PPR Extension_Supporting Statement_For DOC Review

SUPPORTING STATEMENT

U.S. Department of Commerce

National Telecommunications and Information Administration

State and Local Implementation Grant Program

Quarterly Reporting Requirements

OMB Control No. 0660-0038

1. JUSTIFICATION

In order to meet the objectives of the State and Local Implementation Grant Program (SLIGP), DOC/NTIA requested approval for this form from the Office of Management and Budget. This request was approved on August 1, 2013; approval ends on August 31, 2016. The publication of this notice allows NTIA to begin the process to extend the approval for the standard three years, with a minor adjustment to the wording on the form to more clearly indicate to recipients how they are to report each measure.

1. Explain the circumstances that make the collection of information necessary.

Following the tragic events of September 11, 2001, the 9/11 Commission recommended the establishment of a nationwide, interoperable public safety communications network to resolve the communications challenges faced by emergency responders nationwide. On February 22, 2012, President Obama signed into law the Middle Class Tax Relief and Job Creation Act of 2012 (Act).¹ The Act meets a long-standing priority of the Obama Administration, as well as a critical national infrastructure need, to create a single, interoperable, nationwide public safety broadband network (NPSBN) that will, for the first time, allow police officers, fire fighters, emergency medical service professionals, and other public safety officials to effectively communicate with each other across agencies and jurisdictions. Public safety workers have long been hindered in their ability to respond in a crisis situation because of incompatible communications networks and often outdated communications equipment. Therefore, the rapid design and deployment of this NPSBN established by the Act is critical in providing emergency responders the ability to communicate on a secure, reliable, and dedicated interoperable network during emergencies and to use technology to improve response time, keep communities safe, and save lives.

The Act establishes the First Responder Network Authority (FirstNet) as an independent authority within the National Telecommunications and Information Administration (NTIA) and authorizes it to take all actions necessary to ensure the design, construction, and operation of a nationwide NPSBN, based on a single, national network architecture.² FirstNet is responsible for, at a minimum, ensuring nationwide standards for the use of and access to the network; issuing open, transparent, and competitive requests for proposals (RFPs) to build, operate, and maintain the network; encouraging these RFPs to leverage, to the maximum extent economically desirable, existing commercial wireless infrastructure to speed deployment of the network; and overseeing contracts with non-federal entities to build, operate, and maintain the network.³

The Act also charges NTIA with establishing a grant program, the State and Local Implementation Grant Program (SLIGP), to assist state, regional, tribal, and local jurisdictions with identifying, planning, and implementing the most efficient and effective means to use and integrate the infrastructure, equipment, and other architecture associated with the NPSBN to satisfy the wireless broadband and data services needs of their jurisdictions.⁴ The SLIGP Program Office awarded $116.5 million in grant funds to 54 active state and territorial recipients between July 2013 and June 2014.

Moreover, the Act’s framework contemplates that FirstNet will closely coordinate its activities with state, regional, tribal, and local governments and imposes a statutory requirement that FirstNet consult with these entities as it takes all actions necessary to build, deploy, and operate the NPSBN.⁵ Specifically, the Act requires FirstNet to consult with state, regional, tribal, and local governments about the distribution and expenditure of any amounts required to carry out its responsibilities, including: (i) the construction of a core network and any radio access network build-out; (ii) placement of towers; (iii) coverage areas of the network; (iv) adequacy of hardware, security, reliability, and resiliency requirements; (v) assignment of priority to local users and selection of entities seeking network access; and (vi) training needs of local users.⁶

Additionally, the Act specifies that these required consultations are to occur between FirstNet and the single point of contact that the state is required to designate in its application for grant funds under SLIGP.⁷ Thus, progress in meeting FirstNet’s responsibilities under the Act, including its required consultations, is inextricably linked to the establishment of SLIGP. FirstNet must rely on NTIA to utilize SLIGP as the principal means to facilitate its required consultations with regional, state, tribal, and local governments. At the same time, without funding assistance from SLIGP, the states will lack the resources to consult effectively with FirstNet and provide it with information needed for it to proceed with the design and construction of a NPSBN in an effective and timely manner, as required by the Act.

To ensure effective grant oversight and management, SLIGP developed a quarterly performance progress report (PPR) form for recipients to complete as part of post-award monitoring throughout the period of performance. The PPRs are critical to the success of the program and provide key insights into how grant funds are being used. Recipients are asked to report on progress toward program priority areas, which include stakeholders engaged, individuals sent to broadband conferences, staff hired, contracts executed, governance meetings held, and outreach materials distributed, as well as financial expenditures by cost category. The original approval of the performance progress report form was obtained on August 1, 2013, and the current form has an expiration date of August 31, 2016. NTIA seeks to extend the approval of this form, with a minor adjustment to the wording on the form to more clearly indicate to recipients how they are to report each measure. Currently the form includes a line for “Stakeholder Meetings,” but this metric is actually intended to capture the number of stakeholders engaged. The SLIGP program office proposes changing the wording to “Stakeholders Engaged.” The SLIGP program office also proposes to change the current line for “Education and Outreach Materials” to “Education and Outreach Materials Distributed.” The proposed minor revisions will not affect the amount of time needed to complete the form; rather, the proposed minor revisions will provide more clarity to recipients and reduce the time needed for revisions. NTIA will use the collection of information to ensure that SLIGP grant recipients are effectively monitored and evaluated against the core purposes of the program established by the Act.

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 specific information covered by this information collection package consists of the following:

• Quarterly Performance Progress Report (PPR)

Recipients complete the PPR form once a quarter and submit their forms to the SLIGP Program Office via email. Once all reports have been approved, the Program Office aggregates data from all recipients and develops a quarterly dashboard, which is shared with recipients and posted on the website. The dashboard is completely anonymous and does not include any personally identifiable information (PII). To increase transparency, NTIA posts approved PPRs on the SLIGP website following each quarter.

This information collection is designed to obtain information that meets the Information Quality Guidelines for NTIA.⁸ The guidelines establish standards for the utility, integrity, and objectivity of information disseminated by NTIA.⁹

NTIA has contracted with the National Institute of Standards and Technology (NIST) to maintain the electronic data in the Grants Management Information System (GMIS). NTIA, through NIST, will maintain the integrity of the electronic data by safeguarding it consistent with acceptable standards of operation. NTIA will maintain control of paper and electronic SLIGP PPRs to ensure their security. PPRs will be retained for the award period for each recipient, after which they will be destroyed.

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 receives electronic submissions of PPRs from recipients via the Program Office email account and Federal Program Officer (FPO) email accounts.

4. Describe efforts to identify duplication.

Recipients’ quarterly reports are unique to this program, and the information to be collected is not generally available from other sources.

Out of an abundance of concern for recipients, NTIA has designed the SLIGP PPR form to allow recipients to provide only the information relevant to the purpose of the grant.

5. If the collection of information involves small businesses or other small entities,

describe the methods used to minimize the burden.

This collection of information is limited to states and U.S. territories that are recipients of a SLIGP grant and does not involve small businesses or other small entities.

6. Describe the consequences to the Federal program or policy activities if the collection is

not conducted or is conducted less frequently.

Without the information requested, NTIA could not effectively ensure that recipients are spending their grant dollars in a way that is consistent with the purposes of the Act and the specific purposes listed therein for SLIGP.¹⁰ Furthermore, NTIA could not evaluate grantees’ progress toward stated program priority areas and program goals, which are inherent in the Act and Federal Funding Opportunity. For these reasons, if NTIA did not request this information in the PPR, NTIA would fail to meet the purpose of the Act, taxpayer money could be wasted, and SLIGP would not produce the benefits intended under the Act.

7. Explain any special circumstances that require the collection to be conducted in a

manner inconsistent with OMB guidelines.

This information collection is consistent with OMB guidelines.

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 recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

NTIA published a Federal Register Notice to solicit public comment on the quarterly reporting process pursuant to the Paperwork Reduction Act. NTIA received XX public comments to this published notice.

9. Explain any decisions to provide payments or gifts to respondents, other than

remuneration of contractors or grantees.

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 has informed recipients that approved PPRs will be posted on the SLIGP website and that recipients should not include any names or contact information on the PPR that they do not want to be publically available. NTIA will protect confidential and proprietary information 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.).

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 collected 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 estimates a burden of 4 hours per recipient to complete quarterly reports.

Number of Respondents: 54

Frequency of Response: Quarterly

Total Number of Responses Annually: 216

Estimated Number of Hours Per Response: 12.5

Estimated Total Annual Burden Hours: 2,700

13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers

resulting from the collection (excluding the value of the burden hours in Question 12 above).

The financial cost to recipients will include staff time. NTIA will fund reasonable expenses for state agency staff that spend time completing the PPR each quarter. To estimate reasonable staff expenses for filling out the PPR each quarter, NTIA reviewed the Bureau of Labor Statistics (BLS) Occupational Outlook Handbook and determined that the Administrative Services Manager description closely aligns with the positions of most SLIGP recipient staff responsible for filling out the PPR. BLS lists an average salary for this position as $81,080 annually, amounting to $38.98 per hour. With an estimated annual burden of 2,700 hours, the total annual cost burden to respondents is $105,246. Completion of the PPR is an allowable cost that can be charged under the grant as federal share or matching expenses.

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 grant processing and monitoring; (3) NIST Grants Office Services to review financial information; and (4) other related expenses. The administrative budget ceiling for SLIGP equals $13.5 million and is allocated over a six-year period.

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

NTIA proposes a minor adjustment to the wording on the form to more clearly indicate to recipients how they are to report each measure. Currently the form includes a line for “Stakeholder Meetings,” but this metric is actually intended to capture the number of stakeholders engaged. The SLIGP program office proposes changing the wording to “Stakeholders Engaged.” The SLIGP program office also proposes to change the current line for “Education and Outreach Materials” to “Education and Outreach Materials Distributed.” The proposed minor revisions will not affect the amount of time needed to complete the form; rather, the proposed minor revisions will provide more clarity to recipients and reduce the time needed for revisions.

16. For collections whose results will be published, outline the plans for tabulation and

publication.

As discussed in Question 2, some of the information from the PPRs may be disseminated in the form of a high-level dashboard. NTIA may tabulate certain information (e.g., number of stakeholders reached, outreach materials distributed, governance meetings held) and include it in the dashboard to distribute at briefings, presentations, as requested by recipients, or in reports to Congress to meet the Act’s reporting requirements after award.

If seeking approval to not display the expiration date for OMB approval of the

information collection, explain the reasons why display would be inappropriate.

The standard PRA information will be displayed on the PPR form.

17. Explain each exception to the certification statement.

No exceptions are requested.

2. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

The collection of information will not employ statistical methods.

Attachments:

• SLIGP PPR form

• 60-Day Federal Register Notice

• Authorizing Statutory and Regulatory Provisions (Middle Class Tax Relief and Job Creation Act of 2012)

1 Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. No. 112-96, 126 Stat. 156 (2012) (Act) (codified at 47 U.S.C. 1401 et seq.).

2 47 U.S.C. 1426(b)(1).

3 Id.

4 47 U.S.C. 1442(a).

5 47 U.S.C. 1422(b)(2)(B).

6 47 U.S.C. 1426(c)(2)(A).

7 47 U.S.C. 1426(c)(2)(B); 47 U.S.C. 6302(d).

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

9 Id.

10 See 47 U.S.C. 1441(c).