OMB Supporting Statement Part A

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Driver Alcohol Detection System for Safety (DADSS)

OMB: 2127-0669

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Information Collection Supporting Statement A

Focus Group Review of Advanced Alcohol Detection Technology


Submitted by


National Highway Traffic Safety Administration










Table of Contents


A.1. Explain the circumstances that make the collection of information necessary.. A-2

A.2. Indicate how, by whom, and for what purpose the information is to be used. A-3

A.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. A-4

A.4. Describe efforts to identify duplication. A-4

A.5. If the collection of information impacts small businesses or other small entities, describe methods used to minimize burden. A-5

A.6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden. A-5

A.7. Explain any special circumstances that would cause the information collection to be conducted in a manner inconsistent with the guidelines set forth in 5 CFR 1320.6. A-5

A.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 collection prior to submission to OMB.. A-5

A.9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees. A-6

A.10. Describe any assurance of confidentiality provided to respondents. A-6

A.11. Provide additional justification for any questions of a sensitive nature A-6

A.12. Provide estimates of the hour burden of the collection of information on the respondents. A-7

A.13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information. A-7

A.14. Provide estimates of annualized cost to the Federal government. A-8

A.15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1. A-8

A.16. For collections of information whose results will be published, outline plans for tabulation, and publication. A-8

A.17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate. A-8

A.18. Explain each exception to the certification statement identified in Item 19, Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-1. A-9




INFORMATION COLLECTION

SUPPORTING STATEMENT


Focus Group Review of Advanced Alcohol Detection Technology


Approval is requested to conduct a set of focus groups with drivers to gauge public perceptions regarding advanced, in-vehicle alcohol detection technology. The focus groups will be conducted with licensed drivers.


A. Justification


A.1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.


a. Circumstances necessitating the data collection.


  1. National Highway Traffic Safety Administration (NHTSA) mission


The NHTSA was established by the Highway Safety Act of 1970 (23 U.S.C. 101). Its Congressional mandate is to reduce the number of deaths, injuries, and economic losses resulting from motor vehicle crashes on our nation’s highways. To accomplish this mission, NHTSA sets and enforces safety performance standards for motor vehicle equipment and provides funding to State and local governments for their use in supporting highway safety activities, including demonstration and evaluation programs. NHTSA also conducts research on driver behavior and traffic safety to develop efficient and effective means of bringing about safety improvements.


  1. Severity of the Alcohol-Impaired Driving Problem

In 2008, 11,773 people were killed in alcohol-impaired-driving crashes. Drivers are considered to be alcohol-impaired when their blood alcohol concentration (BAC) is .08 grams per deciliter (g/dL) or higher. These alcohol-impaired-driving fatalities accounted for 32 percent of the total motor vehicle traffic fatalities in the United States. Moreover, in these fatal crashes in 2008 the highest percentage of drivers with a BAC level of .08 or higher was for drivers ages 21 to 24 (34%), followed by ages 25 to 34 (31%) and 35 to 44 (25%).


In a continuing effort to reduce the adverse consequences of alcohol-impaired driving, NHTSA in conjunction with the Automotive Coalition for Traffic Safety (ACTS) is undertaking research and development to explore the feasibility of, and public policy challenges associated with, use of in-vehicle alcohol detection technology. The agency believes that use of vehicle-based, alcohol detection technologies could help to significantly reduce the number of alcohol-impaired driving crashes, deaths and injuries by preventing drivers from driving while their blood alcohol concentration (BAC) is at or above the legal limit. In 2008, ACTS and NHTSA entered into a 5-Year Cooperative Agreement to “explore the feasibility, the potential benefits of, and the public policy challenges associated with a more widespread use of unobtrusive technology to prevent drunk driving”. The goal of the Driver Alcohol Detection System for Safety (DADSS) project is, through a step-by-step, data driven process, to develop and test prototypes that may be considered for vehicle integration thereafter.


As technology development progresses and decisions are being made about how to integrate such technology into vehicles, NHTSA needs a better understanding of public preferences with respect to in-vehicle alcohol detection devices. Optimization of technology and public acceptance of it once deployed will depend on the extent to which public attitudes are taken into account during the development process. Thus NHTSA seeks input from drivers to:

  • Gauge public perceptions of advanced in-vehicle alcohol detection technology;

  • Guide the technology design; and

  • Guide a strategy for introduction of this technology.


NHTSA believes that focus groups with licensed drivers are the appropriate method for obtaining information to address the above topics.


b. Legal basis for collecting data


NHTSA has statutory authority to conduct crash injury research and collect relevant data in the interest of public health. Specifically, NHTSA is authorized to: (1) engage in research on all phases of highway safety and traffic conditions; (2) undertake collaborative research and development projects with non-federal entities for the purposes of crash data collection and analysis; and (3) conduct research and collect information to determine the relationship between motor vehicles and accidents, and personal injury or deaths resulting from such accidents.


The Highway Safety Act of 1966, Title 23 United States Code, Section 403 (a,b,c,d) and the National Traffic and Motor Vehicle Safety Act of 1966, Title 15 United States Code 1395, Section 106 (b), give the Secretary authorization to conduct research, testing, development, and training as authorized to be carried out by subsections of these titles.  The Vehicle Safety Act was subsequently re-codified under Title 49 of the U.S. Code in Chapter 301, Motor Vehicle Safety.  See Title 23 Section 403 and Title 49 Chapter 301 for further information.



A.2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.


NHTSA proposes to conduct a total of 24 focus groups in two stages. The first set of focus groups (12 focus groups) will obtain information on public perceptions and attitudes concerning in-vehicle alcohol detection technology designed to prevent alcohol-impaired driving. Perceptions of, and reactions to, technology will be explored. General concepts of in-vehicle technology will be provided, and the focus group participants will be asked questions such as the following:


  • To what extent would this inconvenience you?

  • What concerns you about this technology?

  • How would you feel if the system detected that you had been drinking and request a breath sample from you?

  • How would you feel if the system prevented you from driving the vehicle if you registered over the legal limit?


Focus group participants will also be asked about their initial reactions to potential methodology currently being investigated to measure BAC. Information from this phase of the project will be used by NHTSA and the DADSS research team to provide input to decision making regarding vehicle integration with respect to the technology under investigation. The information will also be used to identify potential barriers to acceptance of the technologies.


A second set of 12 focus groups to be conducted once technology development is further along will gauge driver reaction to technology prototypes, obtain input on alternative prototype features, and obtain guidance on strategies for introduction of the technology into the vehicle fleet.


NHTSA believes that the focus group methodology is the best way to gain an in-depth understanding of how drivers feel about new technology. The focus group format will allow respondents to comment on the areas that they think are most important. The data collected from the focus groups will be used to assist NHTSA in identifying (1) potential barriers to advanced alcohol-detection technologies, (2) strategies for addressing barriers, and (3) strategies for introducing advanced technology to the driving public. The results will assist NHTSA and others involved in advanced technology development in building an understanding among the driving public of the concept of advanced impairment detection technology and support for its integration into the vehicle fleet.



A.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. Also describe any consideration of using information technology to reduce burden.


The focus group meetings will be audio taped for subsequent use by the facilitator in preparing a summary report of each focus group meeting. No one other than the focus group facilitator, other contractor personnel and NHTSA staff involved with this project will have access to these audiotapes. Additional automatic, electronic, mechanical, or other technological collection techniques are not needed for focus groups and will not be used.



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


The unique in-vehicle alcohol detection technologies that will be the subject of the focus groups are currently in development. The concepts and prototypes have not been introduced to drivers. Consequently, drivers have not been able to provide feedback on the concepts, nor indicate their level of acceptance. Hence, there is no duplication of effort.



A.5. If the collection of information impacts small businesses or other small entities, describe methods used to minimize burden.


There will be no impact on small businesses or other small entities. Individuals will participate in the focus groups on their own time, not during working hours.



A.6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.


If the proposed information collection activities are not conducted, NHTSA cannot be certain that the new in-vehicle alcohol detection technology will be acceptable to the driving public if deployed in automobiles. As NHTSA has found in the past, when seat belt ignition interlocks were mandated for vehicles in the 1970s, if driver perceptions and driving behaviors are not taken into account as the technology is being developed, negative public sentiments can quickly derail their implementation. The focus groups are designed to provide NHTSA with information on potential concerns about, and barriers to, new advanced impairment detection technology so that NHTSA can address these concerns as the technology is being developed. If the focus groups are not conducted, NHTSA will be denied important information critical to building understanding of, and support for, new emerging technologies.



A.7. Explain any special circumstances that would cause the information collection to be conducted in a manner inconsistent with the guidelines set forth in 5 CFR 1320.6.


No special circumstances require the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.6.



A.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 collection prior to submission to OMB. Summarize public comments received in response to that notice 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.


As required by the Paperwork Reduction Act of 1995, NHTSA published two notices in the Federal Register, as noted below.


  1. Federal Register Notice


NHTSA published a notice in the Federal Register with a 60-day public comment period to announce this proposed information collection on May 6, 2010, Volume 75, Number 87, pages 25033-25034.


NHTSA published a notice in the Federal Register on August 31, 2010 (Volume 75, Number 168, pages 53369-53370) with a 30-day public comment period to announce that NHTSA intended to forward the request for the proposed information collection to OMB.



  1. Responses to the Federal Register Notice


NHTSA did not receive any comments in response to the Federal Register notice published on May 6, 2010.


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


It is standard practice to reimburse focus group respondents for their time and out of pocket expenses.  NHTSA will provide, on average, $75.00 payment as reimbursement for expenses and compensation for their time.  Compensation will vary based on requirements of each study (e.g., duration, location).  It is unrealistic to expect respondents to incur expenses (e.g. to travel to a focus group location, pay for parking, etc.) as a result of participation.  In many locations, without some form of reimbursement and compensation it would be virtually impossible to recruit participants.



A.10. Describe any assurance of confidentiality provided to respondents.


At the start of the focus group, the facilitator will tell the participants that their names will not be used in any report. The facilitator will also explain that the report to NHTSA will contain only a summary of the comments that reflects both consensus and minority opinions.



A.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 process for screening and selecting focus group participants requires that candidates answer a question with regard to their drinking behavior. As the in-vehicle technology being developed will screen drivers for use of alcohol and will ultimately affect those whose drinking is likely to impair their driving performance, NHTSA feels it is important to obtain feedback from this segment of the driving population. It is also important to gauge the reactions of those who do not drink, or drink and drive, as they could perceive that the technology is unnecessary for them. Asking about drinking behavior is the only means to assure that these individuals are included in the focus groups.



A.12. Provide estimates of the hour burden of the collection of information on the respondents.


NHTSA estimates that each focus group will involve 8 participants and will last 1½ hr. The total hour burden is 288 hours for the 192 focus group participants across the 24 focus groups.


While the participants will be remunerated, the time they spend in the focus group can still be looked at in terms of what it would have cost if the respondents had spent that amount of time on a task while on the job. The total number of estimated reporting burden hours on the general public would be 288 for the proposed focus groups. At $20.90* per hour, the total annual estimated cost associated with the burden hours is: $20.90 x 288 hours for a total of $6,019.20. Respondents would not incur any other reporting cost from the information collection.



TABLE 2.

COST BURDEN ON RESPONDENTS

Population

N

Cost per Hour

Focus Group Length (hr)

Total Cost

Focus group participants

192

$20.90

1.5

$6,019.20

TOTAL

192

$20.90

1.5

$6,019.20

*From http://www.bls.gov/oes/current/oes_nat.htm#b00-0000, All occupations, Mean Hourly Wage Estimate; viewed June 24, 2010.



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


The focus group participants will not incur any record keeping or reporting costs from this information collection.




A.14. Provide estimates of annualized cost to the Federal government.


Total estimated cost to the government for conducting the focus groups is as follows:



Phase 1


Preparation Work

$16,000

Conduct focus groups (4 locations)

$54,000

Summary Report

$17,000

Phase 2


Preparation Work

$16,000

Conduct focus groups (4 locations)

$54,000

Summary Report

$17,000



Total Cost

$174,000


A.15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.


This is a new collection of information for a one-time study, whereby increasing NHTSA’s total burden hour by 288 burden hours.



A.16. For collections of information whose results will be published, outline plans for tabulation, and publication.


A summary report will be prepared for the results of each set of 12 focus groups. The report for each set of focus groups will describe the locations, the number of participants in each focus group, procedures for recruitment and selection of participants, and a summary of the range of responses to each focus group topic.


Activity

Date

Focus group preparation

January 2010 – June 2010

Conduct focus groups, Phase 1

December 2010 – March 2011

Prepare focus group summary report, Phase 1

June 2011

Focus group preparation

December 2011 – January 2012

Conduct focus groups, Phase 2

February 2012 – March 2012

Prepare focus group summary report, Phase 2

June 2012



A.17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.


Approval is not sought to not display the expiration date.



A.18. Explain each exception to the certification statement identified in Item 19, Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-1.


No exceptions to the certification statement are made.



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