18 Supporting Statements

Distracted Driving Intercept Survey

Table of Contents

SUPPORTING STATEMENT

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary..................3

2. Indicate how, by whom, and for what purpose the information is to be used ...................5

3. Describe whether, and to what extent, the collection of information involves

the use of technological collection techniques or other forms of information

technology...........................................................................................................................7

4. Describe efforts to identify duplication. Show specifically why any similar

information already available cannot be used.....................................................................7

5. If the collection of information impacts small businesses or other small entities,

describe methods used to minimize burden........................................................................7

6. Describe the consequence to Federal program or policy activities if the

collection is not conducted or is conducted less frequently................................................8

7. Explain any special circumstances that would cause the information collection

to be conducted in a manner inconsistent with the guidelines set forth in

5 CFR 1320.6.......................................................................................................................8

8. 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. Describe efforts to consult with persons

outside the agency to obtain their views............................................................................. 8

9. Explain any decision to provide any payment or gift to respondents, other

than remuneration of contractors or grantees..................................................................... 9

10. Describe any assurance of confidentiality provided to respondents.................................. 9

11. Provide additional justification for questions of a sensitive nature................................... 9

12. Provide estimates of the hour burden of the collection of information on the

respondents.........................................................................................................................9

13. Provide an estimate of the total annual cost burden to respondents or record

keepers resulting from the collection of information........................................................10

14. Provide estimates of annualized cost to the Federal government.....................................10

15. Explain the reasons for any program changes or adjustments reported in Items

13 or 14 of the OMB Form 83-1.......................................................................................10

16. For collections of information whose results will be published, outline plans

for tabulation, and publication...........................................................................................11

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........12

18. Explain each exception to the certification statement identified in Item 19,

Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-1...............12

Appendices

Appendix A: Title 49, Chapter 301, Section 30168 of the United States Code

Appendix B-1: 60 Day Federal Register Notice

Appendix B-2: 30 Day Federal Register Notice

Appendix C: Distracted Driving Intercept Screener and Survey

Appendix D: Justification for Survey Questions

SECTION A

A) Justification

The National Highway Traffic Safety Administration (NHTSA) was established by the Highway Safety Act of 1970 (23 U.S.C. 101) to carry out a Congressional mandate to reduce the mounting number of deaths, injuries and economic losses resulting from motor vehicle crashes on our Nation’s highways. In support of this mission, NHTSA proposes to conduct information collections to evaluate the effectiveness of a distracted driving high-visibility enforcement (HVE) demonstration program in deterring those practices.

NHTSA must account for whether its initiatives were effective. An essential part of this evaluation effort will be comparing a baseline survey of public’s awareness and attitudes towards NHTSA’s initiatives to reduce distracted driving immediately prior to the initiation of a mobilization with post-mobilization surveys conducted immediately following the campaign.

NHTSA proposes to conduct an information collection to evaluate the effectiveness of a High Visibility Enforcement (HVE) program designed to reduce distracted driving behavior in two States. HVE uses media to increase public awareness of enforcement initiatives to crack down on particular unsafe driving behaviors, which in this case is using an electronic device such as a hand-held cell phone while driving.

NHTSA is requesting approval to conduct intercept surveys at driver licensing offices in Delaware and New Jersey (comparison state) and gas stations in California and Oregon (comparison state) before, during, and after Distracted Driving Demonstration programs for the purpose of evaluating the demonstration program. NHTSA is requesting approval for intercept surveys beginning in January 2013 and concluding in the summer of 2013. NHTSA will administer the Distracted Driving Intercept Survey (DDIS), a one-page survey that drivers can complete while waiting at selected driver’s licensing (DMV) offices or while attending large volume gas stations.

The following sections describe the justification for these proposed data collections in more detail, along with the estimates of cost and burden.

A.1. Explain the circumstances that make the collection of information necessary. Identify any Legal or administrative requirements that necessitate the collection.

1. a. Circumstances making the collection necessary

The National Highway Traffic Safety Administration (NHTSA) was established by the Highway Safety Act of l970 (23 U.S.C. 101) to carry out a Congressional mandate to reduce the mounting number of deaths, injuries, and economic losses resulting from motor vehicle crashes on the Nation’s highways. As part of this statutory mandate, NHTSA is authorized to conduct research as a foundation for the development of motor vehicle standards and traffic safety programs.

NHTSA’s driver distraction research suggests that additional workload demands, such as occur when texting while driving, degrade driver performance.¹ In particular, driving distractions may lead to reduced eye scanning behavior, slower reaction time, degraded vehicle control, and lower detection of objects in peripheral vision, any of which may increase the likelihood of a crash (see distraction.gov).

By 2010, CTIA, the Wireless Association®, estimated that the number of cellular phone subscribers had tripled over the past 10 years to 302 million – 96% of the U.S. population, continuing to increase to 331.6 million by 2011. According to CTIA, the number of active smartphones and PDAs increased 43% from 2010 (78.2 million) to 2011 (111.5 million). Half of American adults own a smartphone as of February 2012². Many users have more than one wireless device – one for work, another for personal use, or a variety of smartphones, tablets, and e-readers. Cell phone ownership starts at increasingly younger ages. The way Americans use their cell phones is rapidly changing. According to CTIA, from 2009 to 2011, the largest increase was in multiple media services that handle photos and other applications (up 51%), followed by text messages (up 47%)³.

Traffic safety stakeholders pushed for laws to prevent distracted driving crashes. In response, States enacted legislation with various laws that ban drivers from using cellular phones while driving: 32 States and D.C. ban all cell phone use by novice drivers; 10 States, D.C., Guam, and the Virgin Islands prohibit all drivers from using handheld cell phones while driving;.39 States, D.C., Guam, and the Virgin Islands ban text messaging for all drivers; and an additional 5 states prohibit text messaging by novice drivers⁴.

NHTSA is planning to conduct state demonstration programs to build public awareness of the hazards of inattentive driving by applying NHTSA’s proven Click It or Ticket (CIOT) high-visibility enforcement (HVE) model to distracted driving. The CIOT model includes 1) data collection before, during, and after media and enforcement phases; 2) earned and paid publicity announcing vigorous enforcement; 3) highly visible enforcement each day of a two-week enforcement period; and 4) a media event announcing program results and giving credit to all of the participants in the community program at the end of each wave.

NHTSA showed that the model successfully reduced hand-held cell phone use and texting at the community level in Hartford, Connecticut and Syracuse, New York⁵. The next step is to implement this program in two States that have a law banning drivers from using hand-held cell phones. Delaware and California applied for and received NHTSA assistance to conduct the distracted driving HVE program on a large scale.

The programs will be implemented statewide in Delaware and throughout the Greater Sacramento area in California (i.e., Sacramento and 8 surrounding counties) to assess how the model applies to large geographical regions that require participation and coordination of multiple agencies. Delaware’s population of 900,000 and the Greater Sacramento’s population of about 4.2 million are many times larger than the populations of Hartford (125,000) and Syracuse (145,000). NHTSA will provide paid media advertisements and an independent evaluation to measure the effectiveness of the program. The State Highway Safety Offices will coordinate the enforcement aspect of the program. The program is scheduled to begin in late fall of 2012 and continue through the summer of 2013. The intent is to create best practices for States that would like to implement the program in a large area of their State or even Statewide. The findings from this proposed information collection would provide a fuller understanding of this process.

2. Statute authorizing the collection of information

The National Traffic and Motor Vehicle Safety Act of 1966, Title 15 United States Code 1395, Section 106 (b), gives the Secretary authorization to conduct research, testing, development, and training as authorized to be carried out by subsections of this title. The Vehicle Safety Act was subsequently re-codified under Title 49 of the U.S. Code in Chapter 301, Motor Vehicle Safety. Section 30168 of Title 49, Chapter 301, gives the Secretary authorization to conduct research, testing, development, and training to carry out this chapter. (See Appendix A)

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.

The purpose of this information collection is to provide critical information needed by NHTSA to demonstrate effective countermeasures that meet the Agency’s mandate to improve highway traffic safety. The collected data will assist NHTSA in its ongoing responsibilities for: (a) reporting the effectiveness of program activities; (b) providing information to NHTSA’s partners involved in improving public safety; and (c) providing sound scientific reports on NHTSA’s activities to other public safety researchers.

NHTSA has awarded a contract to an evaluation firm with extensive experience in conducting intercept surveys and program evaluations. Data from the intercept surveys will be used to evaluate driver awareness of, attitudes towards, and self-reported behaviors in response to NHTSA-sponsored enforcement and media campaigns directed at reducing distracted driving and to assess the overall effectiveness of these programs.

Data from the intercept survey will be collected immediately before and after the demonstration program waves, to compare data in in Delaware and the Greater Sacramento area and in appropriate control areas (Atlantic County, New Jersey and Multnomah County, Oregon). This will permit NHTSA to assess whether the HVE program waves were successful at penetrating public awareness and if they corresponded with any changes in perception of enforcement activity and attitudes regarding distracted driving. In the future the results from these surveys can be compared to findings in States that use alternative enforcement and media models (where applicable).

The results of the analyses described above will be used by NHTSA to assess the effectiveness of the mobilizations and determine where refinements or resource adjustments are needed. Demographic data collected by the survey will pinpoint group differences in response to these and other survey questions. Results of the analyses will be applied to development of strategic initiatives and future programs aimed at reducing traffic injuries and fatalities.

Results from the intercept survey analyses will add value to the larger research and evaluation design. NHTSA will employ a complementary, multi-pronged evaluation approach consisting of intercept surveys (as described in detail in this justification), observational roadside surveys, paid and earned media assessment, and an assessment of enforcement data. Results from each dependent variable will offer a comprehensive assessment of the distracted driving HVE program effectiveness.

Before and after each enforcement wave motorists’ cell phone usage behavior will be observed among free flowing traffic in the highest volume road segments. Fifteen program sites in the program and control areas will be selected; approximately 7,000 observations will be conducted during per round of data collection (i.e., pre and post each wave). Observation protocols will be based on NHTSA’s National Occupant Protection Use Survey (NOPUS) observation protocols, adapted to increase sample size. Data elements from the observational surveys will include vehicle type, sex, estimated age (16-24, 25-59, 60+), whether the driver was holding a hand-held phone to her or his ear, manipulating a cell phone (other than by holding to one’s ear) and if the driver had a hands-free headset (e.g., Bluetooth) in the visible ear.

NHTSA will also examine dedicated law enforcement hours and the number of citations issued per offense, per enforcement wave. Each State will submit baseline enforcement data for a period of time before the first wave of enforcement begins. This will provide a measure of the level of enforcement for each wave.

In addition, NHTSA will analyze the paid and earned media associated with the program. For each wave NHTSA will obtain the dollars spent on media and the strength of the media purchased (using Gross Rating Points-GRPs). Using a news clipping service NHTSA will also assess the earned media provided by news organizations in the program areas.

The intercept surveys are an integral part of this evaluation as they provide information on whether the public and the target audience are aware of the campaign. As such, the intercept surveys provide additional understanding of the program. All dependent measures work together and complement each other to provide an overall evaluation of the program.

The findings from this proposed collection of information will assist NHTSA in addressing the problem of distracted driving and in formulating programs and recommendations. NHTSA will use the findings to help focus current programs and activities to achieve the greatest benefit, to develop new programs to decrease the likelihood of distracted driving, and to provide informational support to States, localities, and law enforcement agencies that will aid them in their efforts to reduce distracted driving-related crashes.

Besides developing its own program and technical assistance activities, NHTSA will:

• Disseminate the information to State and local highway safety authorities, who will use it to develop, improve and target their own distracted driving enforcement programs and activities.

• Disseminate the information to citizen action groups and other organizations concerned with traffic safety issues, who will use it to develop, improve and target their own programs and activities.

• Make reports available to the public on the Department of Transportation’s distraction website (www.distraction.gov), on NHTSA’s driving safely website (www.nhtsa.dot.gov), and in NHTSA’s behavioral research electronic library (http://ntlsearch.bts.gov/repository/ntlc/nhtsa/index.shtm). The Secretary of Transportation often issues press releases to accompany distracted driving reports.

The data collected under this project will help determine the effectiveness of distracted driving demonstration programs conducted on a large scale. They will determine appropriate emphasis for future countermeasure activity. The results will be disseminated to others for research and program development activities. If the surveys were not conducted, NHTSA program efforts would lack direction due to inadequate information upon which to base program decisions, severely limiting the Agency’s effectiveness in reducing injuries and fatalities.

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 information technology. Also describe any consideration of using information technology to reduce burden.

This collection of information does not involve the use of technological collection techniques. NHTSA believes that simple pen and paper forms for data collectors are cost effective (because of not having to purchase the equipment to collect the data electronically), and provide a less formal and more comfortable environment for the participants. While the interviewers will not use electronic devices such as Personal Data Assistants, they will enter the collected data into an electronic database and NHTSA will receive 100 percent of the results of the data collection in electronic files.

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 proposed collection will build upon a distracted driving program that NHTSA conducted in 2010 and 2011 in Hartford, Connecticut and Syracuse, New York. The Hartford and Syracuse programs were similar in that they used high-visibility enforcement and the media campaign, Phone in One Hand, Ticket in the Other. NHTSA’s evaluation of the programs demonstrated that the HVE model could effectively reduce distracted driving behavior at the community level in terms of observed reductions in hand-held phone use and electronic device manipulation while driving. The next step is to demonstrate how to implement this program on a larger scale. Delaware and the Greater Sacramento area are much larger than Hartford and Syracuse. By implementing this program in these larger areas, NHTSA will gather information necessary to create best practices for States that would like to apply high-visibility enforcement programs to distracted driving Statewide.

Because no data on this larger program exists until it is collected, no other data source can be substituted. There is no possibility of duplicating information that is currently available.

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

The collection of information involves individuals (drivers) at DMV offices or gas stations, not small businesses. Potential survey sites (DMVs and gas stations) will be contacted in advance to secure permission to conduct the survey on their premises. The gas stations will be fully informed about the nature of the survey operations and the time required for the data collection activities. Small business is not the target of the survey.

6. Describe the consequences to Federal Program or policy activities if the collection is not collected or collected less frequently.

As the national leader in traffic safety research, Congress has tasked NHTSA with providing evidence-based guidance to the States and stakeholders. Without evaluation efforts to measure how traffic safety programs work, it will be impossible to develop effective intervention strategies and adequately interpret the value of these programmatic efforts.

In evaluating demonstration project activities, the collection of information occurs at two points: before implementation of a HVE mobilization wave and after the conclusion of the mobilization. Researchers conduct the collections as an independent cross-section of the target communities. Each respondent participates in only one administration. The baseline and post-mobilization surveys are necessary to determine whether observed changes in driver attitudes and behaviors can be attributed to the program activities (as opposed to extraneous events or random chance). Without the administration of the pre- and post- surveys it would be impossible to provide evidence-based recommendations for future State and national interventions.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines set forth in 5 CFR 1320.6.

No special circumstances require the collection to be conducted in a manner inconsistent with the guidelines in 5CFR 1320.6.

8. Provide a copy of the Federal Register document soliciting comments on the collection of information, a summary of all public comments responding to the notice, and a description of the agency’s actions in response to the comments. Describe efforts to consult with persons outside the agency to obtain their views.

   1. Federal Register Notice

NHTSA published a notice in the Federal Register with a 60-day public comment period to announce this proposed information collection on June 13, 2012, Volume 77, Number 114, pages 35473-35475 (See Appendix B-1). There were no comments on the Notice.

NHTSA published a notice in the Federal Register with a 30-day public comment period to announce forwarding of the information collection request to OMB for approval on November 30, 2012, Volume 77, Number 231, pages 71477-71478. (See Appendix B-2)

2. Responses to the Federal Register Notice

No comments were submitted to Docket Number NHTSA-2012-0066 in response to the 60 Day Federal Register Notice.

3. Expert Consultation

NHTSA staff adapted the survey instrument from the Distracted Driving Intercept Survey (DDIS) used to evaluate the 2010 and 2011 Hartford, Connecticut and Syracuse, New York distracted driving programs. The DDIS, in turn, was designed using key characteristics of NHTSA’s 2009 Click It or Ticket survey, the 2002 National Survey of Distracted and Drowsy Driving Attitudes and Behaviors, and the 2007 Motor Vehicle Occupant Safety Survey (MVOSS). Prior to the survey development work, NHTSA’s program, research, communications, and regional offices provided significant input on the topics and questions.

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

No payment or gifts will be offered to participants in the proposed survey. In addition, there are no direct out-of-pocket expenses associated with participation.

10. Describe any assurance of confidentiality provided to respondents.

In the survey introduction, interviewers inform respondents that participation is voluntary and that their answers are anonymous. These surveys do not collect identifying information such as names, addresses, telephone numbers, or social security numbers. Upon completion of these surveys, it would be impossible to identify anyone based on his or her responses to the questions.

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.

The survey does not contain any questions of a sensitive nature or related to matters that are commonly considered private.

12. Provide estimates of the hour burden of the collection of information on the respondents.

The distracted driving intercept survey (DDIS) will require 1850 participants per administration, with researchers sampling 1100 participants from the intervention site and 750 from the control site. NHTSA plans to conduct pre- and post-mobilization administrations for each of its two demonstration projects (i.e., states) and anticipates three mobilization waves per state.

DDIS	Interviews	Pre & Post	Minutes	Waves	States	Hours
	1850	x 2	x 5	x 3	x 2	= 1,850

In sum, NHTSA proposes to interview up to 22,200 participants over three enforcement waves (11,100 participants per State) and estimates a burden of 1,850 total hours over a period of one year.

The total number of estimated reporting burden hours a year on the general public would be 1,850 for the proposed survey. At $21.74⁶ per hour, the total annual estimated cost associated with the burden hours is: $21.74 x 3,700 hours for a total of $40,219 (if all respondents are interviewed)... Respondents would not incur any other reporting cost from the information collection.

13. Provide an estimate of the total annual cost to the respondents or record keepers resulting from the collection of information.

There are no record keeping or reporting costs to respondents. Respondents will be contacted randomly, and asked for their attitudes, knowledge, and behavior regarding specific traffic safety topics pertaining to cell phone use while driving. Each respondent only participates once in the data collection. Thus there is no preparation of data required or expected of respondents. Respondents do not incur: (a) capital and start up costs, or (b) operation, maintenance, and purchase costs as a result of participating in the survey.

14. Provide estimates of the annualized cost to the Federal Government.

Based on the Distracted Driving Intercept Survey administered in Hartford, Connecticut and Syracuse, New York in 2010 and 2011, the estimated cost of data collection per participant is $8.00. This includes the costs of collecting the data, as well as travel to the sites, data entry and data analysis. Total costs for the intercept surveys are $177,600 (22,200 completed surveys x $8.00 per survey).

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

This is a renewal of OMB Control Number 2127-0665. In this ICR we are requesting clearance for the Distracted Driving Intercept Survey (not the telephone survey), as it applies to the two State demonstration programs. There are no program changes or adjustments to Item 13. There are adjustments to Item 14 for two reasons:

• The sample of respondents is larger (22,200 vs. 6,400);

• We have experience from the Hartford and Syracuse community demonstration programs and estimate the cost of a completed survey at $8.00 per survey (vs. $6.00).

Given these adjustments the total cost of the intercept surveys is estimated at $177,600, a change from the previous request for clearance.

16. For collection of information whose results will be published, outline plans for tabulation and publication.

NHTSA expects to receive a letter report at the conclusion of each wave, and a final report in December 2013. The final report will cover all three data collection periods and will be published upon receipt and completion of agency review, likely in April, 2014.

Below is a schematic for the entire data collection. The periodic interventions are scheduled to provide repeated and consistent exposure to high-visibility enforcement. Data collection occurs immediately before and after each intervention. .

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

NHTSA will display the expiration date for OMB approval

.

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

No exceptions to the certification are made.

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

No exceptions to the certification are made.

1 U.S. Department of Transportation, National Highway Traffic Safety Administration. (2010, April). Overview of the national highway traffic safety administration’s driver distraction plan. (DOT Publication No. DOT HS 811 299). Retrieved from http://images.thetruthaboutcars.com/2011/06/NHTSAdistracteddrivingplan.pdf

2 Nielsen Wire, Smartphones Account for Half of all Mobile Phones, Dominate New Phone Purchases in the US, 2012, Retrieved from http://blog.nielsen.com/nielsenwire/online_mobile/smartphones-account-for-half-of-all-mobile-phones-dominate-new-phone-purchases-in-the-us

3 CTIA, the Wireless Association. (2012), CTIA-The Wireless Association Semi-Annual Survey Shows Significant Demand by Americans for Wireless Broadband. Retrieved from http://www.ctia.org/media/press/body.cfm/prid/2171

4 Governor’s Highway Safety Association. (2012), Cell Phones and Texting Laws, August 2012 Retrieved from http://www.ghsa.org/html/stateinfo/laws/cellphone_laws.html

5 Cosgrove, L., Chaudhary, N., Reagan, I. Four High-Visibility Enforcement Demonstration Waves in Connecticut and New York Reduce Hand-Held Phone Use (2011), National Highway Traffic Safety Administration. Retrieved from http://ntl.bts.gov/lib/45000/45700/45729/811845.pdf

6 US Department of Labor, Bureau of Labor Statistics (2012). May 2011 National Occupational Employment and Wage Estimates. http://www.bls.gov/oes/current/oes_nat.htm

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