

*The first year of the grant period for all Round 1 awards will have a baseline report. The first quarter 2010 report will be an
abbreviated report. A separate information collection request will be submitted for the subsequent quarterly reports and one
annual report to be submitted by each grantee for the period of the grant.

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First Year*: Cumulative Total Responses and Hour Burden (300 respondents)
Project Category

Total Responses

Aggregate Hour Burden

Comprehensive Community
Infrastructure

300

675

Public Computer Center

150

300

Sustainable Broadband
Adoption

150

270

TOTAL

600

1,245**

*The first year of the grant period for all Round 1 awards will have a baseline report. The first quarter 2010 report will be an
abbreviated report. A separate information collection request will be submitted for the subsequent quarterly reports and one
annual report to be submitted by each grantee for the period of the grant.
**Due to rounding of figures, 1,246 hours in ROCIS.

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).
There is no additional cost burden to the respondents resulting from this collection of
information.

14. Provide estimates of annualized cost to the Federal government.
NTIA intends to make all grant awards by September 30, 2010. The costs to the federal
government for this information collection also will include: (1) NTIA staffing; (2) Contract
Services to support grants processing and monitoring; (3) Grants Office Services to make
financial awards; and (4) other related expenses. The administrative budget ceiling in the
Recovery Act for BTOP equals $141 million.
This is a non-recurring collection of limited cost to NTIA. NTIA will collect and store the
information in electronic format for a maximum of 600 responses and will not need to acquire
additional information systems for the collection and storage of the data. Therefore, costs
associated with printing, equipment, and support services are incidental to general NTIA
administrative and infrastructure costs. The cost to review responses is a small portion of the
salaries of staff time assigned to the program. Total staff time is not expected to exceed 600
hours, which is less than 1% of total program staff time
Estimated Cost: 600 hours at $55 per hour (based on GS-14 staff salary) = $33,000.

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15. Explain the reasons for any program changes or adjustments.
This is a new information collection.

16. For collections whose results will be published, outline the plans for tabulation and
publication.
As announced in the NOFA for the second round of BTOP funding and mentioned in the answer
to Question 2, information from grant recipients’ performance reports will be made available to
the public via a searchable online database populated from the post-award monitoring system. 20
NTIA is required to make publicly available on the Internet a list of each entity that has applied
for a grant, a description of each application, the status of each application, the name of each
entity receiving funds, the purpose for which the entity is receiving the funds, each quarterly
report, and other information as the Assistant Secretary deems necessary to meet BTOP
objectives. 21

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. The expiration date for OMB approval will be displayed on the paper and
electronic versions of the applications.

18. Explain each exception to the certification statement.
No exceptions are requested.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
The collection of information will not employ statistical methods.

20

 See Broadband Technology Opportunities Program, Notice of Funds Availability (NOFA) and Solicitation of
Applications, 75 Fed. Reg. 3811 (January 22, 2010).

21
See American Recovery and Reinvestment Act of 2009, Pub. L. 111-5, Stat.115 (2009) § 6001(i)(5), 123 Stat. at
515. 

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