SUPPORTING STATEMENT
U.S. Department of Commerce
National Telecommunications and Information Administration
State and Local Implementation Grant Program
Quarterly Reporting Requirements
OMB Control No. XXXX-XXXX
JUSTIFICATION
In order to meet the objectives of the State and Local Implementation Grant Program 2.0 (SLIGP 2.0) grant awards, NTIA requests approval for this form from the Office of Management and Budget for the standard three years.
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. In February 2012, the Middle Class Tax Relief and Job Creation Act of 2012 (Act) was enacted.1 The Act meets a long-standing national priority, as well as a critical national infrastructure need, to create a single, interoperable, nationwide public safety broadband network (NPSBN) that allows law enforcement officers, fire fighters, emergency medical service professionals, and other public safety officials to effectively communicate with each other across agencies and jurisdictions. Public safety responders 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hindered in their ability to respond in a crisis situation because of incompatible communications networks and often outdated communications equipment.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 design and deployment of this NPSBN established by the Act is critical to provide 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 established the First Responder Network Authority (FirstNet) as an independent authority within the National Telecommunications and Information Administration (NTIA) and authorized 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’s responsibilities, at a minimum, are 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 charged 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 NTIA awarded $116.5 million in grant funds to 54 state and territorial recipients between July 2013 and June 2014.
The Act’s framework contemplated that FirstNet closely coordinates its activities with state, regional, tribal, and local governments and imposed 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 required FirstNet to consult with state, regional, tribal, and local governments about the distribution and expenditure of any amounts required to carry out its responsibilities to plan, build, operate, and maintain the NPSBN.
Additionally, the Act specified that these required consultations occur between FirstNet and the single point of contact that the state designated in its original SLIGP grant application.6 The original SLIGP award provided recipients needed funding to support their engagement in consultations as required of FirstNet’s under the Act.
SLIGP 2.0
With an available balance of up to $43.4 million from the original SLIGP fund of $116.5 million, NTIA will continue to provide funding through SLIGP 2.0 grants to assist State, regional, tribal, and local jurisdictions to engage effectively with FirstNet and provide it with information needed to continue with planning the NPSBN and the deployment of the Radio Access Network (RAN) 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 of the SLIGP 2.0 grant. 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 goals, which include, individuals sent to broadband conferences, staff hired, contracts executed, governance meetings held, and stakeholder events convened, as well as financial expenditures by cost category. NTIA seeks Office of Management and Budget (OMB) approval of this form. NTIA will use the collection of information to ensure that SLIGP 2.0 grant recipients are effectively monitored and evaluated against the program guidelines for SLIGP 2.0 allowable activities.
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 NTIA website. The dashboard is completely anonymous and does not include any personally identifiable information (PII). To increase transparency, NTIA posts approved PPRs on the NTIA website following each quarter.
This information collection is designed to obtain information that meets the Information Quality Guidelines for NTIA.7 The guidelines establish standards for the utility, integrity, and objectivity of information disseminated by NTIA.8
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 2.0 PPRs to ensure their security. PPRs will be retained for the award period for each recipient, after which they will be destroyed.
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.
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 2.0 PPR form to allow recipients to provide only the information relevant to the purpose of the grant.
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 2.0 grant and does not involve small businesses or other small entities.
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 2.0.9 Furthermore, NTIA could not evaluate grantees’ progress program goals, which are inherent in the Act and Notice of 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 2.0 would not produce the benefits intended under the Act.
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.
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 one public comment to this published notice.
The Bureau of Communications and Information Services of the Pennsylvania State Police (PA State Police) submitted comments to the four solicited subjects identified by the 60-Day Notice. The PA State Police was in agreement with NTIA regarding two comments.
The PA State Police believes that the SLIGP 2.0 data collection is necessary for NTIA “to track grant activities and spending amounts during the grant period” as needed for “performance analysis of the project.” It also agreed with NTIA’s “estimate regarding the burden of hours and costs of the proposed collection of data” to a SLIGP 2.0 grantee.
As to ways to enhance the quality, utility, and clarity of the information to be collected the PA State Police submitted several comments.
The PA State Police continued, “however there is no clear comparison between baseline and current progress of set NTIA milestones; no clear way of seeing the state’s progress.” The SLIGP 2.0 reporting instrument does not require such a comparison for reporting purposes. The SLIGP 2.0 instrument does require the reporting of allowable activities performed plus the reporting of funds obligated and expended (both awarded funds and required matching funds) against the total approved budget.
The PA State Police’s second comment on SLIGP 2.0 information gathering “recommended having one comprehensive narrative section that encompasses the activities for that quarter to explain circumstances if milestones are not met and to highlight best practices.” The SLIGP 2.0 Performance Progress Report (PPR) has a reduced number of narrative sections as compared to the SLIGP 1.0 PPR.
The PA State Police’s third comment on SLIGP 2.0 information gathering recommends that “along with the written portion of the report, the respondent should have the ability to incorporate graphs and charts for progress/milestones met, but this should not be mandatory.” NTIA has determined that grantees may include graphs or charts as attachments to complement their quarterly PPR submissions.
PA State Police’s final comments regarded ways to minimize the burden of the collection of information on respondents. “It would be useful to complete this information in an online reporting system; a system that maintains previous reported information and which allows the latest quarterly report and figures to be added and calculated automatically.” Though such data collection may be advantageous, the two-year duration of the SLIGP 2.0 program coupled with the limited amount and frequency of data gathered plus associated costs to automate the data collection makes such an investment prohibitive. Similar to the SLIGP 1.0 PPR, NTIA will continue to collect the SLIGP 2.0 PPR electronically via email.
The PA State Police’s final recommendation is for NTIA to “consider permitting use of electronic signatures.” To expedite the completion and submission of quarterly PPRs, SLIGP 2.0 grantees may use an electronic signature of the Authorized Certifying Official in lieu of an actual signature.
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.
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.).
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.
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: 56
Frequency of Response: Quarterly
Total Number of Responses Annually: 224
Estimated Number of Hours Per Response: 12.5
Estimated Total Annual Burden Hours: 2,800
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 2.0 recipient staff responsible for filling out the PPR. BLS lists an average salary for this position as $90,050 annually, amounting to $43.29 per hour. With an estimated annual burden of 2,800 hours, the total annual cost burden to respondents is $121,212. Completion of the PPR is an allowable and allocable cost that can be charged under the grant as Federal share or matching expenses.
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 2.0 equals $6.5 million and is allocated over a three to four-year period.
Explain the reasons for any program changes or adjustments.
SLIGP 2.0 grant is a new funding opportunity under the authority of the Act. The SLIGP 2.0 PPR is a new collection, and therefore there are no program changes or adjustments.
For collections whose results will be published, outline the plans for tabulation and
publication.
As discussed in the answer to 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 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.
Explain each exception to the certification statement.
No exceptions are requested.
COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
The collection of information will not employ statistical methods.
Attachments:
SLIGP 2.0 PPR form
60-Day Federal Register Notice
Pennsylvania State Police Comments
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. 1424, 1426(b)(1).
3 47 U.S.C. 1426(b)(1)(A)-(D).
4 47 U.S.C. 1442(a).
5 47 U.S.C. 1422(b)(2)(B).
6 47 U.S.C. 1426(c)(2)(B); 47 U.S.C. 1442(d).
7 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.
8 Id.
9 See 47 U.S.C. 1441(c).
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT |
| Author | Katherine Marie Scott |
| Last Modified By | SYSTEM |
| File Modified | 2017-11-20 |
| File Created | 2017-11-20 |