supporting_statement_part_a fireprone communities 2011

The Supporting Statement for OMB 0596-0186

Perceptions of Risk, Trust, Responsibility, and Management Preferences among

Fire-prone Communities in the Western United States

August 2011

The Supporting Statement for OMB 0596-0186

Perceptions of Risk, Trust, Responsibility, and Management Preferences among Fire-prone Communities in the Western United States

August 2011

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.

Laws, Regulations, and Statutes

• Public Law 95-307, Forest and Rangeland Renewable Resources Research Act of 1978

• Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations

This is a request for renewal of a currently approved information collection. Public Law 95-307 directed the Secretary of Agriculture to research the multiple uses and products, including recreation, of forests and rangelands to facilitate their most effective use. Executive Order 12898 provides guidance to Federal agencies on identifying disproportionately high and adverse human health or environmental effects on minority and low-income populations.

Fire risk and the impact of recent fires have been significant on several Western urban-proximate national forests. The Forest Service does not fully understand how community residents residing in urban areas surrounded by national forests (wildland urban interface) perceive fire risk or impacts from forest fires. The Agency needs to know how residents have been addressing fire risk, residents’ beliefs about individual responsibility in reducing fire risk, and the myriad of other concerns residents have related to fire and fire risk. This understanding is important, because it influences decisions about management of fire and fire risk on national forest lands and in the wildland urban interface.

This study seeks to gain first-hand information from residents in communities proximate to and surrounded by urban national forests in the Western United States. The information gathered will help resource managers better understand the beliefs, perceptions, and behaviors of those residents. Results will be helpful in managing fire education and information programs, continuing public collaboration efforts, and in the selection of fire management and risk mitigation strategies. Other fire management agencies and organizations will also benefit from this knowledge.

The Forest Service is proposing to continue to survey other fire-prone communities in the western United States. OMB approval would permit the Agency to respond rapidly and efficiently to information requests from managers, community groups, and other government and private sector agencies seeking information captured within this proposed collection.

Selection of specific forests for study by the proponent will involve careful verification of need for a particular wildland urban interface area, including checking with local forest managers and researchers known to be conducting fire social science research. Ongoing verification suggests this study remains unique in the landscape of studies being conducted on social science and fire management. The proponent will ensure the information collection activities remain within allocated annual burden hours by not deviating from the set quantities.

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.

1. What information will be collected - reported or recorded? (If there are pieces of information that are especially burdensome in the collection, a specific explanation should be provided.)

Information to be collected includes:

• Concern about fire and fire risk,

• Knowledge about fire,

• Salient values similarity,

• Trust,

• Value consistency and validity of inconsistency,

• Reasons for reliance,

• Performance and confidence,

• Emotional reactions to fire,

• Key fire management objectives,

• Personal experiences with fire,

• Stressors associated with fire,

• Reasons for concern,

• Perceived vulnerability,

• Responsibility and accomplishment for fire risk reduction,

• Barriers to risk reduction,

• Future orientation,

• Mode of information receipt,

• Socio-demographics,

• Objectives/values and concerns related to fire management,

• Alternative approaches to accomplishing fire management objectives,

• Values/goals and trust,

• Types of information needed or of interest.

2. From whom will the information be collected? If there are different respondent categories (e.g., loan applicant versus a bank versus an appraiser), each should be described along with the type of collection activity that applies.

The information to be collected from individual residents of fire prone communities adjacent to national forest lands in the western United States, who agreed to attend and participate in a focus group session. All participants are asked to complete the questionnaire and participate in a focus group discussion.

3. What will this information be used for - provide ALL uses?

The information collected will be used as follows:

• To construct an executive summary on findings,

• To prepare journal articles for submission to peer review outlets,

• For presentations at scientific meetings, and

• For presentations to natural resource managers as appropriate.

Brief summaries may appear in other outlets, such as summaries of research findings produced by the program for administrative and research reporting. The proponent is assessing the feasibility of a workshop for local Forest Service managers to share the findings from this study.

4. How will the information be collected (e.g., forms, non-forms, electronically, face-to-face, over the phone, over the Internet)? Does the respondent have multiple options for providing the information? If so, what are they?

Information collected via self-administered questionnaire and focus group discussions. Only group session participants asked to provide information, due to the need for in-depth qualitative and quantitative information, as well as the need to link the information collected from the group forums and self-administered questionnaires.

5. How frequently will the information be collected?

The information will be gathered from each respondent one time.

6. Will the information be shared with any other organizations inside or outside USDA or the government?

The collected information will be shared via a technical report sent to public and private sectors, as well as journal articles available to the public. Multiple natural resource management agencies will receive research findings, to ensure diffusion of information, as well as any agency or individual requesting summary findings. Upon request, fire safe councils and other public/community based groups surrounding each forest will receive the reports and other available presentations. This may include face-to-face meetings where possible to allow for verification/reflection on findings with publics.

Findings from previously completed research conducted under this OMB approval were shared through unit research updates (summaries going out to an email tree and printed versions sent to the visitors’ center in Washington D.C.), multiple presentations at professional and scientific meetings (including the Society for Human Ecology and the International Symposium on Society and Resource Management) a research paper contributed to the Forest Threats Encyclopedia (available online and in print), a station research paper, and other outlets.

7. If this is an ongoing collection, how have the collection requirements changed over time?

The initial approval (OMB Notice of Action dated July 29, 2005) allowed collection on one forest (San Bernardino National Forest). In July 2008, proponents requested to change the study area location to Lake Tahoe, California, subsequently approved by OMB (Notice of Action dated September 4, 2007). During the last period of renewal the collection was conducted in communities surrounding the Sequoia National Forest. Budgetary constraints limited the collection to the one area, however, others are already identified as points of substantial interest for this work.

Successful completion of that effort revealed significant interest in additional study, and the need to consider similar information in other fire prone areas. Based on the number of inquiries received by the proponent’s Forest Service research unit regarding the ability and potential to collect similar data on other forests, the Forest Service is proposing to continue to continue this collection adding other fire-prone communities in the western United States.

This approval would permit us to respond rapidly and efficiently to information requests from managers, community groups, and other government and private sector agencies seeking information captured within this proposed collection. Furthermore, the ability to gather the information in multiple locations would allow us to understand variations and similarities among selected communities that are essential to understanding complexities of fire management and public-agency interactions. Initial and subsequent findings also suggested needs for refinement of concepts covered in the focus group sessions during discussions, and in the survey instrument, which were integrated into this renewal request (minor changes only).

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.

Due to the need for in-depth discussion and insights derived from the discussions, information technology is not suitable for this inquiry. Each focus group meeting begins with participants answering self-administered questionnaires, after which facilitators lead participants through a series of discussion topics. Comments are tape recorded and simultaneously entered on a laptop computer. Maintenance of anonymity is assured. Only the cooperator and focus group transcriber have access to the tapes and coding of comments is by an ID number rather than the individual’s name.

However, where communities have employed social networks, blogs, and listservs, modern social technologies have been, and will continue to be used to ensure awareness of the study and opportunities to participate. Additionally, websearches will be used to identify a range of community groups and interests to ensure that groups that have a potential vested interest in wildland fire and management are contacted and provided the opportunity for members to participate.

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.

The information to be collected is not presently available, nor are we aware of such an endeavor planned through any other means. The limit of one forest area in the initial collection affirmed the need for further inquiry. The follow-up at Sequoia revealed an important theme of local ecological knowledge not previously uncovered, demonstrating the need to continue this inquiry. Selection of a particular forest will involve careful verification of need for that particular area, including checking with local forest managers and researchers known to be conducting fire social science research to ensure verification of management needs and that no duplication of effort occurs. While selected scales may in fact be similar to other proponent’s proposed work this occurs when literature points to the need for additional study on this topic in different communities. The proponent will take great care in ensuring the communities selected have not been focal points for multiple studies, or when studies have been done, that they are distinctly different and present time lapse between this study and any prior work.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

This information collection does not impact small businesses, it involves community residents who will participate and provide their own opinions.

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.

The ability to manage fire and fire risk on the urban proximate national forests has gained importance as its complexity has increased. Ecosystem related concerns have gained in complexity, and residents’ concerns have increased. Public input has become an expectation, and this is one very effective route for gathering public opinion on fire management on forests in the western United States. Without this information, the basis for management decisions will limited and anecdotal information regarding public values and perceptions, and studies conducted in other areas that may or may not be applicable to the geographic and community characteristics of immediate concern.

This study will yield information that will help the agency understand public concerns and attitudes. For example, this study will help increase understanding of why participants believe certain fire risk reduction techniques are better than others, why participants do or do not trust the Forest Service, and illuminate public concerns about fire risk.

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;

Information gathered once through participation in a focus group session, wherein a self-administered survey is completed, and minimally in advance to arrange participation into a specific group.

• Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

The self-administered questionnaire completed in the group session that the resident agrees to attend; however, scheduling occurs with the resident’s full cooperation and agreement.

• 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;

The results will be applicable to the focus group participants, and will be representative of the styles and ranges of thinking of these community residents proximate to urban-proximate national forests selected. The goal is provide a snapshot of the styles and ranges of thinking of community residents in the most fire-prone areas on this particular forest. The intent of focus groups is not to arrive at assurance of general consensus; rather it is to gain in depth insights and understandings not available through other routes.

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

Violations of anonymity are not a risk in this study, nor will the methods of securing anonymity impede sharing of information with other agencies or individuals desiring study results in non-identifiable statistical databases and group reporting formats. The data collection approach for both the focus group transcripts and the self-administered surveys maintains anonymity by not including participants’ names or contact information in the information collected. While fellow focus group participants may comment later outside of the focus group session, with other participants or with others, participants are advised of this in introductory remarks, and participants are asked to respect the expressions of personal values and experiences provided by fellow attendees.

• Requiring respondents to 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.

There are no other special circumstances. Collection of information conducted in a manner consistent with the guidelines in 5 CFR 1320.6.

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 describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

Notice of the 60-day comment period was published in the Federal Register, vol. 76, No. 111, on Thursday, June 9, 2011, pages 33701 and 33702. Comments in response to the Federal Register Notice were received from one party.

Comment_1: jean public, dated June 6, 2011, via e-mail

Inserted as typed:

please fire the wimps who waste tax dollars like this

we dont need researchers. we need firefighters and planes to carry water to put out fires. we dont need cyanide on our forests, nor other toxic chemicals to kill all life and make the forest into a chemical jungle zone as if its war going on. this survey is at true waste of american tax dollars. it was planned so somebody can sit around an office looking at paper. use these tax dollars to fight the flames. sto p hiring wimp alleged "researchers". jean public address if required

[Federal Register Volume 76, Number 111 (Thursday, June 9, 2011)]

[Notices]

[Pages 33701-33702]

From the Federal Register Online via the Government Printing Office [www.gpo.gov]

[FR Doc No: 2011-14281]

Forest Service response:

It is unfortunate that the argument made takes such an extreme stance. However, I can assure the reviewers that the study is not related to any toxic chemicals that may kill life or create chemical jungles. In fact, the proposed extension would continue to allow expression of public concerns regarding fire management, allowing consideration of the range of opinions in fire management objectives and management approaches to arrive at those objectives.

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 record keeping, 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.

The individuals listed below provided comments since the 2008 submitted comments on the renewal of this information collection. It was the proponent’s intent to contact parties other than those contacted in 2004 and 2008, to supplement the comments received on the original submission, thus comments submitted with those packages are not included.

(Note from proponent: In addition to these comments, it might be helpful to consider the comments submitted with the initial package in 2004 and the renewal in 2008. At those points positive comments were received from a number of individuals, including those with international research perspective on trust and risk management (Doctors Midden and Siegrist), a community resident (Ms. Arbaugh), an independent consultant (Dr. Fege), land managers (Ms. Rosenthal and Mr. Dietrich), and Forest Service public affairs officers (Ms. Wenstrom and Ms. Abbas). In addition, comments from Fire Safe Council representatives were included, all speaking positively to the collection.)

Dr. Jonathan Taylor, retired from USGS, was consulted in April 2011 regarding the study methodology, content, and approach to analysis. He relayed the necessity of this information collection, providing emphatic support for the community based focus, the collection from multiple communities and importance of geographic and cultural variations, and the importance of incorporating local ecological knowledge.

Pam Leschak, Fire Adapted Communities Program Manager, USDA Forest Service-Fire and Aviation Management, Washington, DC, National Interagency Fire Center (NIFC) commented on the Federal Register announcement in 2011, expressing specific support for this line of inquiry and continuing research on communities, especially along the lines of the proposed collection. She has offered ongoing assistance and support for this line of inquiry.

Grace Wang, Ph.D., Western Washington University, collaborated on the Sequoia collection and expressed significant interest in continuing this line of work and relayed multiple messages of support for the study received at when presented in Madison, Wisconsin in June, 2011 at the International Symposium for Society and Resource Management.

Members of the communities surrounding the Sequoia National Forest, especially those coordinated through Dr. Ed Royce, expressed specific need for community voices to be heard and for input opportunities to be increased regarding wildland fire management. They expressed strong interest in the study and its application to land management. (relayed in 2009)

Lynn Huntsinger, Ph.D. of UC Berkeley, and Kim Rodrigues, Ph.D. of UC Davis expressed strong interest in results from this study to complement their efforts with Sierra Nevada communities and adaptive management. We have agreed to coordinate efforts to ensure multiple meetings with communities are not conflicting or creating confusion for participants. (relayed in 2010)

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

No remuneration or gifts are offered. Light refreshments are served during the group session when possible, to help ensure participant comfort.

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

Respondents assured of the anonymous nature of their responses. While participants will be asked to respect the comments and perspectives of other participants, there is no way to assure them that attendees will not discuss their remarks after the session with them or with other individuals. A cautionary statement at the start of the session will be presented to this effect. Contact information maintained separately from responses and destroyed once focus groups are scheduled and held. Although constructed codes will be used to link the questionnaire to the focus group comments, records of discussions will only be handled and viewed by the coding team. There will be no way to directly identify any individual. Any reporting of comments or responses to the surveys will be in-group form, or if from an individual, will be assigned a pseudonym or be free of identifying information. This is not out of keeping with Agency policy, given that the handling of data assures that data can be anonymous and still allow sharing of datasets and findings as appropriate.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or 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.

Participants complete the Impact of Event Scale - Revised, examining impacts of stressors on daily functioning. This measurement addresses aspects of post-traumatic stress disorder, which proponents believe to be similar to the personal experiences of residents in a high fire risk area. This is a valid and reliable scale for assessing stress response, and though questions may be viewed as sensitive, anonymity is assured and respondents may skip any objectionable items. Assessing stress is an important component of understanding the impacts of fire risk on community residents and because it is an established scale, proponents have obtained the information on reliability and validity of the scale and found it to be excellent for this purpose (www.criminology.unimlb.edu.au/victims/resources/assessment/ptsd/ies-r.html).

12. Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form.

a) Description of the collection activity

b) Corresponding form number (if applicable)

c) Number of respondents

d) Number of responses annually per respondent,

e) Total annual responses (columns c x d)

f) Estimated hours per response

g) Total annual burden hours (columns e x f)

Table 1 – Estimated Annual Burden Hours

Survey	Sample Size	Freq	Responses				Non-response				Total Burden Hours
			Resp. Count	Freq x Count	Min./ Resp.	Burden Hours	Nonresp Count	Freq. x Count	Min./ Nonr.	Burden Hours
Survey completion	197	1	195	195	20	65	2	2	3	0	65
Focus group participation	200	1	200	200	90	300	0	0	0	0	300
Pre-Focus Group Contacts by mail, email, or phone	300	1	270	270	15	68	30	30	3	2	69
Total	300					433	32				435

*Note that of the 300 attempts, 270 individuals will be contacted to be scheduled, we assume 200 will agree and be participants in the survey and focus group portions of the study

Proponent’s experience with previous versions of this information collection indicates that of 270 individuals contacted and asked to attend a focus group, 200 will agree to attend. This initial contact will take 15 minutes (or .25 hour).

The 200 attendees will taking self-administered survey will complete it in 20 minutes (.3333 hour). We expect that among these, 3 will likely not respond on the requested survey (very few refuse to complete the survey, however, it seems prudent to allow for this possibility). The focus group discussion (including comment sheet) will involve the same 200 people and will last approximately one hour and thirty minutes (1.5 hours).

Total estimated annual burden is 435 hours.

• Record keeping burden should be addressed separately and should include columns for:

a) Description of record keeping activity: None

b) Number of record keepers: None

c) Annual hours per record keeper: None

d) Total annual record keeping hours (columns b x c): None

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

Table 2 – Estimated Cost to Respondents

(a) Description of the Collection Activity	(b) Estimated Total Annual Burden on Respondents (Hours)	(c)* Estimated Average Income per Hour	(d) Estimated Cost to Respondents
Scheduling into focus groups	69	$19.52	$1,346.88
Completing survey	65	$19.52	$1,268.80
Focus group discussions	300	$19.52	$5,856.00
Totals	 434	$19.52	$8,471.68

Based on average weekly salary from Department of Labor, Bureau of Labor Statistics for July 2011 (http://www.bls.gov/news.release/pdf/realer.pdf) = $19.52/hour (derived from Table A-2), the estimated cost to respondents for this information collection is $8,472.

13. Provide estimates of the total annual 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 estimates 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.

There are no capital operation and maintenance costs.

14. Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

The response to this question covers the actual costs the agency will incur as a result of implementing the information collection. The estimate should cover the entire life cycle of the collection and include costs, if applicable, for:

• Employee labor and materials for developing, printing, storing forms

• Based on previous collection experience, this amount is has been revised and reduced to reflect a more realistic cost of $2,422-

• Employee labor and materials for developing computer systems, screens, or reports to support the collection $2,422-

• Employee travel costs $4,500-

• Cost of contractor services or other reimbursements to individuals or organizations assisting in the collection of information $75,000 assuming 3 years of collection; 200 respondents per year

• Employee labor and materials for collecting the information $7,925-

• Employee labor and materials for analyzing, evaluating, summarizing, and/or reporting on the collected information $31,699-

Table 3 – Estimated Cost to the Government

ACTION ITEM	PERSONNEL	GS LEVEL	HOURLY RATE*	HOURS	Total Cost
Employee labor and materials for developing, printing, and storing forms	Social science analyst	GS-9, step 10	$40.37	60	 $ 2,422
Employee labor and materials for developing computer systems, screens, or reports to support the collection	Social science analyst	GS-9, step 10	$40.37	60	 $ 2,422
Employee travel costs	Scientist	N/A	N/A	N/A	$ 4,500
Cost of contractor services or other reimbursements to individuals or organizations assisting in the collection of information	N/A	N/A	N/A	N/A	$ 75,000
Employee labor and materials for collecting the information	Scientist	GS-13, step 8	$66.04	120	 $ 7,925
Employee labor and materials for analyzing, evaluating, summarizing, and/or reporting on the collected information	Scientist	GS-13, step 8	$66.04	480	 $ 31,699
Total estimated cost to the Federal government for this information collection (all three years)	 $123,968
Total estimated ANNUAL cost to the Federal government for this information collection	 $41,323

* Taken from: http://www.opm.gov/oca/11tables/index.asp, Cost to Government (Los Angeles area calculated at hourly wage multiplied by 1.3

The hourly wage for a GS-13/step 8 is $50.80 multiplied by 1.3 (cost to government) equals $66.04/hour: $50.80/hour x 1.3 (cost to government) = $66.04/hour cost to government.

The hourly wage for a GS-9/step 10 is $31.05 multiplied by 1.3 (cost to government) equals $40.37/hour: $31.05 x 1.3 (cost to government) = $40.37/hour cost to government.

Total annual estimated cost to the Federal government for this information collection is $41,323.

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

This request is for a three-year renewal. There is an adjustment decrease of 50 burden hours based on experience gained from the last collection.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

Questionnaire responses will go into a Windows data file (Excel and then transferred to SPSS when cleaned) and be re-verified. Analysis of questionnaire responses will include summary and descriptive statistics, as well as correlation. Other analyses conducted as appropriate for a non-random sample and constraints will be clearly noted in any presentation of findings.

Focus group discussions will be transcribed and cross-verified for correspondence with audio recordings of discussions. Content analysis will be employed for each discussion area, with themes developed in keeping with content analysis protocols. Analysis of transcripts may employ software designed for this purpose.

Findings will be summarized in a technical report, and aspects of the study will be prepared for submission to one or more peer reviewed journals. In addition, findings will be included in papers, book chapters, and unit research-update summary, as well as other agency reporting mechanisms. The focus will be on respondents, rather than attempts to generalize to the population of community residents within and surrounding the subject forest. Findings will be included in presentations at scientific meetings, natural resource agency meetings, and public meetings, as appropriate.

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.

The OMB approval number and expiration date will be displayed.

18. Explain each exception to the certification statement identified in item 19, "Certification Requirement for Paperwork Reduction Act."

There are no exceptions to the certification statement.

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