SUPPORTING STATEMENT
Generic Clearance for Questionnaire Testing and Research
EIA-882T
OMB No. 1905-0186
Introduction:
The Energy Information Administration (EIA) requests a three-year extension of the Office of Management and Budget (OMB) approval to conduct pretest/pilot surveys and research. This authority facilitates EIA's efforts to employ new techniques to improve our current data collections and to develop new and/ or revised surveys due to restructuring in both the electric power and natural gas industries. New techniques are being used by other Federal agencies to simplify questionnaires and reduce respondent burden, especially on small businesses and individuals. Reduced budgets and staff require improved efficiencies in data collection to meet the needs of our customers. EIA believes that increased use of electronic maintenance, submission, or disclosure of information activities, along with the more traditional ones we have employed in the past, will be extremely helpful as we continue to explore various means to improve the quality of our data and analysis programs.
TYPES of TESTING/RESEARCH ACTIVITIES
1. Pretest/Pilot Surveys: In both the pretest and pilot test stages a variety of methods will be used:
a. Face-to-face interviews
b. Telephone interviews
c. Mail questionnaires
d. Electronic questionnaires
The nature of pretest and pilot surveys differs.
Pretest surveys conducted under this clearance will generally be methodological studies of limited size, normally involving either purposive or statistically representative samples. They will include a variety of surveys, the exact nature and sample designs will be determined at the time of development of the pretests. The samples will be designed to clarify particular issues rather than to be representative of the universe. Collection may be on the basis of convenience, e.g., limited to specific geographic locations. The needs of a particular sample will vary based on the content of the information collection or survey being tested, but the selection of sample cases will not be completely arbitrary in any instance.
Pilot surveys conducted under this clearance will also generally be methodological studies of limited size, but will always employ statistically representative samples. The pilot surveys will replicate all components of the methodological design, sampling procedures (where possible) and questionnaires of the full scale survey. Pilots will normally be utilized when EIA is undertaking a complete revamping of a survey methodology (e.g., moving to computer assisted data collections) or when EIA is required to undertake a data collection in new areas, such as greenhouse gases or alternative fueled motor vehicle transportation system studies.
2. Nonstandardized Questioning of Respondents
a. Focus Groups
b. Cognitive Interviews
Focus groups ("roundtables," etc.) involve group sessions guided by a monitor who follows a topical outline containing questions or topics focused on a particular issue, rather than adhering to a standardized questionnaire. Focus groups are useful for surfacing and exploring issues, e.g., from a specific group of stakeholders.
Cognitive interviews are one-on-one interviews in which the respondent is typically asked to "think aloud" as he or she answers survey questions, reads survey materials, or completes other activities as part of a survey process. A number of different techniques may be involved, including asking respondents to paraphrase questions, probing questions asked to determine how respondents come up with their answers, and so on. The objective is to identify problems of ambiguity or misunderstanding, or other difficulties respondents have answering questions. This is frequently the first stage of revising a questionnaire. It will be particularly important in new subject matter areas.
For each study that EIA undertakes under this generic clearance, EIA will notify OMB, at least two weeks in advance, and provide OMB with an information copy of the questionnaire (if one is used), and all other materials describing the testing activity.
A. Justification
1. Legal Authority
The authority for these voluntary information gathering activities is provided by the following provisions:
Section 13(b) of the Federal Energy Administration Act of 1974 (FEA Act) (P.L. 93-275) [15 U.S.C. '772(b)]
states:
"All persons owning or operating facilities or business premises who are engaged in any phase of energy supply or major energy consumption shall make available to the (Secretary) such information and periodic reports, records, documents and other data, relating to the purposes of this Act, including full identification of all data and projections as to source, time, and methodology of development, as the (Secretary) may prescribe by regulation or order as necessary or appropriate for the proper exercise of functions under this Act."
The functions of the FEA Act are set forth in Section 5(b) of the Act [15 U.S.C. '764(b)], which states that the Secretary shall, to the extent he is authorized by Section 5(a) of the Act,
"(2) assess the adequacy of energy resources to meet demands in the immediate and longer range future for all sectors of the economy and for the general public; ...
(6) assure that energy programs are designed and implemented in a fair and efficient manner so as to minimize hardship and inequity while assuring that the priority needs of the Nation are met; ...
(9) collect, evaluate, assemble, and analyze energy information on reserves, production, demand, and related economic data;"
As the authority for invoking Section 5(b) above, Section 5(a) (15 U.S.C. '764(a)) in turn, states:
"Subject to the provisions and procedures set forth in this Act, the (Secretary) shall be responsible for such actions as are taken to assure that adequate provision is made to meet the energy needs of the Nation. To that end, he shall make such plans and direct and conduct such programs related to the production, conservation, use, control, distribution, rationing, and allocation of all forms of energy as are appropriate in connection with only those authorities or functions---
(3) Otherwise specifically vested in the (Secretary) by the Congress;"
Authority for invoking Section 5(a) of the FEA Act is provided in turn by Sections 52(a), [15 U.S.C. '790a)] which states that the [Administrator of the EIA]:
"(Shall) establish a National Energy Information System. . . (which) shall contain such information as is required to provide a description of and facilitate analysis of energy supply and consumption. . .
(b) . . . the System shall contain such energy information as is necessary to carry out the Administration's statistical and forecasting activities, and . . . such energy information as is required to define and permit analysis of . . .
(1) the institutional structure of the energy supply system including patterns of ownership and control of mineral fuel and nonmineral energy resources and the production, distribution, and marketing of mineral fuels and electricity;
(2) the consumption of mineral fuels, nonmineral energy resources, and electricity by such classes, sectors, and regions as may be appropriate for the purposes of this Act;
. . . (4) the comparability of energy information and statistics that are supplied by different sources; . . .
2. Uses of Data
The information gathered will be used to help modify data collection procedures and to develop better questionnaires, including the use of improved electronic maintenance, submission, or disclosure of information. The end result will be improvements in the quality of data being collected by EIA, a reduction or minimization of respondent burden, increased agency efficiency, and improved responsiveness to the public.
Results of these efforts also will give EIA a better understanding of the energy areas being studied and of how respondents comprehend survey questions. Results will be shared with other DOE components and other agencies in seminars and through presentations at meetings, e.g., at the American Statistical Association's meetings, and the Federal Committee on Statistical Methodology conference.
During the past three years, the results of the surveys were forwarded to OMB in the annual reports. Specific uses of the clearance were used to test the following:
Field test a proposed new survey form, EIA-923, “Power Plant Operations Report.”
The Form EIA-923 was fielded in January, 2008. The purpose was to find out if the company could navigate through the survey and find general problems with it.
Focus groups were held to test energy message components and strategies created from findings of DOE Office of Energy Efficiency and Renewable Energy focus groups in May and June 2006; and to test messages developed by the DOE/Retail Partnership Team. Findings were used to conduct a presentation/discussion among major leading retail companies across the country. The discussion hoped to create and identify a unified sales message among retailers that would help transform the purchasing behavior of Americans and encourage and promote the sale of energy efficient technologies and products through retail chain stores. DOE hoped to enlist corporate America to create persuasive retail environments to help consumers prioritize energy savings in every purchasing decision they make.
3. Technological Considerations to Reduce Burden
One of the goals of this effort is to identify and evaluate advanced survey techniques that will help EIA to obtain the necessary amount of information with a minimum amount of burden through the use of electronic maintenance, submission, or disclosure of information to substitute for paper.
4a. Efforts to Identify Duplication
These tasks will not duplicate any other survey/questionnaire design or pretest work being done by EIA or other Federal agencies. One of the purposes of this request is to stimulate additional research, which would not otherwise be done due to time and cost constraints. This research may involve collaboration with other agencies, especially the Office of Management and Budget, Bureau of Labor Statistics, Census, and the National Science Foundation.
4b. Analysis of Similar, Existing Information
To the maximum extent possible, EIA will use existing information, reviewing results of earlier evaluations of survey data before we attempt to revise existing questionnaires or design new ones. Also, EIA survey staff keep up-to-date on private and public survey research and results.
5. Provisions for Reducing Burden on Small Businesses
One purpose of these efforts is to develop survey methodologies and questionnaires that are easy for small businesses and individuals to respond to, thus minimizing the burden. These methods should also give small businesses a way to have input, with a minimum amount of burden, on the use of improved information technology (electronic data maintenance, submission, or disclosure) to substitute for paper.
6. Consequences of Less Frequent Reporting
Not applicable. Because this clearance is an on-going effort, it has the potential to have an immediate impact on all our data collections. Its delay would hamper the benefits we expect to reap.
7. Special Circumstances
Under this clearance, respondents will not be required to:
Report information to the agency more often than quarterly;
Prepare a written response to a collection of information in fewer than 30 days after receipt of it;
Submit more than an original and two copies of any document;
Retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;
Respond in a manner in connection with a statistical survey, that is not designed to produce valid and reliable results that can be generalized to the universe of study;
Use a statistical data classification that has not been reviewed and approved by OMB;
Respond in a manner that includes a pledge of confidentiality that is not supported by authority established in statute or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
Submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
8. Consultations Outside the Agency
A Federal Register notice was published March 24, 2008, (73 FR 15499) soliciting comments concerning the extension of this clearance. In addition the notice was posted on EIA=s web site, and distributed to the forms clearance contacts within the Department.
9. Payment or Gift to Respondents
No payment or gifts will be made to respondents, unless respondents are required to perform something unusual and OMB approval is granted in advance.
10. Provisions Regarding Confidentiality
For studies and pretests where we obtain proprietary data, we will advise respondents, in writing, that their participation is voluntary and the following confidentiality provision will be made:
The information reported on the form will be protected and not disclosed to the public to the extent that it satisfies the criteria for exemption under the Freedom of Information Act (FOIA), 5 U.S.C. §552, the Department of Energy (DOE) regulations, 10 C.F.R. §1004.11, implementing the FOIA, and the Trade Secrets Act, 18 U.S.C. §1905.
The Federal Energy Administration Act requires the EIA to provide company-specific data to other Federal agencies when requested for official use. The information reported on this form may also be made available, upon request, to another DOE component; to any Committee of Congress, the Government Accountability Office, or other Federal agencies authorized by law to receive such information. A court of competent jurisdiction may obtain this information in response to an order. The information may be used for any nonstatistical purposes such as administrative, regulatory, law enforcement, or adjudicatory purposes.
If Disclosure limitation methods are used, disclosure limitation procedures are applied to the statistical data published from the survey information to ensure that the risk of disclosure of identifiable information is very small.
If disclosure limitation methods are not used, disclosure limitation procedures are not applied to the statistical data published from the survey's information. Thus, there may be some statistics that are based on data from fewer than three respondents, or that are dominated by data from one or two large respondents. In these cases, it may be possible for a knowledgeable person to estimate the information reported by a specific respondent.
For the studies conducted by contractors for EIA consumption surveys, respondents will be advised in writing the following information:
The information you provide will be used for statistical purposes only. In accordance with the Confidential Information Protection provisions of Title V, Subtitle A of Public Law 107-347 and other applicable Federal laws, your responses will be kept confidential and will not be disclosed in identifiable form to anyone other than employees or agents without your consent. By law, every EIA employee, as well as every agent, is subject to a jail term, a fine of up to $250,000, or both if he or she discloses ANY identifiable information about you.
11. Questions of a Sensitive Nature
The questions being asked will not be of a sensitive nature. However, it is possible that in developing surveys potentially sensitive questions may be included. One of the purposes of these efforts is to identify such questions, determine sources of sensitivity, and alleviate them insofar as possible before an actual survey is conducted.
12. Burden of the Collection of Information
A variety of efforts will be used in conducting the activities under this clearance. The exact number of respondent hours needed and the number of respondents are unknown at this time. EIA=s best estimate as to the total number of burden hours annually is 1,000. (4,000 respondents x 15 minutes per response = 1,000 hours) This estimate is based on the amount of testing that can realistically be conducted within the reference period. Before any activity is conducted, OMB is notified in advance the number of respondents and estimated time it will take respondents.
During the past three years, the surveys conducted under this clearance totaled less than 1,000 hours of respondent burden.
The cost to the respondents for the next three years is estimated at $62,000 (1,000 hours x $62 per hour) annually.
There is no cost to respondents for participating in the development of these surveys except for their time, which is estimated at $62 an hour (1,000 hours x $62 = $62,000). There are no plans to remunerate participants other than incidental costs to encourage participation (e.g., travel costs). Any deviation from the above will be covered when we notify OMB as to actual studies conducted under this clearance.
(An average cost per hour of $62 is used because that is the average loaded (salary plus benefits) cost for an EIA employee assigned to data survey work. EIA assumes that the survey respondent workforce completing surveys for EIA is comparable with the EIA workforce.)
13. Estimate of Total Annual Cost
No additional capital, start-up, or operation and maintenance costs for respondents should be necessary for any data collections under this clearance.
14. Annualized Cost to the Federal Government
No additional cost to the Federal Government is anticipated. Expenses (equipment, overhead, printing, and support staff) will be incurred by EIA components as part of their normal operating budgets. Any deviation from the above will be covered when we notify OMB as to actual studies conducted under this clearance.
15. Program Changes or Adjustments
Our estimate of surveys conducted under the generic clearance was 1,000 hours. It is estimated that during the next three years no more than 1,000 hours will be required annually to respond to activities under this clearance.
16. Schedule of Data Collection and Publication
The information will be used for questionnaire development and to improve the quality of EIA=s data. The results will not be published in EIA publications. Some papers may be written and presented at public meetings, or published in EIA service reports or policy guidelines. Due to the nature of this clearance, there is no time schedule. Information collection will not begin until OMB has notified of a proposed activity and given two weeks to comment to EIA on the activity. Work will continue throughout the duration of the three-year clearance.
17. OMB Approval Expiration Date
EIA will display the expiration date for OMB approval of the information collection.
18. Exceptions to the Certification Statement
No exceptions to the Certification Statement should be required. If so, OMB approval will be requested in advance of conducting the survey.
| File Type | application/msword |
| Author | GS1 |
| Last Modified By | GS1 |
| File Modified | 2008-07-01 |
| File Created | 2008-07-01 |