Supporting Statement A - 2013 SOPD updated_NPPD PRIV 01062014_snell clean

Supporting Statement for Paperwork Reduction Act Submissions

Title: Sector Outreach and Programs Division Online Meeting Registration Tool

OMB Control Number: 1670-0019

Supporting Statement A

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.

On behalf of the Department of Homeland Security (DHS), the National Protection and Programs Directorate’s (NPPD) Office of Infrastructure Protection (IP) manages the Department’s program to protect the Nation’s 16 critical infrastructure (critical infrastructure) sectors by implementing the National Infrastructure Protection Plan (NIPP) 2013, Partnering for Critical Infrastructure Security and Resilience. Pursuant to Presidential Policy Directive 21 on Critical Infrastructure Security and Resilience (February 2013), each sector is assigned a Sector-Specific Agency (SSA) to oversee Federal interaction with the array of sector security partners, both public and private. An SSA is responsible for leading a unified public-private sector effort to develop, coordinate, and implement a comprehensive physical, human, and cyber security strategy for its assigned sector. NPPD/IP’s Sector Outreach and Programs Division (SOPD) executes the SSA responsibilities for the six critical infrastructure sectors assigned to IP: Chemical, Commercial Facilities, Critical Manufacturing, Dams, Emergency Services, and Nuclear Reactors, Materials and Waste (Nuclear).

The mission of SOPD is to enhance the resiliency of the Nation by leading the unified public-private sector effort to ensure its assigned critical infrastructure are prepared, more secure, and safer from terrorist attacks, natural disasters, and other incidents. To achieve this mission, SOPD leverages the resources and knowledge of its critical infrastructure sectors to develop and apply security initiatives that result in significant, measurable benefits to the Nation.

Each SOPD branch builds sustainable partnerships with its public and private sector stakeholders to enable more effective sector coordination, information sharing, and program development and implementation. These partnerships are sustained through the Sector Partnership Model, described in the 2013 NIPP pages 10-12.

Information sharing is a key component of the NIPP Partnership Model, and DHS sponsored conferences are one mechanism for information sharing. To facilitate conference planning and organization, SOPD plans to establish an event registration tool for use by all of its branches. The information collection is voluntary and will be used by the SSAs within SOPD. The six SSAs within SOPD will use this information to register public and private sector stakeholders for meetings hosted by the SSA. The SOPD will use the information collected to reserve space at a meeting for the registrant; contact the registrant with a reminder about the event; develop meeting materials for attendees; determine topics of most interest; and efficiently generate attendee and speaker nametags. Additionally, it will allow SOPD to have a better understanding of the organizations participating in the critical infrastructure protection partnership events. By understanding who is participating, the SSA can identify portions of a sector that are underrepresented, and the SSA could then target that underrepresented sector elements through outreach and awareness initiatives.

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 collection of information will involve the use of an online meeting registration tool. The tool will allow the individuals registering for the events to go to the registration site and enter their information. The information to be collected in by the SOPD registration tool will include:

1. Attendee Name

2. Attendee Organization

3. Attendee Organization Location (City, State, Country)

4. Attendee Title

5. Attendee Phone Number

6. Attendee Email Address

7. Attendee Event Topic Interests (Risk, Resiliency, Vulnerability, Legislation, Current or Over-the-Horizon Threats or Issues)

8. Attendee Association Affiliations (companies may belong to multiple trade associations)

9. How did you find out about the event?

The information will then be housed in a secure database. Information collected will only be used by SOPD, and contact information will only be used beyond SOPD with the consent of the submitter. By using this information technology, SOPD will not need to manually input the personal information collected from each of the meeting registrants. Additionally, SOPD’s burden will be reduced because the information technology used has the capability to produce reports based on the information collected to better understand the representation of the event’s attendees.

SOPD will use the information collected to reserve space at the meeting for the registrant, contact the registrant with a reminder about the event, develop meeting materials for attendees, target and focus conference agendas, plan for future conferences, and identify underrepresented elements of the sector to engage.

Specific information collected during the registration process assists SOPD in determining who is represented at the conference.  SOPD utilizes this information to improve planning for future Summits and to ensure that the conference content is applicable and beneficial for attendees.

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.

Using the online registration tool will significantly reduce the burden on the registrant and on SOPD, as the collecting agency. The registration process will take the registrant no more than six minutes to complete, with an average of three minutes. It will also not require the registrant to submit the information via fax or via mail, which should simplify the collection process for the registrant. If a person is unable to access the registration site, there are alternative methods for submitting their registration, including emailing the registration to the SSA’s front office or faxing it to the front office. Instructions for this are included in the registration notification flyer and on the dhs.gov website.

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.



Since this information is an expression of registrants’ desire to attend a specific event, it will be different for each event and, as a result, existing information cannot be used or modified.

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.

The collection of information should not impact small businesses or other small entities.

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

By not collecting this information prior to an event, the SSA will not know the number of stakeholders planning to participate in the critical infrastructure protection event. Additionally, the SSA will not know the type of organizations represented at the event. This would prevent the SSA from ensuring the event will be tailored to the needs of the stakeholder

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

(a) Requiring respondents to report information to the agency more often than quarterly.

(b) Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

(c) Requiring respondents to submit more than an original and two copies of any document.

(d) Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years.

(e) 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.

(f) Requiring the use of a statistical data classification that has not been reviewed and approved by OMB.

(g) 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.

(h) 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 special circumstances that would cause the information collected to be conducted in a manner inconsistent with guidelines.

8. Federal Register Notice:

a. Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice 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.

b. 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.

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



	Date of Publication	Volume Number	Number	Page Number	Comments Addressed
60Day Federal Register Notice:	February 10, 2014	79	27	7683	0
30-Day Federal Register Notice	February 10, 2014	79	27	7683	0

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.



The information will be kept private or anonymous to the extent allowable by law. The information collected is general contact information and is covered under the Department of Homeland Security General Contact Lists Privacy Impact Assessment, dated June 15, 2007, and the DHS/ALL-002 - Department of Homeland Security (DHS) Mailing and Other Lists System of Records Notice (SORN), published to the Federal Register on November 25, 2008, 73 FR 71659.

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:



a. 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 desired. 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.

b. 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.

c. 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.

It is estimated that it will take each participant 3 minutes to complete the registration process. For 1,000 respondents annually, the burden is 50 hours.

This collection only pertains to one form/registration screen.

Table A.12: Estimated Annualized Burden Hours and Costs

Type of Respondent	Report Name	Number of Respondents	Number of Responses per Respondent	Average Burden per Response (in hours)	Total Annual Burden (in hours)	Average Hourly Wage Rate	Total Annual Respondent Cost
Federal, state, local, tribal, territorial, and private sector	N/A	1000	1	0.05 (3 minutes)	50	$40.00	$2,000.00
Totals	1000	1000			50	$40.00	$2,000.00

At a rate of $40.00 per hour, the dollar value of the total annual burden hours associated with existing elements of this information collection equals $2,000.00 annually.

13. Provide an estimate 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 estimate should be split into two components: (1) 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. 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 to keep records for the government, or (4) as part of customary and usual business or private practices.

There are no annualized capital or start-up costs for respondents due to this collection.

 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 have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.



Cost Category	Description of Expense	Total Annual Cost
Equipment Cost	Online Registration Tool Annual use fee	$1150.44
Registration Cost	Cost per registrant $7.20 x Number of registrants 1,000 = $7,200	$7200.00
Total		$8350.44

There are no initial capital costs for the data collection. In sum, the estimated total annual operating cost to the United States Government for this collection is $8,350.44 for the use of the CVENT registration tool.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I. Changes in hour burden, i.e., program changes or adjustments made to annual reporting and recordkeeping hour and cost burden. A program change is the result of deliberate Federal government action. All new collections and any subsequent revisions of existing collections (e.g., the addition or deletion of questions) are recorded as program changes. An adjustment is a change that is not the result of a deliberate Federal government action. These changes that result from new estimates or actions not controllable by the Federal government are recorded as adjustments.



There are no changes to this collection. The number of respondents has been reduced which in turn reduced the number of burden hours subsequently reducing the total annual cost for use of the tool.

The name of the collection has changed from Sector-Specific Agency Executive Management Office Meeting Registration to Sector Outreach and Programs Division Online Meeting Registration Tool due to an internal DHS/NPPD/IP reorganization which changed the name for the of the office.

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 reasons that display would be inappropriate.



DHS will display the expiration date for Office of Management and Budget 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.

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

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