CTS Justification

Request for Approval under the “Generic Clearance for the Collection of Routine Customer Feedback” (OMB Control Number: 2010-0042)

TITLE OF INFORMATION COLLECTION:

Community Engagement Survey for the CTS of Asheville, Inc. Superfund Site

PURPOSE: To solicit input from a group of community members who have asked to be kept informed about the CTS of Asheville, Inc. Superfund Site regarding: (1) how they would prefer to receive information about the Site; (2) whether they have found existing sources of information to be useful; and (3) what their primary interests or concerns are regarding the Site. This effort is part of a review of the Community Relations Plan for the Site, as is required by the Section 300.435(c)(1) of the National Contingency Plan, to be accomplished prior to the initiation of the Remedial Design for the cleanup.

DESCRIPTION OF RESPONDENTS: The survey will be sent to everyone on the community mailing list for the CTS of Asheville, Inc. Superfund Site. Everyone on the list has requested to be on the list to receive information and announcements about the Site. The list includes people who live or have lived near the Site, local businesspeople who are following progress at the Site, people generally interested in environmental issues, staff from state and federal environmental agencies, and local, state and federal government officials.

TYPE OF COLLECTION: (Check one)

[ ] Customer Comment Card/Complaint Form [X] Customer Satisfaction Survey

[ ] Usability Testing (e.g., Website or Software) [ ] Small Discussion Group

[ ] Focus Group [ ] Other: ______________________

CERTIFICATION:

I certify the following to be true:

1. The collection is voluntary.

2. The collection is low-burden for respondents and low-cost for the Federal Government.

3. The collection is non-controversial and does not raise issues of concern to other federal agencies.

4. The results are not intended to be disseminated to the public.

5. Information gathered will not be used for the purpose of substantially informing influential policy decisions.

6. The collection is targeted to the solicitation of opinions from respondents who have experience with the program or may have experience with the program in the future.

Name: Angela Miller, Community Involvement Coordinator for the CTS of Asheville, Inc. Superfund Site, EPA Region 4, (404) 562-8561

To assist review, please provide answers to the following question:

Personally Identifiable Information:

1. Is personally identifiable information (PII) collected? [ ] Yes [X] No

2. If Yes, is the information that will be collected included in records that are subject to the Privacy Act of 1974? [ ] Yes [ ] No [X] Not applicable

3. If Applicable, has a System or Records Notice been published? [ ] Yes [ ] No [X] Not applicable

Gifts or Payments:

Is an incentive (e.g., money or reimbursement of expenses, token of appreciation) provided to participants? [ ] Yes [X] No

BURDEN HOURS

Category of Respondent	No. of Respondents	Participation Time	Burden Hours
Individuals or Households	263	10 minutes	43.83 hours
Private Sector Businesses	76	10 minutes	12.67 hours
State and Local Government	49	10 minutes	8.17 hours
Federal Government	53	10 minutes	8.83 hours
Totals	441		73.50 hours

FEDERAL COST: The estimated one-time cost to the Federal government is: $1,544

The survey would be sent to an existing list of interested people, so there would be no costs associated with compiling a new list of contact information. Sending a survey by email carries no printing or postage costs. The only costs to the Federal government will be the staff time spent answering questions about the survey and compiling responses.

Region 4 expects a 10% response rate, or 45 replies, to the survey. Assuming that it will take the Community Involvement Coordinator (CIC) 20 minutes to review and tally each response, she will spend a total of 900 minutes, or 15 hours, completing the task. Region 4 bills the CIC’s time to the Potentially Responsible Parties (PRPs) at the Site at the rate of $59.26 per hour, plus an indirect cost rate of 73.74% (for Fiscal Year 2017). [15 hours x $59.26 = $888.90 + 73.74% = $1,544.38]

However, the true cost to the Federal government is far less considering two important factors:

1. The CIC’s Community Engagement activities at the Site qualify as response costs under the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), which makes the costs associated with those activities recoverable from the PRPs who have agreed to pay such costs at this Site under an enforceable settlement agreement. Thus, the PRPs will reimburse the EPA for the time the CIC spends compiling responses or answering questions about the survey.

2. The information sought by the survey is information that the CTS CIC wants in order to complete a review of the existing Community Relations Plan for the Site, which is required by Section 300.435(c)(1) of the National Contingency Plan. If an email survey is not approved, then the information would need to be collected one-on-one over the phone or in person, or via a public information session, either of which would require significantly more person-hours, plus, perhaps, the costs of travel and lodging. The staff time spent compiling responses would be similar regardless of the method of information collection. On the whole, compared with other available methods of compiling this information, the email survey would save the EPA money.

If you are conducting a focus group, survey, or plan to employ statistical methods, please provide answers to the following questions:

The selection of your targeted respondents

1. Do you have a customer list or something similar that defines the universe of potential respondents and do you have a sampling plan for selecting from this universe? [X] Yes [ ] No

If the answer is yes, please provide a description of both below (or attach the sampling plan)? If the answer is no, please provide a description of how you plan to identify your potential group of respondents and how you will select them?

The community mailing list for the CTS of Asheville, Inc. Superfund Site is a list of people who have asked to receive information about the Site. Each person on the list has provided an email address. The list is used regularly to send emailed notices and newsletters about the Site. The survey would be sent to the entire list.

Administration of the Instrument

1. How will you collect the information? (Check all that apply)

[ ] Web-based or other forms of Social Media

[ ] Telephone

[ ] In-person

[ ] Mail

[X] Other, Explain: By email

2. Will interviewers or facilitators be used? [ ] Yes [X] No

Please make sure that all instruments, instructions, and scripts are submitted with the request.

Instructions for completing Request for Approval under the “Generic Clearance for the Collection of Routine Customer Feedback”

TITLE OF INFORMATION COLLECTION: Provide the name of the collection that is the subject of the request. (e.g. Comment card for soliciting feedback on xxxx)

PURPOSE: Provide a brief description of the purpose of this collection and how it will be used. If this is part of a larger study or effort, please include this in your explanation.

DESCRIPTION OF RESPONDENTS: Provide a brief description of the targeted group or groups for this collection of information. These groups must have experience with the program.

TYPE OF COLLECTION: Check one box. If you are requesting approval of other instruments under the generic, you must complete a form for each instrument.

CERTIFICATION: Please read the certification carefully. If you incorrectly certify, the collection will be returned as improperly submitted or it will be disapproved.

Personally Identifiable Information: Provide answers to the questions.

Gifts or Payments: If you answer yes to the question, please describe the incentive and provide a justification for the amount.

BURDEN HOURS:

Category of Respondents: Identify who you expect the respondents to be in terms of the following categories: (1) Individuals or Households; (2) Private Sector; (3) State, local, or tribal governments; or (4) Federal Government. Only one type of respondent can be selected.

No. of Respondents: Provide an estimate of the Number of respondents.

Participation Time: Provide an estimate of the amount of time required for a respondent to participate (e.g. fill out a survey or participate in a focus group)

Burden: Provide the Annual burden hours: Multiply the Number of responses and the participation time and divide by 60.

FEDERAL COST: Provide an estimate of the annual cost to the Federal government.

If you are conducting a focus group, survey, or plan to employ statistical methods, please provide answers to the following questions:

The selection of your targeted respondents. Please provide a description of how you plan to identify your potential group of respondents and how you will select them. If the answer is yes, to the first question, you may provide the sampling plan in an attachment.

Administration of the Instrument: Identify how the information will be collected. More than one box may be checked. Indicate whether there will be interviewers (e.g. for surveys) or facilitators (e.g., for focus groups) used.

Please make sure that all instruments, instructions, and scripts are submitted with the request.

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