Approval is
granted in concept through December 2000 for the information
collection entitled, "Electronic Access Survey" under the following
conditions: 1. OMB strongly suggests that the FBI collect FFL
registration information needed to plan for the implementation of
the electronic access utilizing a separate instrument, either
within this information collection clearance package or under a
separate approval. The "Purpose and Use of Information" section of
the justification states that the data from this survey will be
used to assess the number of FFL's interested in electronic access.
The methodology used to collect the information is based on a need
for the agency to collect FFL information from each firearm dealer
for program implementation. This methodology is not appropriate for
generating reliable information to project the number of
certificates of authenticity the agency will need to purchase for
an internet-based NICS checks system. 2. The agency must consult
with the Bureau of Justice Statistics, and provide BJS' written
response related to any portion of this information collection that
utilizes statistical methods. 3. The agency must clearly describe
the research design used for the collection of data used to
determine the number of certificates of authenticity the agency
will purchase. The methodology must accommodate known information
about the population and results of previous ATF, FBI, and other
applicable surveys on this population that have used a similar
methodology. Information from ATF indicates that 80% of the
population has a relatively low response rate for government
sponsored surveys. However, the remaining 20% have a relatively
high response rate, leaving the FBI's estimates of the overall
response rate at approximately 25%. To obtain reliable results, the
agency must improve its methodology and do the following: a)
Discuss the inconsistency between the reported response rates; and
b) Use a probability sample for estimating the required number of
certificates, and then concentrate on ensuring that this sample's
response rate is approximately 80% or higher. The agency should
utilize a research methodology stratifying the population into the
high volume group (which represents about 20% of the population)
and the low volume group (representing 80% of the FFL population).
A random sample with a sample size of approximately 2,000 should be
collected from each strata. The present methodology of collecting
data from the entire universe is too burdensome, and given the low
expected response rate, the results cannot be guranteed to be
generalizable to the population being studied; or c) Report the
response rate for a pilot study (on a limited segment (not to
exceed 30%) of the respondent population) for this collection to
determine whether an acceptable response rate may be attained, if
the agency chooses not to use the suggested stratified sampling
methodology which uses two seperate data collection instruments,
but rather to utilize a census methodology as indicated in its
previous submission. OMB will then determine whether the agency may
proceed with the full blown study dependent on the results of the
pilot; or d) Submit a new information collection package, which
expressly requests approval only for collection of FFL registrant
information, if the agency chooses to collect information solely
for the purpose of registering applicants to begin phasing in the
implementation of electronic access to NICS. The agency may not use
this information to project the number of certificates of
authenticity to purchase as indicated in this information
collection; and e) Incorporate "total design" methods to increase
the response rate. Such methods include a pre-notification letter,
a cover letter that will encourage high participation in the
survey, and stamped return envelope to accompany the survey, thank
you and reminder post cards, subsequent follow-up letters and
surveys for nonrespondents, and follow-up telephone calls; and f)
Conduct a nonresponse analysis to determine whether there are any
statistically significant differences between respondents and those
that have not responded. 4. The survey instrument must include a
toll free number to answer respondents' questions. The agency must
provide OMB with a written response to these issues at least two
weeks before the date it plans to field the requested data
collection. OMB reserves the right to require additional changes
based on the results of the agency's response.
Inventory as of this Action
Requested
Previously Approved
12/31/2000
12/31/2000
12,750
0
0
2,168
0
0
0
0
0
The Brady Handgun Violence Protection
Act of 1994, requires the Attorney General to establish a National
Instant Criminal Background Check System that any Federal Firearm
Licensee may contact by telephone or by other electronic means, for
information to be supplied immediately, on whether receipt of a
firearm by a prospective purchaser would violate state or Federal
law.
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.
Electronic Access Survey