2017 PRA comments received and responses

2017 PRA comments received and responses.xlsx

Sea Grant Program Application Requirements for Grants, for Sea Grant Fellowships, including the Dean John A. Knauss Marine Policy Fellowships, and for Designation as a Sea Grant College or Sea Grant I

2017 PRA comments received and responses

OMB: 0648-0362

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COMMENTS RECEIVED ON OUR INFORMATION COLLECTION REQUEST, AND OUR RESPONSES



















Msg no Date received From How received Comment Response category of comment
1 10/12 Mary Beth Barrow,
NC State University
email to PRAcomments 90-2 has become easier to use and after holding a training for the new FOs, it seems this form has become pretty easy to complete. I do not see a need for two forms but, if that is what is needed within the National Sea Grant Office, then that is fine. I would think we could just use the long form for any proposal submission. We have two versions of the 90-2 form, the short form designed to provide a project summary for a single project, and a long form, contains with it separate 90-2 project summary forms for up to 50 projects. Both have their uses.
The commenter felt that as a staff member of a state Sea Grant program, only the long form was necessary for her use. The other form is useful for single PIs who aren't part of a Sea Grant program, but who are proposing a project for a national Sea Grant competition.
(1) having a long- and a short form of the 90-2.
2 10/27 Mary Beth Barrow,
NC State University
email to info-admin Yes, I mean there should just be the long form and not both the long and short. (in response to a question about what she meant in previous comments about "do not see a need for two forms") (1) having a long- and a short form of the 90-2.
1 10/12 Mary Beth Barrow,
NC State University
email to PRAcomments As far as the 90-4, the main feedback I get from FOs is for an excel format budget template. Most programs have developed their own 90-4 excel spreadsheet (I have attached the examples to this email that I received). If we could have a standard 90-4 form that was in excel format, that would be helpful. There are a few programs that sent me the documents so, I have attached them for your reference. We will examine all 90-4 templates and suggestions for improvement of the form, including providing an Excel version. (2) provide an Excel spreadsheet version of the 90-4.
2 10/27 Mary Beth Barrow,
NC State University
email to info-admin I like the excel 90-4 format. It is different with the years adding on in the form vs a separate sheet. I have been using one that E******** developed in Florida. This had 4 years of tabs and a cumulative additional tab. Seeing all the years on one sheet would be helpful. A vote for an Excel-based 90-4 form that can cover four years of a project and automatically sum up totals. (2) provide an Excel spreadsheet version of the 90-4.
2 10/27 Mary Beth Barrow,
NC State University
email to info-admin Can you break them out into a PDF form so you can upload into Grants.gov or would it be a separate attachment as the 90-2 is? What about the budget justifications? Would they just be separate? Some commercial grant application software could not accept Excel file attachments, so applicants wanted to submit PDFs of the Excel files, which results in data loss. We worked with company, and it now seems possible to attach Excel files. This should not be a problem in the future. (3) can there be a PDF version of the 90-2?
3 10/20 Nancy Balcom,
University of Connecticutt
email to PRAcomments With respect to the 90-4 – please provide an EXCEL worksheet rather than Word or PDF, and have the Years 1,2, 3, etc. worksheets be additive directly to the Cumulative sheet. I think many programs develop their own EXCEL versions – it’d be nice to have a uniform version. We are looking at 90-4 Excel-based templates provided by the network and intend to provide one for general use for applicants who prefer an Excel format. We don't intend to require Excel or any specific format for the 90-4 form at this time. (2) provide an Excel spreadsheet version of the 90-4.
3 10/20 Nancy Balcom,
University of Connecticutt
email to PRAcomments With respect to the 90-2 – the dropdown for research readiness seems fine. Only for projects that have R/? (Some extension projects have an applied research component.) The rules for when the readiness levels must be provided are still being worked out, but it will likely cover both formal Research projects, and research components of Extension projects. When NOAA finalizes their rules, we will create guidance for the applicants. (4) collecting information on readiness levels
3 10/20 Nancy Balcom,
University of Connecticutt
email to PRAcomments I would also agree that any box we do not have to fill in, should be removed from the 90-2 form worksheets. We plan to implement this suggestion to drop unused fields. (5) removing unused fields
4 10/6 Alan Desbonnet,
University of Rhode Island
email to Dorn.Carlson Saw that. Most of the readiness levels are not something, at least at RISG, that we would use very often, especially those below Proof of Concept. Those really seem NASAesque in that they seem to reflect “systems readiness” such as a rocket engine design or like that. Maybe some SG programs fund that kind of research, but I know RISG doesn’t handle much along those lines. NOAA is revisiting its working definitions of Readiness Levels to make sure they are relevant to the kinds of research that NOAA pursues. The commenter is correct that some of the work Sea Grant does is different from what other parts of NOAA do, but the same set of readiness levels should still work. (4) collecting information on readiness levels
4 10/6 Alan Desbonnet,
University of Rhode Island
email to Dorn.Carlson That said, if we are checking off one of the top 3 most all the time, no big deal in my opinion. And if you got to do it, then just do it. It’s not like it’s some huge burden to click a drop down, select an option, then move on. A comment on readiness levels. (4) collecting information on readiness levels
5 10/24 Elissa Schuett
University of Vermont
email to PRAcomments I have spent the afternoon working on 90-4 forms, so I am feeling rather familiar with them. I find them very tedious and prone to human error. By being in either PDF or Word format, I have to either type in (and possibly incur typos) or paste from a spreadsheet each individual value. Using a spreadsheet would better allow incorporating formulas that can reduce the error and make sure everything is adding up correctly. Another call for a spreadsheet-based (e.g., Excel) version of the 90-4 form. We will do this. (2) provide an Excel spreadsheet version of the 90-4.
5 10/24 Elissa Schuett
University of Vermont
email to PRAcomments I haven’t had any problems with the 90-2 forms and like the requirement of cross-checking the math in the table of contents. (no response necessary) (6) address/improve the macros used to fill out the 90-2 form
6 10/24 Peter Rowe,
NJ Sea Grant Consortium
email to PRAcomments Since we do not really have a choice for the ‘research readiness levels’ being included for future NSGCP proposals, our program can handle it and it should work since it is a drop down menu. A comment on readiness levels (4) collecting information on readiness levels
6 10/24 Peter Rowe,
NJ Sea Grant Consortium
email to PRAcomments There are nine categories, some of them very similar, so there could be confusion there. Any chance to reduce the number of options? And it appears that more than one category can be checked, correct? Can better or more explicit definitions be provided? Should the state SG program decide on and enter this information or is the research PI the best to do so? NOAA is working on clarifying and improving the definitions of these readiness levels. When this is done, we will provide new guidance for applicants. (7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms
6 10/24 Peter Rowe,
NJ Sea Grant Consortium
email to PRAcomments Can the 90-2 form be linked to PIER or some other mechanism developed so that ‘partners’ listed in the 90-2 form will automatically be found in PIER when completing partner information there? Currently, If you have to enter new partners in PIER, you must get approval and entry from a request sent to NSGO. Maybe this is already been done. We are looking into whether this is technically possible, and we will see if this can be working into a future update. (6) address/improve the macros used to fill out the 90-2 form
6 10/24 Peter Rowe,
NJ Sea Grant Consortium
email to PRAcomments Make sure the macros in 90-2 form, especially to look ups – affiliation and partners – can seem sticky and not so easy to navigate those tabs. Further, sometimes cutting and pasting in text into the yellow boxes results in the boxes background becoming white. It is not known if this is a problem or not. And when entering partners, for example, if someone enters a partner by typing in yellow box, as opposed to looking up, that cell can turn background white or the ability to enter by look up is compromised. That is a concern especially if file has not been saved recently. Will check the macro workings, and the clarity of the instructions provided. (6) address/improve the macros used to fill out the 90-2 form
6 10/24 Peter Rowe,
NJ Sea Grant Consortium
email to PRAcomments Provide a better definition of ‘multiprogram’ yellow box as well as regional project. We will do this. (7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms
6 10/24 Peter Rowe,
NJ Sea Grant Consortium
email to PRAcomments The suggestion for getting rid of unused cells is a good idea. We plan to implement this suggestion to drop unused fields. (5) removing unused fields
6 10/24 Peter Rowe,
NJ Sea Grant Consortium
email to PRAcomments As per the 90-4 budget forms there are a couple of changes that could be helpful. One is to make it an excel form where data entered could automatically be summed up within a year and across years. This is something we are doing already. It would also be nice to have the ‘amount of effort’ in the personnel section to be divided into two cells – one for federal funds and the other for matching funds. This makes it clearer as to what effort is being put into each bin and reduces need to go to budget justification to figure out. Again, perhaps some guidance or definitions of what can go into each line item. Otherwise form is pretty good. Another request for an Excel version of 90-4, which can provide multiyear totals. (2) provide an Excel spreadsheet version of the 90-4.
7 10/24 Syma Ebbin,
University of Conn
email to PRAcomments Is this the 90-2 that I have my PIs complete? If so, what is critically needed is detailed guidance that I can give PIs regarding how they should complete this form and what they should ignore. It looks to me like the 90-2 short form is aimed at collating multiple projects, so do PIs ignore these unused fields? Also still not sure what to tell PIs about the readiness level. What is this and how is it determined? We agree that detailed guidance is a good idea and will work with programs to provide. A complication is that each program deals with its PIs (Principal Investigators) in a different way, and we will need to provide guidance that works for all. (7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms
7 10/24 Syma Ebbin,
University of Conn
email to PRAcomments Finally, I receive my proposals via email from PIs as 1 compiled pdf file, so ideally this form would also be able to be converted to a word or text file that could be converted to a pdf file and compiled with the project narrative. We will work on a mechanism to accept information in a PDF file format. This will not change what information is collected or what questions are asked. (3) can there be a PDF version of the 90-2?
8 10/24 Carolyn Foley,
Purdue University
email to PRAcomments For the 90-2 forms, I don’t think Illinois-Indiana Sea Grant has a problem dropping the fields as proposed. We plan to implement this suggestion to drop unused fields. (5) removing unused fields
8 10/24 Carolyn Foley,
Purdue University
email to PRAcomments Regarding readiness levels, I think it will be important for NSGO to consider and communicate how Sea Grant will use these readiness levels. For example, it may not be realistic to expect a $50,000-200,000, 2 year project to result in RL8 or RL9 outcomes; I think most of the research projects IISG funds would fall in the RL2-3 range, but we are gathering evidence that in some cases these do provide good stepping stones for subsequent research that might be considered RL6 or higher; for extension personnel, some of their specific projects may be RL9 but if they only submit a single 90-2 and some of their work is more exploratory, this will not be captured in summary statistics; concerns about allowing for flexibility in responding to situations unforeseen when the Omnibus was being prepared (I think this has been expressed by others in terms of how flexible a strategic plan or Omnibus proposal should be). NOAA is revisiting its working definitions of Readiness Levels to make sure they are relevant to the kinds of research that NOAA pursues. The commenter is correct that some of the work Sea Grant does is different from what other parts of NOAA do, but the same set of readiness levels should still work. (7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms
8 10/24 Carolyn Foley,
Purdue University
email to PRAcomments Some feedback on the 90-4 form is that it would be really nice to have an Excel version rather than Word or PDF. Another vote for an Excel 90-4 form (2) provide an Excel spreadsheet version of the 90-4.
9 11/3 Peter Rowe,
NJ Sea Grant Consortium
email to Dorn.Carlson Is it possible to have categories in the 424 part of the application packet and our 90-4 align better or provide definitions?

For example, the 424 has a category “Contractual”. Should our 90-4 also have a contractual line item, perhaps outside of “G. Other Costs”.

424 has a category call “Equipment”. I have always read that as ‘permanent equipment’ from our 90-4; and yet there could be confusion as our 90-4 also has an “Expendable Supplies and Equipment” line.

Adding more confusion, does the 424 line “Supplies” align one to one with the 90-4 “Expendable Supplies and Equipment” line or would supplies under “G. Other Costs” also be rolled up into the 424 line “supplies” or stay in the “Other” line.

I notice on out 90-4 there is a “publication and Documentation Costs” line. I have always placed those costs into the “other” category in the 424.

So, a little better parallel construction, might make transfer easier from one document to the other.
Commenter is referring to the fact that the budget categories on the 90-4 form do not always match up exactly with the budget categories on the standard government SF424 form. This is because our program need program budgets broken down in ways not captured by the SF424 form.

We will revisit to see if the two forms can be better harmonized to minimize confusion among applicants who use both forms, paying special attention to the specific examples provided here.
(7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms
9 11/3 Peter Rowe,
NJ Sea Grant Consortium
email to Dorn.Carlson I see under the omnibus guidance that was provided us, the comparison between the two forms was laid out, so that definitely helps, so my comments may be superfluous.

I still think I could mess things up though.
(a followup comment addressing the concerns of the previous comment about the differences between the 90-4 form and the government standard SF424 form.) (7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms

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cate


(1) having a long- and a short form of the 90-2.


(1) having a long- and a short form of the 90-2.


(2) having an Excel spreadsheet version of the 90-4.
(2) having an Excel spreadsheet version of the 90-4. please make an Excel version of the 90-4 form, with enhancements
(2) having an Excel spreadsheet version of the 90-4.
(3) can there be a PDF version of the 90-2? provide a PDF version of the 90-2 form
(2) having an Excel spreadsheet version of the 90-4.
(4) collecting information on readiness levels collecting information on readiness levels is fine
(2) having an Excel spreadsheet version of the 90-4.
(5) removing unused fields removing unused fields is fine
(2) having an Excel spreadsheet version of the 90-4.
(6) address/improve the macros used to fill out the 90-2 form address/improve the macros used to fill out the 90-2 form
(2) having an Excel spreadsheet version of the 90-4.
(7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms
(3) can there be a PDF version of the 90-2?


(3) can there be a PDF version of the 90-2?


(4) collecting information on readiness levels


(4) collecting information on readiness levels


(4) collecting information on readiness levels


(4) collecting information on readiness levels


(5) removing unused fields


(5) removing unused fields


(5) removing unused fields


(6) address/improve the macros used to fill out the 90-2 form


(6) address/improve the macros used to fill out the 90-2 form


(6) address/improve the macros used to fill out the 90-2 form


(7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms


(7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms


(7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms


(7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms


(7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms


(7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms



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cate COUNTA of cate
(1) having a long- and a short form of the 90-2. 2
(2) having an Excel spreadsheet version of the 90-4. 6
(3) can there be a PDF version of the 90-2? 2
(4) collecting information on readiness levels 4
(5) removing unused fields 3
(6) address/improve the macros used to fill out the 90-2 form 3
(7) provide more/better/different guidance on how to fill out the 90-2 and 90-4 forms 6
Total Result 26
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