This ICR is
approved under 5 CFR 1320 for two (2) years, with the following
specified Terms of Clearance. Over the past three years, there has
apparently been some confusion as to the appli- cable uses for this
generic ICR clearance. Perhaps as many as- one in four of the draft
surveys submitted to OMB so far in 1997 under this generic
clearance have not been surveys addressing customer satisfaction,
and are not consistent with OMB's Terms of Clearance. These surveys
have instead dealt primarily with "fact-finding" for the "purpose
of regulatory development or enforcement", and are thus
inconsistent with OMB's 1994 Terms of of Clearance. The generic ICR
is approved to allow the expedited OMB clearance of EPA customer
satisfaction surveys that are simple, straight- forward, and
narrowly focussed to: 1. current or former customers of EPA
products or services: 2. the level of satisfaction with an actual
service or product provided by EPA that they have utilized; and, 3.
their recommendations for improving said EPA product or service.
The first two of these elements are necessary for each customer
satisfaction survey approved under this generic ICR. The third
element is appropriate so long as the focus of the survey is on
elements one and two. Surveys that target these elements and are
submitted to OMB in accordance with the ICR will be reviewed by OMB
within 10 working days. For example, the following types of survey
are NOT covered by these Terms of Clearance: *"Potential customer"
surveys, i.e., targeting those who are not actual customers of an
EPA product or service. For example, a survey of the general
population as "customers" of EPA Clean Air programs represents too
broad a population category. In addition, surveys whose focus is
asking various "stakeholder" groups about the direction an EPA
regulatory program should take will not be approved. *"Data
gathering" sureys that seek to learn more about a sector of an
industry or population for the purposes of "fact finding" or
program development for regulatory purposes. Further, as stated in
OMB's 1994 Terms of Clearace: "As specified in the ICR, EPA shall
provide OMB an annual report outlining the use of this generic
clearance, including the number of surveys, the burden imposed, and
a brief description of their purposes. For surveys with statistical
design or methodological issues, EPA shall solicit advice and
guidance from statistical experts within the Agency to determine
statistical validity (and adhere closely to recommended procedures
in OMB's "Resource Manual for Customer Satisfaction Surveys" and
addenda). EPA shall submit surveys and material identified in the
ICR (i.e., purpose, burden, number of respondents, methodology,
etc.) for expedited OMB review, generally 10 calendar days. OMB
reserves the authority to disapprove any individual survey that
does not meet the conditions outlined in the ICR including
following OMB's Resource Manual for Customer Satisfaction Surveys,
and the principals of the Paperwork Reduction Act and Executive
Order No. 12862. This generic clearance does not extend to "fact
find- ing" for the purpose of regulatory development or
enforcement. OMB is relying in large part on EPA's internal review
and quality control to develop useful customer information."
Finally, this generic ICR approval does not and is not intended to
cover all types of surveys that EPA may wish to do relating to
customer satisfaction -- only the narrow range of surveys -
discussed above. Surveys that do NOT meet the Terms for this
expedited generic clearance may -- nontheless -- be entirely valid
and appropriate surveys to improve agency services and to promote
the objectives of the Executive Order or the Customer Satisfaction
initiative. The PRA clearance process should be used for each of
these surveys. At the time of renewal of this clearance, EPA should
provide a complete record of the surveys applied for, the number of
surveys approved, and the problems (if any) associated with each
ICR. OMB will use this record in evaluating the continued use of a
generic clearance for customer satisfaction surveys.
Inventory as of this Action
Requested
Previously Approved
10/31/1999
10/31/1999
11/30/1997
83,635
0
65,766
15,748
0
16,430
0
0
0
EPA plans to conduct customer
satisfaction surveys using feedback cards, evaluations forms,
telephone and mail questionnaries, focus groups, and electronic
comment via internet.
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.