TARE_Supporting_Statement_2011- Post OMB Interview (2011-09-07)

Supporting Statement for Paperwork Reduction Act Submission

Technical Assistance Request and Evaluation

OMB Control Number: 1670-NEW

Specific Instructions

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

The Office of Emergency Communications (OEC), formed under Title XVIII of the Homeland Security Act of 2002, 6 U.S.C. § 101 et seq., as amended, provides emergency communications-related technical assistance at no charge to State, regional, local, and tribal government officials. To receive this technical assistance, stakeholders must submit a request form identifying their priorities. In order for OEC to assess the value of the services it provides through technical assistance, an evaluation form is also requested of those receiving technical assistance.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection.

OEC will use the technical assistance request form to identify the number and type of technical assistance visits needed by the State, territory, local, and tribal agencies. This information will enable OEC to plan and align resources accordingly. OEC will consider each request based on the priority indicated by the State, as well as the anticipated impact of the service offering on the implementation of the Statewide Communications Interoperability Plan (SCIP) and the National Emergency Communications Plan (NECP). The evaluation form will be completed by stakeholders at the completion of OEC technical assistance visits and enable OEC to assess the quality of technical assistance services provided and in a holistic fashion measure the value of the services. The information collected through these evaluations will then be used by OEC for continued improvement planning. The forms, which include the following, will be completed by State, territory, local, and/or tribal government employees and collected through unclassified electronic or manual submission:

DHS Form 9042 – Technical Assistance Request Form

OEC will use DHS Form 9042, the Technical Assistance Request Form to conduct a review of the effectiveness and adequacy of technical assistance services provided to State and local officials for interoperable and operable communications. These evaluation forms will be filled in at the completion of technical assistance services to participants of those events.

DHS Form 9043 – Technical Assistance Evaluation Form

OEC will use DHS Form 9043, the Technical Assistance Evaluation Form to collate requests for technical assistance and evaluate the impact of requests on the attainment of the National Emergency Communications Plan’s goals, objectives, and initiatives. These request forms will be filled in by statewide interoperability coordinators or their designees at the start of the technical assistance review cycle, and on an as needed basis when out-of-cycle.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.

The collection of information is mostly electronic via email, but can also be received in paper form by facsimile or mail, to facilitate ease of evaluation of OEC technical assistance. A webform may be a future version of electronic collection. to Evaluation forms will be available in hard copy at each training session and time will be provided to complete the evaluation at the conclusion of the course. OEC anticipates that approximately 80 percent of evaluation forms will be received electronically. OEC will use DHS Forms 9042 and 9043 for TA requests and evaluations, respectively.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.

This information is not collected in any form and, therefore, is not duplicated elsewhere.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.

This information collection does not have an impact on small businesses or other small entities.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

If OEC does not collect this information it will not be able to effectively carry out a key statutory responsibility of the office—the provision of technical assistance services. In addition, without this collection, OEC will be unable to gather sufficient information for quality assurance or quality improvement purposes.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

*requiring respondents to report information to the agency more often than quarterly;

*requiring respondents to prepare a written response to a collection of information

in fewer than 30 days after receipt of it;

*requiring respondents to submit more than an original and two copies of any document;

*requiring respondents to retain records, other than health, medical, government

contract, grant-in-aid, or tax records, for more than three years;

*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;

*requiring the use of a statistical data classification that has not been reviewed and

approved by OMB;

*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

*requiring respondents to submit proprietary trade secrets, 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.

The special circumstances contained in item 7 of the Supporting Statement are not applicable to this information collection.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8(d), soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice [and in response to the PRA statement associated with the collection over the past three years] and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

60 Day Federal Register Notice: Wednesday, March 3, 2009 (Volume 75, Number 41), Page 9608-9609.

30 Day Federal Register Notice: February 11, 2011 (Volume 76, Number 29), Page 7870.

DHS received no comments from either FRNs.

Describe 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.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years — even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

Form Numbers: DHS Form 9042 Technical Assistance Request and DHS Form 9043 Technical Assistance Evaluation

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

There is no offer of monetary or material value for this information collection.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Information protected by the Privacy Act of 1974 will be kept private or anonymous to the extent allowable by law. System will be covered by existing PIA: DHS-Wide General Contacts List and existing SORN: DHS/ALL-002 - Department of Homeland Security (DHS) Mailing and Other Lists System.

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. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should:

*Indicate the number of respondents, frequency of response, annual hour burden,

and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

*If this request for approval covers more than one form, provide separate hour

burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

*Provide estimates of annualized cost to respondents for the hour burdens for

collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in Item 14.

OEC estimates that stakeholders (police, fire, EMS, emergency managers, dispatchers, radio operators, government workers, etc.) will request and evaluate technical assistance services. Test participants indicate that the total time required to complete the Technical Assistance Request Form and Technical Assistance Evaluation Form amounts to 25 minutes for each form, including clerical time. Therefore, the total annual burden associated with the proposed elements of this collection is 51 minutes. For an estimated 2,056 respondents, the burden is 863.52 hours. At a rate of $24.42 per hour¹, the dollar value of the total annual burden hours associated with the existing elements of this information collection equals $21,087.16.

Instrument	# of Respondents	Responses per Respondent	Average Burden per Response (in hours)	Total Annual Burden (in hours)	Total Annual Burden (in dollars)
Technical Assistance Request Form	56	1	.42	23.52	574.36
Technical Assistance Evaluation Form	2000	1	.42	840	20,512.80
TOTAL	2,056	1	.84 (50 Minutes)	863.52	21,087.16

13. Provide an estimate of the total annual [non-hour] cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

* The cost estimate should be split into two components: (a) a total capital and start-

up cost component (annualized over its expected useful life) and (b) a total operation and

maintenance and purchase of services component. The estimates should take into account

costs associated with generating, maintaining, and disclosing or providing the information

[including filing fees paid]. Include descriptions of methods used to estimate major cost

factors including system and technology acquisition, expected useful life of capital

equipment, the discount rate(s), and the time period over which costs will be incurred.

Capital and start-up costs include, among other items, preparations for collecting

information such as purchasing computers and software; monitoring, sampling, drilling

and testing equipment; and record storage facilities.

* If cost estimates are expected to vary widely, agencies should present ranges of cost

burdens and explain the reasons for the variance. The cost of purchasing or contracting

out information collection services should be a part of this cost burden estimate. In

developing cost burden estimates, agencies may consult with a sample of respondents

(fewer than 10), utilize the 60-day pre-OMB submission public comment process and use

existing economic or regulatory impact analysis associated with the rulemaking containing

the information collection, as appropriate.

* Generally, estimates should not include purchases of equipment or services, or

portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance

with requirements not associated with the information collection, (3) for reasons other

than to provide information or keep records for the government, or (4) as part of

customary and usual business or private practices.

There is no submission or filing fee associated with applying to participate in OEC events. As all forms are completed via email or in person, there are no associated printing or mailing costs.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

Based on internal review, OEC personnel estimate that it takes approximately 10 minutes to review applications and evaluations. The hourly basic rate of $54.15 for General Schedule grade 13 step 10 for the Washington, DC locality was used for these calculations.

2,056 request/evaluation forms package x 10 minutes/package = 343 hours

343 hours x $54.15 = $18,573.45

Total Cost to the Government = $18,573.45

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

There has been no increase or decrease in the estimated annual burden hours previously reported for this information collection as this is a new collection.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

This information collection will not be published for statistical purposes.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

OEC will display the expiration date for OMB approval of this information collection.

18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

OEC does not request an exception to the certification of this information collection.

1 This hourly rate is an average hourly wage calculation based on Bureau of Labor Statistics (BLS) from May 2008 for numerous occupations of persons who attend OEC events, including the following: Medical and Health Services Managers; Emergency Management Specialists; Network and Computer Systems Administrators; Network Systems and Data Communications Analysts; Electrical and Electronic Engineering Technicians; Emergency Medical Technicians and Paramedics; First-Line Supervisors/Managers of Police and Detectives; First-Line Supervisors/Managers of Police and Detectives; First-Line Supervisors/Managers of Fire Fighting and Prevention Workers; First-Line Supervisors/Managers; Protective Service Workers (All Other); Fire Fighters; Police and Sheriff's Patrol Officers; Sales Representatives (Wholesale and Manufacturing, Technical and Scientific Products); Communications Equipment Operators (All Other); Reservation and Transportation Ticket Agents and Travel Clerks; Police, Fire, and Ambulance Dispatchers; Dispatchers (Except Police, Fire, and Ambulance); Legal Secretaries; Medical Secretaries; Secretaries (except Legal, Medical, and Executive); First-Line Supervisors/Managers (of Mechanics, Installers, and Repairers); Radio Mechanics; Telecommunications Equipment Installers and Repairers (except Line Installers); US Government Employee (GS-13, Step 5, averaged across locality and CONUS).

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