0660.0037.SuppStmt.11192010.FINAL

SUPPORTING STATEMENT
U.S. Department of Commerce
National Telecommunications and Information Administration
Broadband Technology Opportunities Program (BTOP)
Quarterly and Annual Performance Progress Reports
OMB Control No. 0660-0037

A. JUSTIFICATION
This request for extension and revision of a currently approved collection of information 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.
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) (“Recovery
Act”).

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).

1

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’s implementation of OMB’s Uniform Administrative Requirements
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
4

See Recovery Act § 6001(a)-(b), 123 Stat. at 512-13.

5

See id. § 6001(i)(5), 123 Stat. at 515 (emphasis added).

6

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

See Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education,
Hospitals, and Other Non-Profit and Commercial Organizations, 15 C.F.R. Part 14; Uniform Administrative
Requirements for Grants and Cooperative Agreements to State and Local Governments, 15 C.F.R. Part 24.

8

See Broadband Initiatives Program and Broadband Technology Opportunities Program, Notice of Funds
Availability (NOFA) and Solicitation of Applications, 74 Fed. Reg. 33104, 33122-24 (July 9, 2009) (“First
NOFA”); Broadband Technology Opportunities Program, Notice of Funds Availability (NOFA) and Solicitation of
Applications, 75 Fed. Reg. 3792, 3810-11 (Jan. 22, 2010) (“Second NOFA”).
2

Sustainable Broadband Adoption (SBA) projects in order to effectively monitor, manage and
evaluate the program.
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 quarterly
and annual performance progress reports (PPRs). The quarterly performance progress reports,
submitted at the end of each quarter of the calendar year, ask a series of questions that broadly
address project progress and monitoring needs of program personnel by obtaining actual
information on quarterly and cumulative project and milestone progress, and potential project
barriers, if any. The annual performance progress report, submitted at the end of the calendar
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 is 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

See BTOP Recipient Handbook FY 2010, Recipient Reporting, ch. 5(Nov. 2010),
http://www2.ntia.doc.gov/files/Recipient_Handbook_v1.1_11-9-10_Final.pdf.
10

Id.

11

Id.
3

•

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. On a quarterly
basis, NTIA will also publicly post a data extract in Excel format that contacts a subset of key
metrics and performance data from each report. Recipients’ 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 will have grant recipients submit their performance progress reports through a post-award
monitoring database/document transfer system.
The post-award monitoring system will allow grant recipients to submit program-specific
performance and financial reports. 15 The system was launched in July 2010, and recipients
started submitting supports through this system for the quarter ending July 30, 2010 in August
2010. It will interface with the BTOP application database as well as NIST and NOAA’s grants
management systems. Using data from these sources, will populate relevant sections of grant
recipient reports so that grant recipients will not be forced to re-enter information that exists
elsewhere. Grant recipients will also be able to download PDF versions of reporting forms. The
forms have fillable fields and users may save the forms and submit them electronically.
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).

12

Id.

13

See Recovery Act § 6001(i)(5), 123 Stat. at 515; Second NOFA, 75 Fed. Reg. at 3811.

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,
available at www.ntia.doc.gov/ntiahome/occ/ntiaiqguidelines_09252002.htm (Sept. 25, 2002).

15

Recovery Act reports are submitted separately.
4

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 from NIST and
NOAA’s grant management systems as well as the BTOP application database.
BTOP performance progress 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’s implementation of OMB’s Uniform Administrative Requirements. 17
In addition, NTIA is obligated by the Recovery Act to make post-award project performance
information available to the public through an online database. 18
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

16

See BTOP Recipient Handbook FY 2010, Recipient Reporting, ch. 5(Nov. 2010), available at
http://www2.ntia.doc.gov/files/Recipient_Handbook_v1.1_11-9-10_Final.pdf.
17

See, e.g., Recovery Act, § 6001(i)(5) 123 Stat. at 515; OMB Circular A-102, § 2(a); OMB Circular A-110,
Subpart C, § 21; OMB Circular A-136, § II.3; see also Uniform Administrative Requirements for Grants and
Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit and Commercial Organizations,
15 C.F.R. Part 14; Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local
Governments, 15 C.F.R. Part 24.
18

See Recovery Act, § 6001 (i)(5) 123 Stat. at 515; First NOFA, 74 Fed. Reg. at 33122-24; Second NOFA, 75 Fed.
Reg. at 3811; Department of Commerce Uniform Administrative Requirements for Grants, § 14.53(f).
5

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 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 soliciting public comment was published on September 15, 2010
(Volume 75, pg. 56057). No comments were received in response to this notice.
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 PPRs), 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
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.).

6

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.
Not applicable.

12. Provide an estimate in hours of the burden of the collection of information.
NTIA developed burden estimates for the 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 awarded 233 grants in total, with awards – and subsequently respondents to this
collection – being divided among the three funding categories as outlined in the tables on the
following page. 19
Infrastructure and Comprehensive Community Infrastructure (123 respondents)

19

Type of Form

Annual Responses
Required

Total Responses
Expected

Hour Burden Per
Response

Aggregate Hour
Burden

Quarterly Report

4

492

5.02

2,468

Annual Report

1

123

3.94

484

TOTAL

5

615

4.80 (Average)

2,952

These estimates describe individual and aggregate burden on an annual basis, not for the entire period of
performance.
7

Public Computer Center (65 respondents)
Type of Form

Annual Responses
Required

Total Responses
Expected

Hour Burden Per
Response

Aggregate Hour
Burden

Quarterly Report

4

260

4.57

1,188

Annual Report

1

65

2.23

145

TOTAL

5

325

4.1 (Average)

1,333

Sustainable Broadband Adoption (45 respondents)
Type of Form

Annual Responses
Required

Total Responses
Expected

Hour Burden Per
Response

Aggregate Hour
Burden

Quarterly Report

4

180

3.97

715

Annual Report

1

45

3.04

137

TOTAL

5

225

3.78 (Average)

851

Total Responses and Hour Burden for this Collection (233 respondents)
Project Category

Total Responses

Aggregate Hour Burden

Comprehensive Community Infrastructure

615

2,952

Public Computer Center

325

1,333

Sustainable Broadband Adoption

225

851

TOTAL

1,165

5,137

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.
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
8

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 recurring collection of limited cost to NTIA. NTIA will collect and store the
information in electronic format for a maximum of 1,165 responses annually 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 annual staff time is not expected to exceed
1,165 hours, which is less than 2% of total program staff time
Estimated Cost: 1,165 hours annually at $55 per hour (based on GS-14 staff salary) =$64,075.
15. Explain the reasons for any program changes or adjustments.
Below is a summary of revisions to the performance progress reports (program changes).
As noted below, the revisions will improve the quality of the data collected, eliminate
unnecessary burden, and produce information more closely tailored to NTIA’s monitoring needs.
Form and Question

Revision

Reason

All PPR forms, many
questions

Increase the word limits for many
questions.

Feedback from recipients and federal staff
indicated that recipients would prefer
additional space to respond.

All PPR forms, instruction
section

Clarify the meaning of many
metrics.

Clarifying the information requested will
reduce recipient confusion and improve the
quality of the data that NTIA receives.

All PPR forms, “General
Information,” Question 3

Delete request for Employer
Identification Number

NTIA determined that this information is not
necessary.

Annual PPR for
Infrastructure/CCI,
“Overall Project
Performance Indicators,”
Question 2

Conform text of question to the text
in the instructions section and the
information requested in the table
below.

NTIA made this change to correct a clerical
error.

Annual PPR for
Infrastructure/CCI,
“Overall Project
Performance Indicators,”
Question 3

Add request for information about
parties the recipient is negotiating
with or to whom the recipient has
denied a request for interconnection.

NTIA needs to collect this information to
monitor compliance and inform external
stakeholders about the interconnection
policies of BTOP Infrastructure and CCI
recipients.

9

Form and Question

Revision

Reason

Annual PPR for
Infrastructure/CCI,
“Overall Project
Performance Indicators,”
Question 3

Remove request for names of
specific providers with whom
recipient has executed new
agreements.

Recipients frequently consider this
information sensitive and confidential, and
NTIA does not believe that it is necessary for
monitoring purposes to collect this
information from every Infrastructure and
CCI recipient.

Annual PPR for
Infrastructure/CCI,
“Overall Project
Performance Indicators,”
Question 4

Request the total number of anchor
institutions in the service area
instead of the number of anchor
institutions “passed.”

NTIA believes that the information elicited
by the revised has the same utility as the
information elicited by the original question,
but the revised question is less likely to be
misinterpreted by recipients.

Annual PPR for
Infrastructure/CCI,
“Overall Project
Performance Indicators,”
Question 7

Add request for information about
limitations on consumer access to
lawful content, service provider, or
application, or preventing
consumers from attaching legal
devices to the network.

NTIA needs to collect this information to
monitor compliance and inform external
stakeholders about the nondiscrimination
policies of BTOP recipients.

Annual PPR for
Infrastructure/CCI,
“Overall Project
Performance Indicators,”
Question 9

Change the request for the number
of fiber strands to a request for the
number of strand-miles.

NTIA believes that this change will provide
more useful information about project impact
without significantly increasing the burden
on recipients.

Quarterly PPR for
Infrastructure/CCI,
“Overall Project
Performance Indicators,”
Question 9

Instruct recipients to list all anchor
institutions connected during the
quarter, instead of all anchor
institutions connected since award
inception.

NTIA believes that requiring a cumulative
listing of institutions connected is
unnecessary because the institutions
connected in previous quarters should be
listed in those quarters’ reports.

Annual PPR for Public
Computer Centers, “Project
Indicators,” Question 7b

Delete Question 7b

Although this information would be useful,
NTIA is concerned that many recipients will
not have it available because collection of
this data was not requested in the application.

Quarterly PPR for Public
Computer Centers, “Project
Indicators (This Quarter)”
and “Project Indicators
(Next Quarter),” Question
2

Split the space for the narrative
response into separate lines for each
milestone.

This format will enable recipients to align
their narratives to the milestones to which
they relate.

10

Form and Question

Revision

Reason

Quarterly PPR for Public
Computer Centers, “Project
Indicators (This Quarter),”
Question 4b

Clarify that “average users per
week” should not be reported
cumulatively.

NTIA believes that the revised calculation
will be easier for recipients, and the result
will be easier for NTIA and others to
interpret.

Quarterly PPR for Public
Computer Centers, “Project
Indicators (This Quarter),”
Question 4e

Request the number of hours that
existing and new PCCs are open to
the public as a result of BTOP
funds.

Including both new and existing PCCs aligns
this metric with projections made by the
applicants during due diligence.

Quarterly PPR for
Sustainable Broadband
Adoption, “Project
Indicators (This Quarter)”
and “Project Indicators
(Next Quarter),” Question
2

Split the space for the narrative
response into separate lines for each
milestone.

This format will enable recipients to align
their narratives to the milestones to which
they relate.

Quarterly PPR for
Sustainable Broadband
Adoption, “Project
Indicators (This Quarter),”
Question 4a

Request that recipients report the
number of business and institutional
subscribers separately from the
number of household subscribers.

NTIA expects that recipients will count
household subscribers separately from
business and institutional subscribers,
consistent with the information requested in
the application and due diligence. Collecting
these totals separately will provide
significantly more meaningful information
about the overall impact of each project and
the program as a whole.

Quarterly PPR for
Sustainable Broadband
Adoption, “Project
Indicators (This Quarter),”
Question 4d

Request information about
community anchor institutions
receiving discounted broadband
service, in addition to households
and businesses receiving such
service.

NTIA needs to collect this information to
monitor project performance against
information provided in the application.

The adjustment decrease is based on a reduction of respondents/responses.

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 with report data from the post-award monitoring

11

system. 20 BTOP recipient reporting data will be available within 60 days of the quarter end date
at http://www2.ntia.doc.gov/GrantsAwarded.
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 As noted above in Question 2, on a quarterly basis, NTIA will also publicly post a
data extract in Excel format that contacts a subset of key metrics and performance data from each
report.

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

21

See Second NOFA, 75 Fed. Reg. at 3811.
See Recovery Act § 6001(i)(5), 123 Stat. at 515.
12