Justification

Request for Approval under the “Generic Clearance for Participatory Science and Crowdsourcing Projects” (OMB Control Number: 2080-0083; EPA ICR Number: 2521.43)

TITLE OF INFORMATION COLLECTION: US EPA Sanitary Survey App for Marine and Fresh Waters

PURPOSE:

A sanitary survey is a method of investigating the sources of fecal contamination to a water body. Sanitary surveys help state, territorial, and tribal managers, of beach and other waterbody programs, and public health officials: identify sources of water pollution; assess the magnitude of pollution; and identify priority locations for water quality monitoring or remediation. Recreational water sanitary surveys involve collecting information at the beach or waterbody, as well as on the surrounding land.

EPA has updated its recreational sanitary survey app, EPA Sanitary Survey App for Marine and Fresh Waters (App), to help waterbody managers evaluate all contributing waterbody and watershed information including water quality data, pollution source data, and land use data. The data from the App can be exported for use in predictive models and for sharing within or between agencies (e.g., public health and environmental). The App includes routine and more comprehensive annual sanitary surveys for both fresh and marine waters. The App surveys update the paper forms of the sanitary surveys for the Great Lakes and marine waters. The App can be used by the citizen science community interested in collecting sanitary survey information or in understanding what fecal contamination sources are impacting a beach or waterbody and to easily gather information on possible existence of harmful algal blooms. The App has been designed to be used on any device, including smart phones, tablets, and computers, and in the field without the need for Internet or WIFI access.

NEED AND AUTHORITY FOR COLLECTION:

Although the collection of this data and use of the App is voluntary, the information that is collected by using the App can be used by EPA and states to ensure that recreation aspect of the Clean Water Act 101(a)(2) interim goal of water quality which provides for "the protection and propagation of fish, shellfish, and wildlife and provides for recreation in and on the water" is met. The citizen science community is increasingly interested in supporting the EPA, states and tribes with quality data that can inform and/or support their decisions and support restoration and remediation of recreational waters.

Clean Water Act § 104, 33 U.S.C. § 1254, authorizes EPA to encourage, cooperate with and render technical services to individuals, including the general public, to promote the coordination and acceleration of demonstrations, studies and training relating to the causes, effects, prevention and elimination of water pollution.

The Beaches Environmental Assessment and Coastal Health (BEACH) Act amends the Clean Water Act (CWA) in part and authorizes the U.S. Environmental Protection Agency (EPA) to award BEACH Act Program Development and Implementation Grants to coastal and Great Lakes states, tribes, and territories (collectively referred to as jurisdictions) for their beach monitoring and notification programs. The grants assist those jurisdictions to develop and implement a consistent approach to monitor recreational water quality; assess, manage, and communicate health risks from waterborne microbial contamination; notify the public of pollution occurrences, and post beach advisories and closures to prevent public exposure to microbial pathogens. To qualify for a BEACH Act Grant, a jurisdiction must submit information to the EPA documenting that its beach monitoring and notification program is consistent with performance criteria outlined in the National Beach Guidance and Required Performance Criteria for Grants, 2014 Edition.

The National Environmental Education Act, § 4, 20 U.S.C. § 5503 authorizes EPA to develop and support programs to increase environmental literacy.

USES OF RESULTING DATA:

The information collection by the citizen science community is voluntary. The information collected by the citizen science community could be used by states, territories and tribes to understand sources of fecal contamination that are impacting a beach or waterbody, so these sources can be remediated. Remediation of fecal sources results in a reduced number of swimming advisories and improved water quality. The data collected using the App can also be used to develop predictive models for making same-day decisions on swimming advisories. The App can also be used to identify areas where there might be harmful algal blooms.

DATA COLLECTION METHODS:

Data will be collected through the US EPA Sanitary Survey App mobile application. The US EPA Sanitary Survey App for Marine and Fresh Waters was developed under a federal contract with Attain, LLC (1600 Tysons Boulevard, Suite 1400, McLean, VA 22102). Attain LLC subcontracted Innovate! Inc. (6189 Cobbs Road, Alexandria, VA 22310) to support App development. The US EPA Sanitary Survey App for Marine and Fresh Waters updates the paper forms for the surveys for marine waters and the Great Lakes. The information collected with the App will be stored in a secure GeoPlatform maintained by EPA.

The US EPA Sanitary Survey App will be available for users to download and use free of charge. In addition, storage of data on the GeoPlatform will be free of charge. Users can download their data from the GeoPlatform in a variety of formats (e.g., Excel file, CSV file).

The App does not collect sensitive PII – it only collects information on the surveyor’s name and organization. Each agency or citizen science organization will be given its own log in account and having the surveyor’s name would allow an agency or organization to track who in the agency or organization has completed the form on its behalf. Generally, a user can only access the information the user has collected; therefore, the data and PII collected is not available to others.

PARTICIPANT UNIVERSE:

Category of Respondent	No. of Respondents (annual)	Number of responses per respondent	Participation Time per response	Estimated Annual Burden Hours
Individual submitting Freshwater Routine Survey - Complete Data Collection, Export Data Form, Share Data Form	500	1	30 minutes – Data Collection 5 minutes – Export Data 5 minutes – Share Data	333
Individual submitting Freshwater Annual Complete Data Collection, Export Data Form, Share Data Form	400	1	2 hours – Data Collection 5 minutes – Export Data 5 minutes – Share data	866
Individual submitting Marine Routine Survey - Complete Data Collection, Export Data Form, Share Data Form	500	1	30 minutes – Data Collection 5 minutes – Export Data 5 minutes – Share Data	333
Individual submitting Marine Annual Complete Data Collection, Export Data Form, Share Data Form	400	1	2 hours – Data Collection 5 minutes – Export Data 5 minutes – Share data	866
Total	1800			2,398

AGENCY COST: 

The anticipated cost to the Federal Government is approximately $14,033 annually.  These estimated costs are comprised of: project administration and estimated contractor payments. EPA person-costs are estimated using an hourly rate for a GS-14 (step 1) including an additional 60% for benefits based in Washington, DC. Time spent on each step may vary, as well as the GS-level of the employees involved.   

Task	Costs (and Person-hours)		Total Hours and Cost
	EPA ($50.41/ Hour)	Estimated contractor costs	Total Cost/Year
Project Administration	Assume 80 hours	---	$4,033
Contractor costs		$10,000
Total			$14,033

 

STATISTICAL ANALYSIS:

EPA is not conducting any statistical analysis. All statistical analyses will be conducted by states, territories, tribes or local governments. These entities will make decisions with this data.

DATA QUALITY ASSESSMENT PROCEDURES:

EPA has developed a management plan for data in the data system that accompanies the App. EPA determined that no Quality Assurance Project Plan (QAPP) is necessary for the App itself other than the quality assurance already required by the contract with the developer. The quality of the data in the App will rely on QAPPs developed by the users for their data collection (e.g., local government scientists and citizen science individuals/organizations). Users must attest that data collection is in accordance with an approved QAPP and provide a link to a QAPP in the App in order to submit their data to the GeoPlatform.

ADMINISTRATION OF THE INSTRUMENT: (Check all that apply)

[ x ] Web-based or Social Media

[ ] Telephone

[ x ] In-person

[ ] Mail

[ ] Other, Explain

INSTRUMENT: Append a copy of the questionnaire or a screen shot of the website or app that includes the information collection.

CONTACT NAME: Sharon Frey EMAIL: [email protected]

Guidance: Request for Approval under the “Generic Clearance for Citizen Science and Crowdsourcing Projects” (OMB Control Number: 2080-0083)

TITLE OF INFORMATION COLLECTION: Provide the name of the collection that is the subject of the request.

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.

NEED AND AUTHORITY FOR COLLECTION: In this section, describe why the information is needed and under what legal authority it will be collected. Then, to establish legal authority, cite the principal authorities and explain how they relate to the collection.

USES OF RESULTING DATA: In this section, describe how the information you collect will fulfill a need. If your ICR is a renewal, you must include a discussion of how the Agency has made use of the information already received.

DATA COLLECTION METHODS: To demonstrate that the information you collect will be useful - accurate, reliable, and retrievable - once collected, describe the collection methodology and management.

PARTICIPANT UNIVERSE: To calculate the total burden and costs, you must estimate the number of respondents to complete each activity. The total number of respondents is also referred to as the respondent universe. In estimating the respondent universe, you should consult industry reports, census data, or a previously completed Information Collection Request. The public comment period or your consultations (with nine or fewer respondents) may also provide some information on the approximate number of respondents.

You should note that the respondent universe may vary among the activities listed because not all respondents must complete each activity.

AGENCY COST: To estimate agency costs, multiply burden hours per activity by labor rates. The cost to employ Federal government workers is published annually by the Office of Personnel Management. Estimate the cost to the Federal government for just the information collection, not the project as a whole. In your write-up for this section, briefly explain how you derived your Agency burden and cost estimates.

STATISTICAL ANALYSIS: Briefly explain your statistical analysis. In your discussion, confirm that the anticipated survey results will satisfy the survey objectives and your program's information needs.

Also, if you plan to use a contractor for any aspect of the survey, state the name and address of the firm, and indicate on which component(s) (i.e., design, tabulation, etc.) the contractor will provide support.

ADMINISTRATION OF THE INSTRUMENT: Check all that apply.

INSTRUMENT: Append a copy of the information collection or a screen shot of the website or app that includes the information collection.

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