0568 SS Part A 011017

SUPPORTING STATEMENT

OMB CONTROL NO: 0648-0568

National Oceanic and Atmospheric Administration: (1) Office of Education, Educational Partnership Program (EPP), (2) Ernest F. Hollings Undergraduate Scholarship Program; (3) Dr. Nancy Foster Scholarship Program; and, (4) National Marine Fisheries Service Recruitment, Training, and Research Program

A. JUSTIFICATION

This request is for revision and extension of a current information collection.

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

The Administrator of the National Oceanic and Atmospheric Administration (NOAA) is authorized by section 4002 of the America COMPETES Act, Pub. Law 110-69, to establish and administer a Graduate Sciences Program and two undergraduate scholarship programs to enhance understanding of ocean, coastal, Great Lakes, and atmospheric science and stewardship by the general public and other coastal stakeholders, including underrepresented groups in ocean and atmospheric science and policy careers. In addition, NOAA’s Administrator is authorized by section 214 of the Consolidated Appropriations Act, 2005, Pub. Law 108-447, to establish and administer the Ernest F. Hollings Undergraduate Scholarship Program to support undergraduate studies in oceanic and atmospheric science, research, technology, and education that support NOAA’s mission and programs.

The Dr. Nancy Foster Scholarship Program is authorized at 16 U.S.C. 1445c-1 and 16 U.S.C. 1445c to recognize outstanding achievement in oceanography, marine biology or maritime archaeology (including all science, engineering, and resource management of ocean and coastal areas) particularly by women and members of minority groups. For more information about the Dr. Nancy Foster Scholarship Program, go to http://fosterscholars.noaa.gov/.

The 2007 reauthorization of the Magnuson-Stevens Act directed that a study be conducted to determine if a shortage exists in the number of individuals with post-baccalaureate degrees who have the ability to conduct high quality scientific research in fishery stock assessment, fishery population dynamics, and related fields for government, non-profit, and private sector entities (P.L. 109-479, sec. 217). In response to the shortage identified by the report, the Southeast Fisheries Science Center (SEFSC) of NOAA’s National Marine Fisheries Service (NMFS) created the Recruiting, Training, and Research (RTR) Program to increase the quality and quantity of stock assessment scientists entering the discipline.

NOAA’s Office of Education (OEd) administers scholarship programs and one grant program – the Educational Partnership Program (EPP) with Minority Serving Institutions (MSI) Cooperative Science Centers (CSC). The OEd maintains a Student and Performance Measures Tracking System (SPMTS) with student data from all the programs it administers. NOAA OEd staff enters data for the scholarship programs. The EPP CSCs enter and update the SPMTS for their students. Information submitted by program alumni via the Voluntary Alumni Update System (the previously approved alumni form) is automatically captured within the SPTMS.

Student applicant information, including information provided by references, will be collected for the Educational Partnership Program with Minority Serving Institutions Undergraduate Scholarship Program and the Ernest F. Hollings Undergraduate Scholarship Program. During their summer internships, Hollings and EPP scholars complete, during their summer internships of eight weeks, a biweekly online training record to track accomplishments (max 2000 characters per week) and hours worked.

In addition, OEd has included the alumni form in this collection, recently revised with OMB approval, but now including two additional sets of alumni, as described below. OEd believes this information is necessary because NOAA desires to know whether the NOAA funded students pursue and complete NOAA-related science degrees, whether the students are employed by NOAA, NOAA contractor or otherwise in NOAA-related fields, or are involved in other programs due to their NOAA-funded education and training.

NOAA OEd collects information on post-graduation activities to assess the following: 1) whether students pursue and complete advanced degrees in NOAA-related sciences, 2) whether students gain employment with NOAA, NOAA contractors or other employers which address NOAA’s mission, 3) receive fellowships or awards as a result of their NOAA-funded education and training, and, 4) publish scholarly works in peer-reviewed journals.

The Dr. Nancy Foster Scholarship Program (OMB Control No. 0648-0432) and the Recruiting, Training, and Research Program also collect alumni data. As the RTR workshops are run by its host universities (Virginia Tech 2004-2011, University of Florida 2012-Present), previous evaluations have been conducted using university-approved (IRB-approved) evaluation forms. The Voluntary Alumni Update System (VAUS) is used by the following four programs to track former students over time, specifically related to NOAA objectives.

1. Office of Education, Educational Partnership Program with Minority Serving Institutions;

2. Ernest F. Hollings Undergraduate Scholarship Program;

3. Dr. Nancy Foster Scholarship Program; and,

4. National Marine Fisheries Service Recruitment, Training and Research Program.

2. Explain how, by whom, frequently, and for what purpose the information will be used. If the information collected will be disseminated to the public or used to support information that will be disseminated to the public, then explain how the collection complies with all applicable Information Quality Guidelines.

Education Programs and Their Purposes

NOAA recognizes outstanding scholarship and encourages independent graduate level research – particularly by female and underrepresented students – in ocean and atmospheric science and policy careers.

The purpose of the OEd Educational Partnership Program (EPP) with Minority Serving Institutions is to educate, train and graduate students in NOAA-mission sciences. OEd EPP is strongly committed to broadening the participation of Minority Serving Institutions (MSIs) such as Historically Black Colleges and Universities, Hispanic Serving Institutions, Indian Tribally Controlled Colleges and Universities, Alaska Native-Serving Institutions, and Native Hawaiian-Serving Institutions. NOAA’s OEd EPP/MSI partnership is comprised of four program components:

• The Undergraduate Scholarship Program (USP) provides an opportunity for rising junior and senior students to study disciplines relating to the NOAA's mission. Students attending MSIs (Hispanic Serving Institutions, Historically Black Colleges and Universities, Tribal Colleges and Universities, Alaskan-Native Serving Institutions, and Native Hawaiian Serving Institutions) conduct internships at approved NOAA offices and sites upon acceptance to the program.

• The Graduate Sciences Program (GSP) is aimed primarily at increasing opportunities for students in NOAA-related fields to pursue research and educational training in atmospheric, environmental, remote sensing and oceanic sciences at MSI when possible. The GSP offers between two years (master's candidates) to four years (doctoral students) of NOAA-related research and training opportunities. (CLOSED to new students)

• The Environmental Entrepreneurship Program’s (EEP) provides funding to eligible MSIs on a competitive basis to provide students with training in the application of NOAA sciences in order to foster economic development opportunities. EEP facilitates partnerships among MSIs; various NOAA offices; academic research, government and business organizations that can help prepare students with appropriate knowledge and skills to exploit environmental tools and technological resources. (CLOSED to new students)

• The Cooperative Science Centers’ (CSCs) objectives are to educate and graduate students in NOAA-related sciences, to conduct research in support of NOAA’s mission, and to build capacity within the collaborating institutions. EPP established five Cooperative Science Centers at MSIs to advance collaborative research in the NOAA-related (pertains to NOAA’s mission) sciences. The first four Cooperative Science Centers were established in 2001 and the fifth Center in 2006. The 2011 and 2016 grant awards resulted in four Cooperative Science Centers (the previous ones existed only through their grant durations). The Center Director, Deputy Director and Distinguished Scientist at each Center develop and lead key education and research activities.

For more information about the Educational Partnership Program, visit: http://www.noaa.gov/office-education.

The purpose of the Ernest F. Hollings Undergraduate Scholarship Program is to:

1. Increase undergraduate training in oceanic and atmospheric science, research, technology, and education and foster multidisciplinary training opportunities;

2. Increase public understanding and support for stewardship of the ocean and atmosphere and improve environmental literacy;

3. Recruit and prepare students for public service careers with NOAA and other natural resource and science agencies at the federal, state and local levels of government; and,

4. Recruit and prepare students for careers as teachers and educators in oceanic and atmospheric science and to improve scientific and environmental education in the United States.

For more information about the Ernest F. Hollings Undergraduate Scholarship Program, visit: http://www.noaa.gov/office-education/hollings-scholarship

The purpose of the Dr. Nancy Foster Scholarship Program is to support independent graduate level research through financial support of graduate studies in the fields of oceanography, marine biology or maritime archaeology (including all science, engineering, and resource management of ocean and coastal areas). The program seeks to increase the number of women and minorities in these scientific disciplines, particularly as they relate to the mission of the Office of National Marine Sanctuaries (ONMS).

The purpose of the NOAA’s National Marine Fisheries Service (NMFS) Recruiting, Training, and Research (RTR) Program is to: 1) recruit top quantitative undergraduate students from across the country, 2) station a NMFS stock assessment scientist at a university with a well-respected fisheries program in the southeastern U.S. to perform many of the critical tasks of a faculty member, including teaching graduate courses and supervising graduate students in the discipline, and 3) support additional graduate students in the discipline.

OEd Student Tracker Database

The OEd Student Tracker Database maintains data for all students receiving funding under the following programs:

• EPP/MSI Undergraduate Scholarship Program;

• EPP/MSI Graduate Sciences Program;

• EPP/MSI Environmental Entrepreneurship Program;

• EPP/MSI Cooperative Science Centers; and,

• Ernest F. Hollings Undergraduate Scholarship Program.

The collection of student data is a program requirement that enables OEd to assess compliance with its performance measures, described below. NOAA’s OEd staff maintains this database and updates it and thus no public burden is incurred for this portion of the input to the database. Information on CSC students is entered by CSC program coordinators or principal investigators, as required by a special award condition.

OEd requires that NOAA-funded Cooperative Science Center student data be provided annually, though updates may be made at any time. Regular updates on the post-education activities of alumni is strongly encouraged. Updates made by alumni to the Voluntary Alumni Update System (VAUS), previously referred to as the alumni form, are captured automatically by SPTMS.

The VAUS is used to collect post-graduation information about the student. NOAA needs to determine whether NOAA-funded students pursue and complete post-graduate NOAA-related science degrees, are employed by NOAA or a NOAA contractor, or in fields related to NOAA’s mission.

The collected student data is also tabulated to provide the status on progress of all OEd programs’ performance measures.

Student Scholarship Training Record

During their summer internships, Hollings and EPP undergraduate scholars are required to complete a biweekly Training Record (SSTR) which logs their hours, activities and accomplishments.

Performance Measures

Graduate Sciences Program (closed to new students)

• Number of graduate sciences program students hired in NOAA Line Offices.

Undergraduate Scholarship Program

• Number of undergraduate scholarship students attending MSIs who are trained and graduate in NOAA-related sciences;

• Number of undergraduate scholarship students attending MSIs who pursue graduate work in NOAA-related sciences; and,

• Number of undergraduate scholarship students attending MSIs who are hired by NOAA, NOAA Contractors and other natural resources and science agencies at the Federal, State, local and tribal levels.

Ernest Hollings Scholarship Program

• Number of Hollings scholarship students who are trained in NOAA-related sciences, research technology, and education;

• Number of Hollings scholarship students who are hired by NOAA and other natural resource and science agencies at the Federal, State, and local levels;

• The number of students from the Hollings Program who teach and become educators in NOAA-related sciences; and,

• The number of Hollings students who pursue graduate work in NOAA-related sciences.

Environmental Entrepreneurship Program (Closed to new students)

• Number of students who receive training and experiential learning opportunities in NOAA-related environmental business enterprises.

Cooperative Science Centers

• Number of students from underrepresented communities who are trained and graduate in

NOAA mission sciences annually;

• Number of students who are trained and graduate in NOAA mission sciences annually;

• Number of students completing experiential opportunities at NOAA facilities;

• Number of EPP-funded students who are hired by NOAA, NOAA contractors and other environmental, natural resource, and science agencies at the Federal, State, local and tribal levels, in academia and the private sector;

• Number of collaborative research projects undertaken between NOAA and MSI partners in support of NOAA operations;

• Number of students and faculty who participate in and complete postdoctoral level research programs in support of the NOAA mission;

• Number of peer reviewed papers published in NOAA mission sciences by scientists (faculty, postdoctoral fellows, and students) sponsored by NOAA EPP;

• Funds leveraged with NOAA EPP funds (including student support) ; and,

• Number of outreach participants engaged in NOAA mission relevant learning opportunities.

For the CSCs, the allocated funds are tracked. For the award period beginning in 2016, fifty (50) percent of CSC funding, including the lead and all partner institutions, is mandated for direct student support. For prior award periods, the minimum amount required for direct student support was thirty percent of the award. Direct Student Support means CSC funds directly paid for support of CSC-support eligible post-secondary students in the following budget subcategories: 1) tuition; undergraduate student scholarship; graduate student fellowship; 2) travel (to participate in experiential research at NOAA facilities or other CSCs or NOAA programs, present at scientific conferences/meetings, training, professional development); 3) salaries and fringe benefits; stipend (for laboratory/computer/equipment fees, books, transportation and lodging support when conducting CSC/NOAA research activities) and 4); registration (for conferences, workshops or Forum).

To measure the impact of OEd programs, the data collected are compared to the available data in the national education databases (e.g., National Science Foundation and National Center for Education Statistics) and NOAA workforce management database. Furthermore, the student data collection identifies degree pipeline areas (BS, MS, or PhD) and where OEd and its academic partners may target recruitment for its’ NOAA-related science educational and training programs. NOAA scholarship programs produce a pool of qualified candidates that may be hired by NOAA and help to sustain a world-class NOAA organization.

The collected student data is also tabulated to provide the status on progress of all programs’ performance measures.

Dr. Nancy Foster Scholarship Program Performance Measure

• Number of Postsecondary Students in Higher Education Programs

Performance measures for the RTR Program include the percentage of participants who end up working for NOAA and the percentage of participants who enter National Science Foundation (NSF) Field of Study #055 (Fishing & Fisheries Sciences/Management).

Results of this collection which demonstrate the effectiveness and impact of OEd programs may be submitted for publication in peer-reviewed or grey literature. In this event, data would be reported in anonymous and aggregate form according to occupation fields commonly used by other Federal agencies such as National Science Foundation, Department of Education and Census Bureau.

It is anticipated that the information collected will be disseminated to the public or used to support publicly disseminated information. NOAA Office of Education will retain control over the information and safeguard it from improper access, modification, and destruction, consistent with NOAA standards for confidentiality, privacy, and electronic information. See response to Question 10 of this Supporting Statement for more information on confidentiality and privacy. The information collection is designed to yield data that meet all applicable information quality guidelines. Prior to dissemination, the information will be subjected to quality control measures and a pre-dissemination review pursuant to Section 515 of Public Law 106-554.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological techniques or other forms of information technology.

The collection of information will primarily entail web-based forms with electronic fillable forms (e.g., PDF forms) as a back-up. Applicants, alumni and grant recipients will complete the web-based forms that will automatically be transferred to a database. In the event that the web-based method is not functional, the applicants and grant recipients may complete fillable forms that may be sent electronically or mailed.

4. Describe the efforts to identify duplication.

Cooperative Science Center student data and information are unique to the program component in that they are not collected by any other entity. The NOAA scholarship applications are unique in that the applications require responses to NOAA-related questions. The common alumni form (VAUS) is used by the following programs: (1) Office of Education Educational Partnership Program with Minority Serving Institutions; (2) Ernest F. Hollings Undergraduate Scholarship Program. The Dr. Nancy Foster Scholarship Program; and Recruiting, Training, and Research (RTR) Program will disseminate the alumni form via Google Forms or Survey Monkey.

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

Not applicable.

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

If the collection is not conducted, the data will not be available to support program performance assessments and NOAA program reports.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

Not applicable.

8. Provide a copy of the PRA Federal Register notice that solicited public comments on the information collection prior to this submission. Summarize the public comments received in response to that notice and describe the actions taken by the agency in response to those comments. Describe the 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.

A Federal Register notice was published on Wednesday, October 5, 2016 (81FR 69045). No public comments were received on the proposed information collection.

Comments solicited through other venues:

Student and Performance Measures Tracking System (SPMTS)

In anticipation of a redesign of the SPMTS user interface, comments were solicited from the primary non-NOAA users of the SPMTS, the four Cooperative Science Center program coordinators in December 2015 regarding the function of the system and recommendations for improvement. This feedback is being used to streamline the system for efficiency and utility. The new student tracking system is targeted for initial launch and testing in Spring 2017, at which time a revised data collection request will be submitted. Below are some comments on the current SPMTS:

As a user, I found the system easy to access but cumbersome to input given the various categories and different reporting times. Inputting new students was not difficult; however, updating a student's file appeared to be confusing. For example, is there a field that indicates the last update? 

Response: Yes we do maintain a separate database for all supported students. Yes, a more robust query/data access functions would eliminate duplication and omission of data.

One aspect of the SPMTS that makes using it difficult for reporting and data analysis is that when we download a report from the system, different types of information about an individual student are reported separately.

Post-Education – this screen is worthless without a date for when the entry was made. Going back 10 years and trying to decide what the sequence of someone’s career path has been, is impossible. There should be a field that automatically enters that day’s date for when the entry is made. This is also true of all the “experience”, etc. screens.

The redesign of the system will address these comments by streamlining the data entry and update processes, eliminating redundant fields, and establishing a date/user stamp to denote when and by whom each entry/update was made. In addition, the system will allow queries of student records by any/all student attributes, greatly enhancing the utility of the system. The most significant change will be to post-graduate records, which will allow a student’s entire career trajectory to be captured.

Cooperative Science Center Student Data

In December 2016, the four Cooperative Science Centers were asked to provide the time it takes to submit data entries to the SPMTS. NOAA’s Office of Education received feedback from the four Cooperative Science Centers and the average time to enter the data was twenty eight (28) hours. NOAA’s Office of Education has revised our response time estimate accordingly.

9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

Not applicable.

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

As needed, student information may be disclosed to the National Oceanic and Atmospheric Administration Office of Civil Rights and the Workforce Management Office to assist the Office of Education in completing and maintaining the student tracker records. The justification for sharing information on a need to know basis within the agency is provided explicitly within the statutory language of the Privacy Act.  See 5 U.S.C. 552a(b)(1).

As needed, student information may be disclosed to entities outside of NOAA for purposes related to program management under the routine uses described in System of Records Notice NOAA-14, published September 17, 2015 (text below). For example, OEd has enlisted the National Student Clearinghouse to search student records to verify degree completion and enrollment in advanced degree programs. Student data are transmitted using secure means (e.g. Accellion) in compliance with NOAA and DOC privacy policies.

8. A record in this system may be transferred to the Office of Personnel Management or to the National Science Foundation, National Center for Science and Engineering Statistics (NCSES) or to an evaluation contractor for personnel research purposes, as a data source for management information; for the production of summary descriptive statistics and analytical studies in support of the function for which the records are collected and maintained; or for related manpower studies.

The physical electronic OEd files are protected from access outside of NOAA and outside of Office of Education by a system of firewalls and routers.  Whenever feasible, applications are hosted within the internally protected network to limit access by NOAA personnel only. Restricted access is employed so that only authorized users within the NOAA Office of Education scholarship team have access to the scholarship files.

The OEd student scholarship programs’ paper application is destroyed after the evaluation and selection of NOAA student scholars.  The student name, street address, telephone number and email address are maintained electronically in a secured location on the NOAA server, as is the student tracker database. Access to the electronic files on the OEd shared drive requires username/password combinations to retrieve the information.  

 

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.

Not applicable.

12. Provide an estimate in hours of the burden of the collection of information.

The student and performance measures tracking system web-form is required annually from four (4) NOAA Educational Partnership Program Cooperative Science Center grant recipients though additional updates may be made at any time. The completion of the student tracker database form by each program coordinator, containing information on all students within his/her grant program, is expected to take a maximum of 28 hours to enter data for an average of 200 students and performance measures. In other words, each time a program coordinator completes the student and performance measures report, the report includes updated information on approximately 200 students and 16 performance measures. A report is considered one response (including information on 200 students and 16 performance measures). There are 4 program coordinators; thus, the total reports/responses are 4. Each report takes 28 hours; thus, 4 x 28 hours makes a total burden for this information collection, annually, of 112 hours, a 60% reduction in total burden from the previous collection.

Based on the previous three-years of applications, OEd expects to receive an average of approximately 550 undergraduate scholarship programs (USP and Hollings) applications. Subject to the appropriated funds, approximately 10 and 150 students are selected annually for the USP and Hollings scholarship program, respectively. Completion of the undergraduate scholarship programs application is estimated to take 12 hours. Based on 550 applications, OEd calculates 1100 reference forms (two references per application). Completion of the undergraduate scholarship programs reference form is estimated to take 1 hour. Burden: 6,600 hours for applications and 1100 hours for references.

Completion of the biweekly Student Scholarship Training Record is expected to take approximately 30 minutes and would be submitted 4 times by each scholar during the 8 week summer internship period.

It is estimated that 100 Alumni Update Forms will be received from four programs through the VAUS. A total of 162 forms were completed during the previous two years for an average of 81 forms annually. Completion of the alumni form is estimated to take 5-6 minutes (0.1 hrs), for a total of 1 hour. The alumni form will be used by the following four NOAA programs:

1. Office of Education, Educational Partnership Program;

2. Ernest F. Hollings Undergraduate Scholarship Program;

3. Dr. Nancy Foster Scholarship Program; and,

4. National Marine Fisheries Service Recruitment, Training and Research Program.

Table 1: Respondent, Burden, Cost Chart

Requirement	# of Respondents	# of Responses per Respondent	Total # of Responses	Response Time (hours)	Total Burden (hours)	Labor Rate per hour ($)	Labor Cost to Public per Burden Hour
Student and Performance Measures Tracking System Form	4	1	4	28	112	35	3,920
Undergraduate Scholarship Program Application	550	1	550	12	6,600	8	52,800
Undergraduate Scholarship Program Reference Form	1,100	1	1,100	1	1,100	40	44,000
Student Scholarship Training Record Form	135	4	540	0.5	270	15	4,050
Alumni Update Form for Student Scholarship Programs	100	1	100	0.1	10	30	300
TOTAL REQUESTED	1,889		2,294		8,092		105,070

13. Provide an estimate of the total annual recordkeeping/reporting cost burden to the respondents resulting from the collection (excluding the valued of the burden hours in Question 12 above).

OEd furnishes paper applications to prospective scholars upon request in the event that they cannot access the web-based form. No such requests were received within the last three years. Based on this average, OEd expects to receive at most two mailed scholarship program applications annually. It is estimated that it will cost each applicant a maximum of $25 for photocopying and mailing of the application packages (if Fedex is used), with a total possible cost of $50.

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

Total annualized cost is $35,400. The figure represents salary dollars needed to process the collected data (430 hours @$80.00 per hour = $34,400) and $1,000 printing costs. The 430 hours is based on the following:

• 100 hours to process, verify and validate, the student data from the CSC;

• 55 hours to conduct administrative review on the Hollings and USP student applications and reference forms (5-6 minutes per application)

• 275 hours to review Hollings and USP applications for merit.

15. Explain the reasons for any program changes or adjustments.

Program Changes:

SPMTS Form: Due to a change in the special award conditions for the CSC award beginning in 2016, submission of updates to the SPMTS form by CSCs is now required once, rather than three times, annually.

Hollings/USP - Training Record - The addition of this new form increases number of annual responses by 540 and hours by 270, respectively.

Adjustments: New estimates are based on actual responses received during last 3 annual application cycles.

Hollings/USP – Application Form: Decrease of 250 responses from 800 to 550, however, due to recent estimates of time to complete the application, the number of hours increased from 6,400 to 6,600

Hollings/USP – Reference Form: Decrease of 500 responses, from 1,600 to 1,100 and same decrease for hours

Alumni Form: Decrease of 1,077 responses, from 1,177 to 100. Estimate of time to complete is reduced to 10 hours.

Total mailing costs are now estimated at $50.

16. For collections whose results will be published, outline the plans for tabulation and publication.

The EPP and Hollings Undergraduate Scholarship Program student data (student name, research project and photographs) are posted on NOAA’s Office of Education web site, included in EPP newsletter articles, and submitted for press releases. The number of NOAA OEd supported students (by NOAA-scientific or technological discipline and program component) is included in Government program reports, used for program evaluation and analysis, and used for outreach and promotional purposes.

OEd may also wish to submit for publication in peer-reviewed or grey literature, articles which report the impact of NOAA education programs on national statistics on STEM education. In this event, data would be reported in anonymous and aggregate form according to occupation fields commonly used by other Federal agencies such as National Science Foundation, Department of Education and Census Bureau. For example, OEd may report total numbers of students graduated by NOAA mission field and, where applicable, by ethnicity in order to demonstrate impact on diversity in these fields.

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

Not applicable.

18. Explain each exception the certification statement.

Not applicable.

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