0157 ss 120710rev

SUPPORTING STATEMENT
NOAA SPACE-BASED DATA COLLECTION SYSTEM (DCS) AGREEMENTS
OMB CONTROL NO. 0648-0157

A. JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary.
This request is for renewal of the information collection.
NOAA operates two space-based data collection systems: the Geostationary Operational
Environmental Satellite Data Collection System (GOES DCS) and the Argos Data Collection
System (Argos DCS), which is flown aboard NOAA's Polar-orbiting Operational Environmental
Satellites (POES). Both the GOES DCS and the Argos DCS are operated to support
environmental applications, e.g., meteorology, oceanography, hydrology, ecology, and remote
sensing of Earth resources. In addition, the Argos DCS currently supports applications related to
protection of the environment, e.g., hazardous material tracking, fishing vessel tracking for treaty
enforcement, animal tracking, and oil and gas pipeline monitoring to prevent leakage. Presently,
the majority of users of these systems are government agencies and researchers and, in fact,
much of the data collected by both the GOES DCS and the Argos DCS are provided to the World
Meteorological Organization via the Global Telecommunications System for inclusion in the
World Weather Watch Program. Current loading on both of the systems does not use the entire
capacity of that system, so NOAA is able to make its excess capacity available to other users
who meet certain criteria (see Question 2 below). Accepted applicants use the NOAA DCS to
collect environmental data and in limited cases, non-environmental data via the Argos DCS, to
support other governmental and non-governmental research or operational requirements, such as
for law enforcement purposes.
Regulations explain not only the policy for using the GOES DCS, but also how users may use
the Argos DCS. These regulations ensure that the Government will not allow its space-based
data collection systems to be used where there are commercial services available that fulfill
users’ requirements. The regulations contain the minimum information requirements necessary
to determine if a user meets these criteria. NOAA enters into an agreement with accepted
applicants and gives them access to the system.
2. Explain how, by whom, how frequently, and for what purpose the information will be
used. If the information collected will be disseminated to the public or used to support
information that will be disseminated to the public, then explain how the collection
complies with all applicable Information Quality Guidelines.
Applications are made in response to the requirements in 15 CFR 911 (under the authority of 15
U.S. C. 313, Duties of the Secretary of Commerce and others), using system use agreement
(SUA) forms. The application information received is used to determine if the applicant meets
the criteria for use of the system. The system use agreements contain the following information:

(1) the period of time the agreement is valid and procedures for its termination, (2) the
authorized use(s) of the DCS, and its priorities for use, (3) the extent of the availability of
commercial services which met the user's requirements and the reasons for choosing the
government system, (4) any applicable government interest in the data, (5) required equipment
standards, (6) standards of operation, (7) conformance with applicable International
Telecommunication Union (ITU )and FCC agreements and regulations, (8) reporting time and
frequencies, (9) data formats, (10) data delivery systems and schedules and (11) user-borne costs.
For both systems, an important prerequisite in reviewing applications for use is that there are no
commercial space-based services available which meet the users’ requirements in terms of
satellite coverage, accuracy, data throughput, platform power consumption, size and weight,
platform compatibility, service continuity and reliability. The GOES DCS can be used only for
environmental purposes and the user needs to be a government agency or sponsored by one for
use, while the Argos DCS can be used for environmental and some very limited nonenvironmental purposes. The non-environmental use of the Argos system is primarily authorized
for government users, for such applications as humanitarian cargo tracking, law enforcement, or
national security purposes. For non-governmental, environmental use of the Argos system, a
prerequisite has ben added that there must be a government interest in the collection of the data.
This prerequisite is similar to, but not the same, as the current GOES DCS sponsorship
requirement.
Moreover, only government and non-profit users may be allowed to use the Argos DCS for nonenvironmental uses, except in cases where there is a significant possibility of the loss of life.
However, at no time will non-environmental use of the Argos DCS exceed five percent of the
system’s total use. These criteria are necessary because neither system is intended to compete
with private sector services. Details concerning the use of the data are also necessary to rank
system use. A standard part of the system use agreement with accepted applicants is that the user
must provide free and open access to the data by U.S. Government agencies.
The GOES DCS is managed solely by NOAA; as a result, the collection of information required
is greater than for the Argos DCS, which is managed cooperatively with the Centre National
d’Etudes Spatiales (CNES), the French Government space agency. As a result of the cooperative
nature of the Argos DCS, CNES handles more of the daily administration of the system, and thus
NOAA does not require the same information from users of the Argos DCS that it requires from
users of the GOES DCS. The system use agreement is under the care of the CNES, and NOAA
is responsible for collecting the technical information.
As explained in the preceding paragraphs, the information gathered has utility. NOAA will
retain control over the information and safeguard it from improper access, modification, and
destruction, consistent with NOAA standards for confidentiality, privacy, and electronic
information. See response to Question 10 of this Supporting Statement for more information on
confidentiality and privacy. The information collection is designed to yield data that meet all
applicable information quality guidelines. Prior to dissemination, the information will be
subjected to quality control measures and a pre-dissemination review pursuant to Section 515 of
Public Law 106-554.

3. Describe whether, and to what extent, the collection of information involves the use of
automated, electronic, mechanical, or other technological techniques or other forms of
information technology.
System use agreements are available from a Web site (http://noaasis.noaa.gov/DCS) and can be
e-mailed to Letecia [email protected], or faxed to 301-817-4569. An automated electronic
submission system for ingesting use requests has been in use for several years for Argos. The
automated system for the GOES DCS has been on hold due to support issues. The number of
applications for the GOES DCS is much smaller than for Argos, and is therefore less of a
processing burden. We hope to have the GOES system online within the next year. The Argos
System Use Agreements are processed by a private company representing the French
Government, and are sent via email into NOAA’s online system.
4. Describe efforts to identify duplication.
The information collected relates to a unique benefit and no duplication has been identified.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
While small businesses may be respondents, the collection would not have any significant
impact upon them and the information requested is the minimum needed to make the necessary
determinations.
6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
If the collection was not conducted, NOAA could not allow potential users access to the system,
which would be to the detriment of those potential users and the government agency using their
data or services. The term of system use agreements for use of the GOES DCS is five years; for
use of the Argos DCS the term is three years. These terms are necessary to ensure that users will
periodically canvass the marketplace to determine whether commercial services have developed
the capabilities to meet their requirements.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
The collection is consistent with the OMB guidelines.

8. Provide information on the PRA Federal Register Notice that solicited public comments
on the information collection prior to this submission. Summarize the public comments
received in response to that notice and describe the actions taken by the agency in response
to those comments. Describe the efforts to consult with persons outside the agency to obtain
their views on the availability of data, frequency of collection, the clarity of instructions
and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be
recorded, disclosed, or reported.
A Federal Register Notice, published on September 28, 2010 (75 FR 59686), solicited public
comment on this collection. None was received.
The program managers for the GOES and Argos DCS consult with users at conferences held
annually at a minimum and usually more frequently.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts are made to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
No confidentiality is promised or provided.
11. Provide additional justification for any questions of a sensitive nature, such as sexual
behavior and attitudes, religious beliefs, and other matters that are commonly considered
private.
No sensitive questions are asked.

12. Provide an estimate in hours of the burden of the collection of information.
The estimated burden for the NOAA DCS is calculated as follows:
GOES

Argos

Totals

Number of respondents

50

365

415

Number of responses per respondent

1

1

Total annual responses

50

365

Time per response

2 hours and
six minutes

1 hour

Total annual burden hours for collection 105

365

415

470

Estimating respondent time at $40 an hour, respondent costs would be $18,800.
13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection (excluding the value of the burden hours in
Question 12 above).
The estimated operational cost for reporting and record-keeping is $0.
14. Provide estimates of annualized cost to the Federal government.
The annual cost to the Federal Government to process the information obtained is estimated at
$1,000 for IT support and personnel costs.
15. Explain the reasons for any program changes or adjustments.
Adjustments: The burden to the public has increased slightly due to more applications being
received (i.e. more use of the system). Thus, although the reporting time for the GOES form has
been corrected from 3 hours to 2 hours, 6 minutes, there is a net burden increase. Finally, there is
no virtually no submission cost as almost all forms are emailed.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
The results of the collection will not be published.

17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain the reasons why display would be inappropriate.
NOAA requests an exemption from displaying the OMB control number and expiration data on
the Argos DCS System Use Agreement itself, and will include it on an insert that contains the
other PRA information. The Argos DCS is operated through a cooperative program between the
United States and France. The French have requested that the PRA guidance be less conspicuous
on the form.
18. Explain each exception to the certification statement.
NA.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not employ statistical methods.