This collection of information is not approved. OMB questions whe ther the proposed collection will have practical utility, as requ ired by 5 CFR 1320.9(a), and does not believe that it uses effect ive and efficient survey methodology appropriate to the purpose f or which the information is to be collected, as required by 5 CFR 1320.9(i). Finally, the agency has not demonstrated a statutory requirement or other substantial need that would warrant OMB appr oval for a survey that does not appear to be designed to produce valid and reliable results that can be generalized to the univers e of study, as required by 1320.5(d)(2). If the agency decides t o modify and resubmit the proposed collection, it should address the following specific concerns. Confidentiality: Because the respondents are potentially subject to enforcement proceedings by the agency, and information they pr ovide could potentially be used in such proceedings, they must be guaranteed anonymity in order for their responses to be considere d candid. This can be accomplished by having the survey conducted by a third party who agrees contractually to provide EPA only wi th summary statistics that could not in any way be used to identi fy the respondents. Clarity/Specificity of Questions: A number of the questions are a mbiguous as to what exactly is being asked. Examples are: total c ost of the reuse plan (what is included in this term, over what t ime frame); number of people employed (FTEs, full-time/part-time, for how long); length of construction phase (does it include cle anup, to what extent is this under respondent control); local tax revenue (what kinds of taxes, what levels of government). Other q uestions appear to request vague information of little practical utility. Examples include: the respondent's opinion on how the ec onomic viability of the project was affected by the process; the types of jobs (in braod categories such as manufacturing and prod uction, professional and management, clerical and administrative) that will be created by the project. Reliability of Respondent Information: There are a number of ques tions to which the respondent is not likely to know the answer. E xamples include questions relating to what would have happened in the absence of the PPA/Comfort Letter process, the percentage of those employed by the project who will be local residents, the lo cal tax revenue resulting from the project, and the secondary eco nomic effects of the project. Reliable answers to such questions often require more resource-intensive analysis than is likely to have been performed. Reporting Ranges: In many cases ranges are asked for when ti woul d be more appropriate to ask for a specific estimate, if one is a vailable. If one is not available, respondent may be able to do little more than guess. Multiple Surveys for Same Project: It appears that multiple respo ndents may be contacted regarding the same project (eg, owners, d evelopers, lenders, insurers). It is not clear how EPA will ensu re that such projects are not double counted in the resulting sum mary statistics. Inadequate Attention to Program Alternatives: There are few quest ions designed to elicit information on sturctural weaknesses in t he program or possible alternatives that respondents feel might b etter serve their needs.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
12/31/1998
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OSRE will use four anecdotal surveys to collect information from private parties (non-government personnel) at Brownfield sites where prospective purchaser agreements and comfort/status letters have been issued or where they have been sought but not obtained. OSRE will use the information collected to evaluate the effectiveness of the guidance on prospective purchaser agreements and the comfort/status letter policy, consider revisions to the guidance and policy, and consider expanding the use of prospective purchaser agreements and comfort/status letters in other EPA media programs.
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.
Four Private-Party Anecdotal Surveys Regarding Prospective Purchaser Agreements and Comfort/Status Letters