Pursuant to 5 CFR 1320.1, this ICR is disapproved as inconsistent with the Paperwork Reduction Act of 1995 (PRA) as enacted at 44 U.S.C. 3501 et seq. The collection submitted to OMB for approval under control number 2020-0021 is a generic clearance for collection of "customer satisfaction and behavioral change feedback on EPA compliance assistance as well as data on the resulting impact on compliance." A generic clearance may be extended to information collections that consist of a general plan for collecting data and specific data collection tasks. In these cases, the specific data collection tasks must generally be submitted to OIRA for approval under the terms of clearance for the general plan. Under the draft implementing guidance for the PRA, OMB generally will not approve a generic clearance unless it meets four tests: 1) there is a demonstrated need for a generic strategy; 2) specific data collection tasks may be reviewed by a single OIRA desk officer within a short period of time; 3) the general plan addresses the subject matter and employs methodologies that are free of controversy or any features that require particular justification adn review under the 5 CFR 1320; and 4) the general plan covers intended collections in enough detail that the consistency of each task with the plan is transparent. The information collection, "Compliance Assistance Tool Evaluation Surveys," requested under 2020-0021 does not meet these tests. In particular, the proposed collection is so general as to encompass surveys characterized by a myriad of target populations, sample designs, and methodologies for the analysis of resulting data. Furthermore, the statistical methods and sample designs were not spelled out in detail as part of the main plan. the generality of the Agency's description of the proposed collection is such that it would be difficult for a member of the public to provide meaningful comments on it. In addition, the collection does not provide for OIRA review of individual surveys. Finally, the collection seeks to obtain "data on the resulting impact on compliance," which implies program evaluation. In order to ensure that data for purposes of program evaluation meets certain quality criteria and thus have practical utility, such information collections should be submitted to OMB pursuant to the normal PRA notice and comment process.
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This is ICR supports a voluntary collection of information to gather customer satisfaction and behavioral change feedback on EPA compliance assistance, as well as date on the resulting impact on compliance. Surveys will be used to provide the Agency with feedback on its compliance assistance documents, on-site visits, telephone assistance, Websites, and compliance assistance seminars and workshops. EPA will also seek informa- from state/local regulating agencies regarding the impact of EPA's compliance assistance on the state of compliance.
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.
Compliance Assistance Tool Evaluation Surveys