2299ss02 A

Supporting Statement

Tribal Capacity: Determining the Capability to Participate in the National Environmental Information Exchange Network

U.S. Environmental Protection Agency

October 2008

Table of Contents

Page

Part A of the Supporting Statement 1

1. Identification of the Information Collection 1

   1. Title of the Information Collection 1

   2. Short Characterization/Abstract 1

2. Need for and Use of the Information Collection 1

   1. Need/Authority for the Information Collection 1

   2. Practical Utility/Users of the Data 2

3. Non-duplication, Consultations, and Other Collection Efforts 2

   1. Non-duplication 2

   2. Public Notice Required Prior to ICR Submission to OMB 2

   3. Consultations 3

   4. Effects of Less Frequent Collection 3

   5. General Guidelines 3

   6. Confidentiality 3

   7. Sensitive Questions 3

4. The Respondents and the Information Requested 3

   1. Respondents’ NAICS Codes 3

   2. Information Requested 3

5. The Information Collected – Agency Activities, Collection Methodology,

and Information 3

1. Agency Activities 3

2. Collection Methodology and Management 4

3. Small Entity Flexibility 4

4. Collection Schedule 4

6. Estimating the Burden and Cost of the Collection 4

   1. Estimating Respondent Burden 4

   2. Estimating Respondent Costs 4

   3. Estimating Agency Burden and Costs 4

   4. Burden Statement 5

Part B of the Supporting Statement 5

ICR Supporting Statement

Part A of the Supporting Statement

This Supporting Statement is for EPA ICR number 2299.01, Tribal Capacity: Determining the Capability to Participate in the National Environmental Information Exchange Network, OMB Control No. 2025-new. As required by the Paperwork Reduction Act (PRA) (44, U.S.C. 3501 et seq.), EPA has solicited comments on specific aspects of the proposed information collection and, receiving none, is submitting the ICR to OMB for review and approval.

1. Identification of the Information Collection:

   1. Collection Title: Tribal Capacity: Determining the Capability to Participate in the National Environmental Information Exchange Network.

2. Abstract: The National Environmental Information Exchange Network (Exchange Network) is an Internet-based approach to exchange environmental data among partners, specifically states, territories and tribes. Built on the principles of applying data standards; providing secure, real-time access; and electronically collecting and storing accurate information, the Exchange Network enables participants to control and manage their own data while making it available to partners via requests over a secure Internet connection. By facilitating the efficient exchange of environmental information among interested parties at all levels of government, the Exchange Network has begun to transform the way information is shared and improved environmental decision-making nationwide.

While some Indian Tribes have been active partners in the Exchange Network, overall tribal participation is limited. EPA has awarded grants to fund infrastructure and other support needed to share data on the Network to 59 tribes or slightly more than 10 percent of over 500 federally recognized tribes. Of these, eight have exchanged data over the Network and another five are developing the infrastructure required to do so.

The purpose of the survey: to establish a baseline of tribal capabilities to collect and manage environmental data and to participate in the Exchange Network. Under a cooperative agreement with EPA, the National Congress of American Indians (NCAI) will conduct a baseline assessment survey to obtain data on tribes to help identify barriers and other factors limiting tribal participation in the Network. The survey will focus on gathering information related to tribal collection and dissemination of environmental data; information technology infrastructure within each tribal respondent, tribal capacity, and tribal needs; and tribal awareness of the Exchange Network. The survey will be distributed to all federally recognized tribes that are members of NCAI. Response to the survey is voluntary. NCAI will use the findings of this survey to make recommendations to EPA and to facilitate programs to broaden tribal participation in the Network.

2. Need for and Use of the Information Collection

   1. Need/Authority for the Information Collection: EPA plans for NCAI to use a survey questionnaire to its constituency/membership in order to make recommendations to facilitate the design of new and improved programs to broaden tribal participation in the Exchange Network.

Since 2002, the U.S. EPA has been supporting the implementation of the Exchange Network through its National Environmental Information Exchange Network Grant Program. The program provides funding for states, territories, and federally recognized Indian tribes and has played an enormous role in the current success of the Exchange Network.

Increased tribal participation in the Network will improve environmental decision making and further environmental results on Indian lands and nationwide.

2. Practical Utility/Users of the Data: NCAI will analyze and use the data collected through this survey to advise EPA and provide recommendations to strengthen tools available to tribes to further environmental information management objectives of the Exchange Network and improve environmental decision making on and around Indian lands. These improved tools will facilitate tribal participation in the Network and will make tribal data accessible to all Network partners, public and private sector decision makers, and the public.

3. Non-Duplication, Consultations, and Other Collection Criteria

   1. Non-Duplication: The Office of Information Collection of the Agency’s Office of Environmental Information has made every reasonable attempt to ensure that this survey does not request data and information currently available through less burdensome mechanisms. EPA continues to work closely with the National Congress of American Indians to obtain the best available information on tribal participation in the Exchange Network and tools needed to facilitate this participation. NCAI has developed the appropriate survey mechanism to elicit the needed stakeholder information with the minimum amount of burden on their tribal members.

2. Public Notice: EPA published the PRA-required Federal Register notice on May 12, 2008, announcing our intent to conduct a baseline assessment survey of tribal stakeholders in the Exchange Network through the National Congress of American Indians (NCAI). The comment period under this notice was 60 days.

Pursuant to section 3506(c )(2)(A) of the Paperwork Reduction Act, EPA specifically solicited comments and information to enable us to:

1. Evaluate whether the proposed collection of information is necessary for the proper performance of the functions of the Agency, including whether the information will have practical utility.

2. Evaluate the accuracy of the Agency’s estimate of burden of the proposed collection of information, including the validity of the methodology and assumptions used.

3. Enhance the quality, unity, and clarity of the information to be collected.

4. Minimize the burden of the collection of information on those who are to respond.

EPA received no comments to the May 2008 Federal Register notice regarding the Tribal Capacity survey. No major revisions to the survey tool were, therefore, required or made.

3. Consultations: As previously stated, the Agency continues substantive dialogue with the National Congress of American Indians, through its existing cooperative agreement, to determine the need for, expectations of, and data analysis expected through this information collection. Additionally, discussions of this survey and potential improvements garnered from it have been presented to the Exchange Network Leadership Council (ENLC) and the Information Management Work Group (IMWG) to fully meet the priorities reflected in the “Exchange Network Strategic Plan,” July 2007.

4. Effects of Less Frequent Collection: The Tribal Capacity ICR is a one time only data collection activity for the respondents.

5. General Guidelines: EPA will conduct data collection, through NCAI, in accordance with the Paperwork Reduction Act guidelines in 5 CFR 1320.6 and EPA’s Quality Assurance Guidance. Information to be disseminated will comply with EPA’s Information Quality Guidelines, which were developed for implementing OMB’s Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of the Information Disseminated by Federal Agencies.

6. Confidentiality: EPA and NCAI have developed the survey tool to eliminate responses which contain Personally-Identifiable Information or Confidential Business Information. No confidential information is requested within the survey.

7. Sensitive Questions: No sensitive questions pertaining to private or personal information will be asked in the survey.

4. Respondents and Information Requested

   1. Respondents NAICS Codes: NCAI will notify its membership of federally-recognized tribes of the availability of the survey mechanism. Federally-recognized tribes are classified under the North American Industry Classification System (NAICS) identification number 921150, American Indian and Alaska Native Tribal Governments.

2. Information Requested: The NCAI survey tool is attached to this Supporting Statement. EPA, through its cooperative agreement with NCAI, plans to conduct a survey to collect and understand current tribal collection, exchange, security and submission of environmental data. The survey will also request information on availability of IT staff, dedicated data systems, and future needs to improve environmental data management.

NCAI and EPA designed the questionnaire to include many burden-reducing features. To that end, most questions are multiple-choice with comment fields to provide tribe-specific information in support of the answer. Analysis will utilize the multiple-choice answers as well as the substance of the comments included in each response.

5. Information Collected – Agency Activities, Collection Methodology, and Information

   1. Agency Activities: EPA, in cooperation with NCAI, has developed the attached survey tool, sought public comment, developed this ICR, collaborated with the ENLC and IMWG, and discussed potential analysis and programmatic recommendations resulting from this survey. NCAI will distribute the survey, provide assistance to respondents in completing their responses, receive and review responses, and summarize and analyze data resulting from the survey responses. Following this analysis, NCAI will make recommendations to EPA on programmatic improvements to increase tribal participation in the Network. EPA will present program changes to the ENLC and IMWG for review and approval.

2. Collection Methodology and Management: NCAI will notify its membership of the survey mechanism, available through the “Survey Monkey” website, and provide hard copy (if requested) to respondents unable to use the online tool. Respondents will be offered 60 calendar days in which to respond to the survey.

3. Small Entity Flexibility: The survey has been designed to facilitate responses from tribal environmental data/program managers. Most respondents will represent small tribal governments with limited resources. EPA and NCAI continue to collaborate to reduce the burden of responding on these small entities.

4. Collection Schedule: Upon approval by OMB, the survey will be provided to NCAI’s membership within 30 calendar days. Following the 60 calendar day response period, NCAI expects to make recommendations to EPA on programmatic improvements within 90 calendar days of the end of the response period. EPA expects to implement any changes within the FY 2010 National Environmental Information Exchange Network Grants program.

6. Estimating the Burden and Cost of the Collection

   1. Respondent Burden: NCAI will provide the survey to the more than 350 tribal governments that are NCAI members. The annual public reporting and recordkeeping burden for this collection of information is estimated to average 30 minutes per response. Additionally, NCAI will provide assistance to its entire membership to increase the response rate to the survey and reduce the burden of finalizing responses.

2. Respondent Costs: The direct labor cost to respondents to complete the survey equals the time to read and understand the questions, gather the information, and complete the survey form. The non-labor costs each respondent will incur include access and use to a computer with an Internet connection. Labor costs will comprise the majority of the financial burden imposed on respondents. Because EPA will not require respondents to purchase any goods, including equipment or machinery, to respond to the survey, we do not expect capital costs to result from completing the survey.

3. Agency Burden and Costs: Burden and costs for collection and analysis of data resulting from this survey will be borne by NCAI under cooperative agreement with EPA. Increasing tribal participation in the Exchange Network is an identified task under the Cooperative Agreement. No costs to EPA are expected beyond invoiced time and labor under the Cooperative Agreement.

4. Burden Statement: The survey will be distributed to over 350 federally recognized tribes that are members of NCAI. Response to the survey is voluntary. EPA and NCAI estimate a total of 250 potential respondents, each responding once to this one-time only survey. The estimated total burden is 125 hours. No additional costs are expected.

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Part B of the Supporting Statement

1. Questionnaire Objectives, Key Variables, and Other Preliminaries

   1. Objectives: NCAI will use questionnaire information to expand participation in the Exchange Network from tribal partners and increase customer satisfaction from this constituency.

2. Key Variables: The questionnaire attempts to understand individual tribe’s environmental information collection needs, storage methods, submission processes, and exchange mechanisms. By understanding these variables, NCAI will be better prepared to offer broad process improvements to increase tribal participation and improve environmental data management.

3. Other Preliminaries: NCAI will provide the questionnaire to the over 250 tribes currently members of their organization. They will make calls and provide hardcopy surveys to those tribal organizations unable or unwilling to fill out the survey online. The survey has been developed in SurveyMonkey and been assigned EPA form number 5800-01. NCAI will note within their distribution emails and listserves that participation in this survey is voluntary.

2. Statistical Approach for the Survey. NCAI expects a very high response rate to the questionnaire. NCAI will analyze the individual surveys for themes which may generate recommendations to improve participation in the Exchange Network. No statistical limitations on responses will be necessary.

3. Pretests and Pilot Tests. NCAI previously surveyed their membership on topics of common concern to determine current and future needs of their constituency. No pre-tests or pilots will be necessary for this questionnaire. Recommendations will be made from the survey data based on broad tribal needs, Exchange Network strategic goals, and NCAI knowledge of their membership.

4. Collection Methods and Follow-Up. The SurveyMonkey tool is attached to this Supporting Statement. A link to the questionnaire will be sent to each member tribe of NCAI and will be highlighted on the NCAI website. NCAI meetings, conventions, conference calls, and direct calls to tribes will be used to ensure the widest possible audience has the opportunity to respond to the survey.

5. Data Preparation and Analysis. NCAI will analyze individual surveys for themes which may generate recommendations to improve tribal participation in the Exchange Network. Network governance bodies (e.g., ENLC, NOB) will be notified of the results of this survey and provided tribal-specific recommendations that may increase tribal participation within the Exchange Network. Cross-media and cross-government solutions will be sought to efficiently broaden the Exchange Network across all levels of government.

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