TechEvaluation 2023 Part A.CBS_MG

Supporting Statement A

Technical Evaluations Series:

TECHNICAL ASSISTANCE, TECHNOLOGY TRANSFER, MEETING/FORUM, AND AVS TECHNICAL ASSISTANCE

OMB Control Number 1029-0114

Terms of clearance: None

General Instructions

A completed Supporting Statement A must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified below. If an item is not applicable, provide a brief explanation. When the question “Does this ICR contain surveys, censuses, or employ statistical methods?” is checked "Yes," then a Supporting Statement B must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Introduction

This information collection clearance package is being submitted by the Office of Surface Mining Reclamation and Enforcement (OSMRE) for renewed approval to collect information from a series of four customer service survey forms. OSMRE disseminates the customer survey service forms to help us determine the effectiveness and future needs of respondents who (1) are assisted by OSMRE’s Applicant/Violator System Office (AVSO), (2) receive technology transfer and (3) technical assistance, or (4) participate in technical meetings and forums. In addition, information obtained from these customer service survey forms will help OSMRE improve future technical assistance activities, ultimately benefiting the public.

OMB approved this collection and assigned it control number 1029-0114. OSMRE is seeking to extend its authority to collect this information for an additional three years.

Specific Instructions

Justification

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

OSMRE needs the information the four customer service survey forms provide to ensure that technical assistance activities meet the needs of those who participate or receive the assistance. Representatives from State and Tribal regulatory and reclamation authorities, industry, environmental and citizen groups, receive the assistance or participates in the meetings and forums. These customer service survey forms are the primary means through which OSMRE evaluates the performance goals outlined in its annual plans developed pursuant to the Government Performance and Results Act (GPRA).

Customer satisfaction is seen as an important performance indicator for the Federal government. These customer service survey forms will provide OSMRE the information it needs to determine that level of satisfaction among our customers and identify areas where improvements can be made.

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. Be specific. If this collection is a form or a questionnaire, every question needs to be justified.

OSMRE is seeking renewed approval for the use of four customer service survey forms; forms for evaluating the following: 1) Applicant/Violator Services (AVS), 2) Technical Assistance, 3) Technology Transfer, and 4) Meeting/Forums. The information collected will be used to identify and evaluate the effectiveness of OSMRE's technology development and transfer activities, its technical assistance, and to expand on those activities where needed. The intent of OSMRE’s technical program is to enhance the effectiveness of its regulatory and abandoned mine lands (AML) programs in meeting the goals of the Surface Mining Control and Reclamation Act of 1977 (SMCRA).

Approval of this information collection means that OSMRE will obtain data to assess the level of customer service provided by its technical programs. It will provide OSMRE with the data essential to determine the effectiveness of our services and develop improvements that our customers want. Furthermore, it will enable OSMRE to evaluate its performance under GPRA.

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 and specifically how this collection meets GPEA requirements.

The AVS Evaluation form is sent to customers who receive services through the AVS office. The evaluation form is provided to customers via email and is customized based on the type of service they receive. The technical transfer evaluation form, the technical assistance, and the meeting/forum evaluation forms are available at OSMRE’s website at

https://www.osmre.gov/resources/forms.

Therefore, OSMRE is in compliance with GPEA requirements.

OSMRE estimates that approximately 95% of the surveys are submitted electronically.

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.

These evaluations are used to determine the effectiveness of OSMRE’s technical program by requesting customers and participants to respond to basic questions regarding performance and usefulness of OSMRE’s AVS services, technical assistance activities, technology transfer activities, or technical forums. Similar information does not exist elsewhere.

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

There is no special burden assigned to small entities. On a voluntary basis only, we are asking those customers to respond to the evaluations.

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

This information will be collected within approximately three months after each instance of service, technical assistance, technology transfer or after a technical forum is held. Without these follow-up evaluations we do not know whether we have met either the customers' present needs or are in a position to meet their future needs.

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

* requiring respondents to report information to the agency more often than quarterly;

* requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

* requiring respondents to submit more than an original and two copies of any document;

* requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

* 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;

* requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

* 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; or

* requiring respondents to submit proprietary trade secrets, 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.

These collections are conducted in conformance with the provisions of 5 CFR 1320.5(d)(2).

8. If applicable, 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 in response to the PRA statement associated with the collection over the past three years, and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

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.

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

Feedback from respondents in 2022 concerning the customer service survey forms were largely unchanged from survey responses received in 2020. Contacts with the following were made:

Applicant Violator System Office (AVSO)

Lexington Field Office

2675 Regency Road

Lexington, KY 40503


Pennsylvania Department of Environmental Protection

131 Broadview Road

New Stanton, PA 15672

Technology Transfer Program Specialist

Division of Permitting and Compliance

400 Market St., 5th Floor

Harrisburg, PA 17105

Participants did not identify any concerns regarding the availability of data, frequency of collection, clarity of instructions and record keeping of the information collection requirements.

On April 7, 2023, OSMRE published in the Federal Register (88 FR 20907) a notice requesting comments from the public regarding the need for the collection of information, the accuracy of the burden estimate, ways to enhance the information collection, and ways to minimize the burden on respondents. This notice gave the public 60 days in which to comment, however, no comments were received.

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

Payments or gifts are not provided to respondents of the surveys.

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

Neither their names nor other identifying information is requested or retained.

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.

No questions of a sensitive nature are asked.

12. Provide estimates of the hour burden of the collection of information. The statement should:

* 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 desirable. 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.

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

* 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 under “Annual Cost to Federal Government.”

Estimated Information Collection Burden

a. Burden Hour Estimates for Respondents

In 2022, respondents returned 203 surveys, 76% of the 266 customer service surveys. Based on feedback OSMRE estimates that surveys will take on average 5 minutes to complete. Respondents indicated from interviews conducted the continual ease of use of these surveys.

203 surveys x 5 minutes= 1,015 minutes or 17 hours (1,015/60 minutes/hour rounded) to complete customer surveys annually.

b. Estimated Cost to Respondents

Hourly wage cost for state employees is derived from the Department of Labor’s Bureau of Labor statistics found at: https://www.bls.gov/oes/current/naics4_999200.htm#43-0000. The wage rate is for technical participants is represented by the occupational category for environmental engineers using mean hourly wage of $45.10/hour or $72.16/hour (45.10 x 1.6) with benefits. Benefits for state workers are calculated at a rate determined from the BLS news release USDL-23-1305, EMPLOYER COSTS FOR EMPLOYEE COMPENSATION—March 2023, dated June 16, 2023 (http://www.bls.gov/news.release/pdf/ecec.pdf).

Therefore, the estimated total annual wage cost for respondents would be $72.16 per hour x 17 hours = $1,227.

13. Provide an estimate of the total annual non-hour cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected in item 12.)

* The cost estimate should be split into two components: (a) 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 (including filing fees paid for form processing). 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 or keep records for the government, or (4) as part of customary and usual business or private practices.

Total Annual Non-Wage Cost Burden to Respondents

a. Annualized Capital and Start-Up Costs

There are no costs incurred to respondents beyond that already indicated in item 12 above.

b. Operation and Maintenance Costs

No significant non-wage operation or maintenance costs are associated with this information collection activity.

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 not have been incurred without this collection of information.

Estimate of Annualized Cost to the Federal Government

OSMRE takes on average 15 minutes to process a survey for each of the estimated 203 surveys received annually. Therefore, we estimate 50.75 hours (203 surveys x 0.25 hours/survey). It is expected that a GS 13, step- 5 level employee will review the surveys received. The hourly wage is $53.49(https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2023/RUS_h.pdf). With benefits calculated at a rate of 1.6 for government employees based on the U.S. Bureau of Labor Statistics news release USDL-23-1305, the hourly rate is $85.58. The cost to the federal government will be $4,343 ($85.58/hour x 50.75 hours).

15. Explain the reasons for any program changes or adjustments in hour or cost burden.

The current information collection burden approved by OMB for these evaluations is 19 hours. The number of annual participants as fallen from 220 to 203 reducing the annual burden by 2 hours for administering the surveys. Therefore, this information collection request will decrease the burden hours for respondents as follows:

19 Hours currently approved

- 2 Hours due to an adjustment

17 Hours requested

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 will be compiled and published as a part of OSMRE’s reporting under GPRA.

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.

The OMB approval number, 1029-0114, and expiration date will be displayed on the forms.

18. Explain each exception to the topics of the certification statement identified in "Certification for Paperwork Reduction Act Submissions."

There are no exceptions to OMB’s Certification for Paperwork Reduction Act Submissions.

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