2434ssa204

2434ssa204.docx

Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery (Renewal)

OMB: 2030-0051

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U.S. Environmental Protection Agency

Information Collection Request

Title: Generic Clearance for the Collection of Qualitative Feedback on Agency Service Delivery

OMB Control Number: 2030-0051

EPA ICR Number: 2434.204

Abstract: This information collection provides the Agency with an opportunity to engage with and learn from current and potential stakeholders or partners in, or consumers of, EPA or EPA-supported services and programs by gathering qualitative information about their needs and experiences. Getting such feedback in a timely manner is critical if the Agency is to know how and where it should focus while seeking to improve, or expand upon, its products and services.

Supporting Statement A

  1. NEED AND AUTHORITY FOR THE COLLECTION

Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

Executive Order 12862 directs federal agencies to provide service to the public that matches or exceeds the best service available in the private sector. In order to ensure that our programs are effective and meet our customers’ needs, the Environmental Protection Agency seeks to obtain OMB approval of a generic clearance to collect qualitative feedback on our service delivery.

EPA has also received funding through the Bipartisan Infrastructure Law (BIL) and the Infrastructure Investment and Jobs Act (IIJA) as well as direction associated with the Justice40 initiative and through Executive Order 13985, which compel the Agency to aggressively work to implement programs responsive to, and involving, various communities and stakeholder groups.

This collection of information is necessary to enable the Agency to engage its customers and stakeholders to gather their feedback in an efficient, timely manner. This feedback will provide insights into customer or stakeholder perceptions, experiences, and expectations which, in turn, will help EPA to focus attention on areas where collaboration, communication, training, changes in operations, or additional project development can improve the public’s interaction with the Agency’s programs and services.

PRACTICAL UTILITY/USERS OF THE DATA

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.

The Agency will collect, analyze, and interpret qualitative information gathered through this generic clearance to identify strengths and weaknesses of, or gaps in, its programs and services and make improvements accordingly. Solicitations of feedback will target areas such as the timeliness, appropriateness, courtesy, and effectiveness of services delivered as well as evaluations of the public’s need for updated or new EPA services and programs.


Information collection types under this generic clearance fall into two general categories.

  • Needs Gathering and Community Engagement -- Information gathering opportunities allow the Agency to engage specific communities to gauge factors such as their perceived difficulties, needs, and aspirations as well as their current capacities. How those communities are defined can vary, but may be based on location, industry, socioeconomic condition, or issue focus. EPA needs such feedback to understand where and how it may most effectively support the public with programs and services.

  • Mechanisms to collect feedback on existing programs, events, communications, or services allow the Agency to understand how and where it can be more effective in providing, and improve the experience of individuals or groups consuming, its products and services.

Various methodologies may be employed in the collection of information including but not limited to:

  • Surveys (in print or electronic format);

  • Widgets;

  • Interviews;

  • Focus Groups;

  • Community/Public Meetings;

  • General Solicitations or Contests intended to gather input and ideas; and

  • User or Observational Testing.


To obtain approval for a collection that meets the conditions of this generic clearance, a standardized request form will be submitted to OMB along with any collection instruments (or screenshots of digital instruments), scripts, etc. According to OMB procedures for generic ICRs, submissions will be approved by default in 5 business days unless OMB intervenes because of issues within the request.


The Agency will only submit a collection for approval under this generic clearance if it meets the following conditions:

  • Information gathered will not be used for the purpose of substantially informing influential policy decisions 1;

  • The collections are voluntary;

  • The collections are low burden for respondents (based on considerations of total burden hours, total number of respondents, or burden hours per respondent) and are low cost for both the respondents and the federal government;

  • The collections are non-controversial and do not raise issues of concern to other federal agencies;

  • The collections are targeted to the solicitation of opinions from respondents who have experience with the EPA service/program or experience with environmental issues that the Agency may address with services/programs in the near future; and

  • The collections will collect and retain personally identifiable information (PII) only to the extent and duration necessary to meet program objectives.


The Agency has established a manager/managing entity to serve this generic clearance who will conduct an independent review of each information collection to ensure compliance with the terms of this clearance before any submission is made to OMB. If these conditions are not met, the Agency will submit an information collection request to OMB for approval through the normal PRA process.

  1. USE OF TECHNOLOGY

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, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

Each information collection will be conducted in the mode that is most appropriate and convenient for respondents but with an overall focus on employing information collection technology to the greatest extent possible. This approach will help reduce the time and effort needed for respondents to access the information collection and minimize the time and costs associated with the Agency’s initial delivery, and subsequent processing, of the requested information.

  1. EFFORTS TO IDENTIFY DUPLICATION

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.

No similar data are gathered or maintained by the Agency or other sources known to the Agency.

  1. MINIMIZING BURDEN ON SMALL BUSINESSES AND SMALL ENTITIES

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

Small business or other small entities may be involved in these efforts, but the Agency will minimize the burden imposed by this collection on all respondents by sampling, asking for readily available information, and using short, easy-to-complete information collection instruments.

  1. CONSEQUENCES OF LESS FREQUENT COLLECTION

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.

Without having access to the types of feedback gathered through this collection, the Agency will not have timely information to adjust its services to meet customer needs.

  1. GENERAL GUIDELINES

Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

The proposed collection does not create special circumstances requiring justification under 5 CFR 1320.5.

  1. PUBLIC COMMENT AND CONSULTATIONS

8a. Public Comment

If applicable, 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. Specifically address comments received on cost and hour burden.

In accordance with 5 CFR 1320.8(d), EPA published a 60-day notice for public comment on 01/26/2024 in the Federal Register (89 FR 5228). The Agency reviewed all comments and did not find any that were addressed to the specific topic areas outlined in this collection.

  1. PAYMENTS OR GIFTS TO RESPONDENTS

Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

In the case of usability studies and focus groups, the Agency may provide modest stipends or gifts to encourage participation or compensate respondents for their time and travel expenses. The value of these remunerations will be aligned with current industry standards but will generally not exceed $75 per day per person. In any instances where payments in excess of this amount are required, the Agency will provide OMB with additional justifications in the request for clearance of these specific activities.

Outside of focus groups and usability studies, the Agency will not provide payments or other forms of remuneration to respondents of this collection.

  1. ASSURANCE OF CONFIDENTIALITY

Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.

The Agency will not gather confidential business information (CBI) or sensitive personally identifiable information (PII) under this information collection. EPA may request and retain PII in the form of basic identification and contact information only in instances where, and only for as long as, it is necessary to meet a collection’s objectives. All confidential data will be handled in accordance with 40 CFR 122.7, 40 CFR Part 2, and EPA’s Security Manual Part III, Chapter 9, dated August 9, 1976. Any claim of confidentiality must be asserted at the time of submission. Any personal information included in a request would be treated in accordance with the Privacy Act, section 14 of TSCA, and the Freedom of Information Act.



JUSTIFICATION FOR SENSITIVE QUESTIONS

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 justification should include the reasons why the Agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

Questions about sensitive issues that are normally considered private (e.g., religious beliefs, sexual attitudes, and behavior) will not be included in the information collections covered by this ICR.

  1. RESPONDENT BURDEN HOURS & LABOR COSTS

Provide estimates of the hour burden of the collection of information. The statement should:

  • Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Generally, estimates should not include burden hours for customary and usual business practices.

  • If this request for approval covers more than one form, provide separate hour burden estimates for each form and the aggregate the hour burdens.

  • Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included as O&M costs under non-labor costs covered under question 13.

Respondent Burden Hours and Labor Costs

A variety of instruments and platforms will be used to collect information from respondents. The annual burden hours requested are based on the number of collections we expect to conduct over the requested period for this clearance.



Estimated Annual Reporting Burden

Type of Collection

No. of Respondents

Annual Frequency per Response

Hours per Response

Total Hours

Qualitative Survey

180,000

1

0.25

45,000



  1. Respondent CAPITAL AND O&m CostS

Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).

The cost estimate should be split into two components: (a) a total capital and start-up cost

component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should consider costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling, and testing equipment; and record storage facilities.

If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate.

Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

Respondents to these collections are not anticipated to incur capital or O&M costs.

  1. AGENCY COSTS

Provide estimates of annualized costs to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

The anticipated cost to the Federal Government is approximately $18,000 annually. These costs are comprised of support staff, contractor payments, and remunerations to focus group participants.


  1. REASONS FOR CHANGE IN BURDEN

Explain the reasons for any program changes or adjustments reported in the burden or capital/O&M cost estimates.

There are no changes or adjustments reported in the burden or capital/O&M cost estimates.

  1. PUBLICATION OF DATA

For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

If findings are shared with the public, they will be released only in an aggregated and/or anonymized manner that otherwise complies with the Agency's "Guidelines for Ensuring the Quality of Information Disseminated to the Public.”

  1. DISPLAY OF EXPIRATION DATE

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

The Agency plans to display the expiration date for OMB approval of the information collection on all instruments.

  1. CERTIFICATION STATEMENT

Explain each exception to the topics of the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

This information collection complies with all provisions of the Certification for Paperwork Reduction Act Submissions.

1 As defined in OMB and Agency Information Quality Guidelines, “influential” means that “an agency can reasonably determine that dissemination of the information will have or does have a clear and substantial impact on important public policies or important private sector decisions.”

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File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File Title18Q Supporting Statement Instructions_draft
AuthorMcGrath, Daniel (he/him)
File Modified0000-00-00
File Created2024-07-19

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