SUPPORTING STATEMENT
U.S. Department of Commerce
National Telecommunications and Information Administration
911 Grant Program
OMB Control No. 0660-0041
JUSTIFICATION
Explain the circumstances that make the collection of information necessary.
In 2012, the Next Generation 911 (NG911) Advancement Act of 2012 (Middle Class Tax Relief and Job Creation Act of 2012, Pub. L. 112-96, Title VI, Subtitle E (codified at 47 U.S.C. § 942)) enacted changes to the 911 Grant Program. The act reauthorized the National 911 Implementation Coordination Office (ICO), a joint effort between NHTSA and NTIA (Agencies). It delineated the responsibilities of the ICO to include a joint program to establish and facilitate coordination and communication between federal, state, and local emergency communications systems, emergency personnel, public safety organizations, telecommunications carriers, and telecommunications equipment manufacturers and vendors involved in the implementation of 911 services.
The NG911 Advancement Act also provided funding for grants that support the implementation and operation of 911 services, E911 services, migration to an IP-enabled emergency network, and adoption and operation of NG911 services and applications. These grants will fund: the implementation of IP-enabled emergency services and applications enabled by NG911 services, including the establishment of IP backbone networks and the application layer software infrastructure needed to interconnect the multitude of emergency response organizations; and training public safety personnel, including call-takers, first responders, and other individuals and organizations who are part of the emergency response chain in 911 services. In 2016, approximately $115 million from spectrum auction proceeds were deposited into the Public Safety Trust Fund and made available for the 911 Grant Program. After publishing the final rules for the grant program, the ICO made 36 grant awards on August 9, 2019, totaling $109,250,000. In November of 2017, the Agencies obtained OMB approval for an information collection related to the annual progress reporting and the State 911 Plans under OMB Control Number 0660-0041.
During the period of performance for the 911 Grant Program, which ends on March 31, 2022, state and tribal organization grant recipients will be required to submit performance reports in accordance with 2 C.F.R. § 200.328, the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (OMB Uniform Guidance). The Annual Performance Report asks grant recipients to describe their project activities and progress made during the past year, including a description of federal expenditures to date, key milestones, the primary activities needed to accomplish those milestones, significant project accomplishments, any delays or challenges, and an explanation as to why any established goals were not met, if applicable. Additionally, the Annual Performance Report asks grant recipients to describe the metrics they will use to assess program implementation, as well as their anticipated project activities and progress for the next year. State and tribal organization grant recipients will submit the Annual Performance Reports once a year. It is important for the Agencies to have this performance reporting information so that they can effectively administer the grant program and account for the expenditure of funds.
Lastly, state and tribal organization grant recipients will continue to submit financial reports in accordance with 2 C.F.R. § 200.327. The Agencies submitted a Request for Common Form in ROCIS to use the previously approved information collection instrument SF-425 Federal Financial Report (OMB Control No. 4040-0014), on which the Agencies will calculate and report the annual burden hours. The Federal Financial Report (SF-425) will ask grant recipients about the cash management information and financial status information. The state and tribal Organization Grant recipients will submit the Federal Financial Reports (SF-425) on a quarterly basis. The SF-425 Federal Financial Report is necessary for the effective monitoring of the Federal grant award.
Under the collection request that will operate as a revision to an approved collection for OMB Control No. 0660-0041, the Agencies are seeking OMB approval to collect annual performance information from grantees, using the revised Annual Performance Report instrument. The report has been updated to clarify the requested information and to require program metrics. The Agencies will use the standard forms and the collections of information to ensure that grant recipients are effectively monitored and evaluated against the core purposes of the 911 Grant Program.
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 36 states, territories, and tribal organizations that comprise the grantees for the 911 Grant Program will submit Annual Performance Reports electronically, once a year, for the duration of the grant program. The Agencies’ staff will use the information to review the activities accomplished by the grant recipients and ensure that these recipients meet all ongoing statutory certification requirements.
The Agencies do not intend to disseminate the collected information to the public.
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.
Collection of all information will be accomplished through electronic submissions. Analysis and aggregation of information will not be done using technological analysis techniques. All submissions will be analyzed individually.
Describe efforts to identify duplication.
The Annual Performance Reports are unique to this program. The information collected is not generally available from other sources.
If the collection of information involves small businesses or other small entities,
describe the methods used to minimize the burden.
This item does not apply. States, territories, and tribal organizations are the only eligible recipients for this grant program and it 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 on the Annual Performance Report, the Agencies cannot effectively ensure that grant recipients are spending their grant dollars in a way that is consistent with the purposes of the Act. Together with the SF-425 Federal Financial Report, the Annual Performance Report will enable the Agencies to monitor the grant recipients’ spending habits and activities. In the absence of collecting the information on the Annual Performance Report, the Agencies would fail to evaluate the grant recipients’ progress toward the grant program priority areas and program goals. Moreover, without the Annual Performance Report, the grants could be the subject of waste, fraud, and abuse of Federal funds. Therefore, it is necessary for the Agencies to collect information using the Annual Performance Reports.
Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
No special circumstances require the collection of information 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.
The Agencies provided the 60-day notice in the Federal Register, published on March 6, 2020 (Vol. 85, No. 45, page 13145) and did not receive any comments from the public as of the end of the comment period, May 5, 2020. The 60-day notice can be found at https://www.govinfo.gov/content/pkg/FR-2020-03-06/pdf/2020-04602.pdf.
Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payment or gifts will be offered to the respondents submitting applications for NG911 grant funds.
Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
No assurance of confidentiality is given by the Agencies. There is no requirement that information be sent to the Agencies. All information submitted by respondents is done so on the basis that it is required to obtain or retain benefits.
The Agencies 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.
The process of submitting annual performance reports will not contain any questions related to matters that are commonly considered sensitive or private.
Provide an estimate in hours of the burden of the collection of information.
The Agencies estimate that responses to the questions included in the proposed regulations would require an average of 60 hours to complete (Annual Performance Report - 60 hours). Estimating the maximum number of respondents at 36, this would result in a total burden of 2,160 hours.
The total estimated costs to respondents or record-keepers are based on the following:
The total hour burden of the collection of information equaling 2,160 hours
Respondents will be State, territory, and tribal government management personnel. To estimate reasonable staff expenses to respond to this information collection, the Agencies reviewed the Bureau of Labor Statistics (BLS) Occupational Outlook Handbook and determined that the Administrative Services Manager description closely aligns with the positions of recipient staff responsible for completing this request. BLS lists a median salary of $96,180 annually, amounting to $46.24 per hour. https://www.bls.gov/ooh/management/administrative-services-managers.htm
Total cost based on an hour’s burden equals $99,878.40 for the Annual Performance Report.
The estimate in hours of the burden of the collection of information does not include the hours for the Standard Forms associated with this grant program. The burden hour estimates for the Standard Forms will be included on the Agencies’ Request for Common Form to use the previously approved OMB information collection instruments.
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).
Not applicable. There are no capital, start-up, or annual operation and maintenance costs involved in the collection of information outside of the value of the burden hours in Question 12.
Provide estimates of annualized cost to the Federal government
The estimated annualized costs to the Federal government are based on the amount of time spent on review by program staff within NHTSA and NTIA. The Agencies estimate that at an average cost of $50 per hour and an estimated level of 5 hours per respondent (5 hours review of the Annual Performance Report), the total annual cost would be $9,000 for the Annual Performance Report). This estimate presumes that 36 states, territories, and tribal organizations will submit Annual Performance Reports. The estimate of the annualized cost to the Federal government does not include the hours for the Agencies’ review of the Standard Forms associated with this grant program. The estimates for the Standard Forms will be included in the Agencies’ Request for Common Form to use the previously approved OMB information collection instruments.
Explain the reasons for any program changes or adjustments.
The Agencies are asking for a revision to an approved collection for OMB control number 0660-0041. First, there is no longer a need for the application instrument (State 911 Plan) as the grant recipients have already been selected. Secondly, the annual report instrument has been updated to clarify the requested information and to require program metrics. The program metrics responses to the annual report instrument will assist the Agencies in understanding how grantees are tracking their own progress toward program objectives. This information will also improve the ability to assess program implementation across the entire universe of grantees. Further, the revisions will give the Agencies more clarity into grantees’ matching funds expenditures on an annual basis. Finally, there has been an overall decrease in the estimated number of responses per year, from 60 to 36, as the Agencies made 36 grants under the program.
For collections whose results will be published, outline the plans for tabulation and
publication.
The information collected will not be tabulated or published.
If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
Approval is not being sought to not display the expiration date for OMB approval of the information collection. The standard PRA information will be displayed on Annual Performance Report.
Explain each exception to the certification statement.
No exceptions to the certification statement are made.
COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
The proposed regulation will not employ statistical methods to analyze the information collected from respondents.
Attachments
NG911 Advancement Act of 2012 (Pub. L. 112-96, Title VI, Subtitle E)
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | SUPPORTING STATEMENT |
| Author | Katherine Marie Scott |
| File Modified | 0000-00-00 |
| File Created | 2021-01-14 |