Justification

1205-0481 “Green Jobs Baseline Information Data ” Non Substantive Request Justification

Rationale: As a condition for approving the extension request for this ICR, OMB asked for responses to its follow-up questions (below) and that the agency’s responses, along with revised documents, be submitted as a non substantive request.

1. This request for extension should provide information on the current status of recruitment at the different sites and what they have been seeing in terms of recruitment rates so far. 

Agency response: This information has been included in the revised supporting statement A, pages 11-12.

2. A.10 it seems the Privacy Act likely applies to this collection, but it doesn’t clearly say so here.  If it does, please provide the applicable SORN.  If the Privacy Act applies, the statement in the BIF should read “confidential under the Privacy Act,” but if it doesn’t, then the statement should be “private to the extent permitted by law.”   

Agency response: Individual responses are not considered to be agency records, and ETA makes no express assurances of confidentiality; however, privacy is assured. Therefore please note this statement at the outset of the revised supporting statement A,#10. Also all related wording in the Consent form;  the Baseline Information Form statement was changed to “private.” The assurance is to maintain records private to the extent permitted by applicable laws.

3. A.12 the request appears to be for the full burden of the baseline collection, but should be updated to reflect only the remaining recruitment burden. 

Agency response: The supporting statement A #12 was revised to reflect the current burden. The corresponding data in Part B was concurrently updated. In Part B, the table and related text pertinent to the Respondent Universe and Sampling was revised to reflect current conditions. For example, since the original approval, our number of sites went down from 6 to 4 and the number of respondents also went down accordingly. So in our discussion about Respondent Universe in Part B, we updated the table that showed the “universe” consisting of previous 6 sites and 6000 respondents changed to 4 sites and 4000 respondents.

4. Although this is just the baseline, there is no analysis plan provided or power analysis to show that the proposed site level sample sizes will be sufficient to detect reasonable program effects.  What technical information is available in these areas (perhaps from a design document) or when will more formal plans be available? 

Agency response: Please see the Study Design, uploaded in ROCIS as an ICR supplementary document.