Instructions for Completing Supporting Statements A&B

Each request for OMB approval of an information collection must include a Supporting Statement prepared in the format described below. The quality of the Supporting Statement is a key factor in whether approval is obtained. If an item is not applicable, provide a brief explanation (do not write N/A). All Statements must respond to the items in Section A; if the collection will employ statistical methods Section B will be required. Click here for the electronic template for the Supporting Statement. DO NOT alter the questions in this template!

Attach copies of any forms or other instruments used to obtain the information from the public. Unless an exemption is requested, e.g. for an international collection, forms must display the OMB Control Number and current expiration date, or have placeholders for them in new collections. Also required on all forms is a Paperwork Reduction Act Statement, a paragraph containing: Purpose of the information collected. Estimated time for completion. Contact information for the applicable program person NPS authorization statement on the voluntary nature of the collection

Your Supporting Statement should each question below.
These are provided in the electronic format available on this site.

Supporting Statement A
[TITLE OF COLLECTION]

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

Include a citation and brief description of any statute or executive order that requires the collection, as well as any pending regulations on which revisions are based, if applicable. Copies of statutes mandating or authorizing a collection must be included with all submissions. Provide some background information on the program and describe how the collection supports it. Detail any specific program problems you hope to resolve. If NPS or a state or local partner is already collecting information from the same universe of respondents, briefly describe these collections and how they relate to the proposed collection. Every practical effort should be made to consolidate requirements on the same respondents, and the Supporting Statement should reflect that this has been done. If collections have very similar questions, you may wish to describe the relationship in Item 4, rather than in Item 1.

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.

For all “renewals” you must indicate the actual use NPS has made of the information received as a result of the previous collection. This explanation of the proposed and any past use of the information is a key one and must be detailed. Do not just make general statements about the overall use of the information, but address the specific items of information being collected. You should deal individually with each question or type of question being asked in your survey or on your form unless the purpose of the question is obvious to someone not familiar with your program. One of OMB's key standards under the Paperwork Reduction Act is whether the information has "practical utility"; you must demonstrate that you will be using all of the information collected for a practical and necessary program purpose.

It is anticipated that the information collected will be disseminated to the public or used to support publicly disseminated information. NPS (insert line office or program name) will retain control over the information and safeguard it from improper access, modification, and destruction, consistent with NPS 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.

If you do not plan to disseminate the information, or use it to support information that will be disseminated, explicitly state this in the answer: Although the information collected I may be not expected to be disseminated directly to the public, results may be used in scientific, management, technical or general informational publications.

Finally, OMB has standards for asking questions about race or ethnicity. If you ask such questions, you must comply with those standards.

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.

Explain the basis for the decision for adopting this means of collection. Also describe any consideration you have given or are giving to the use of improved information technology to reduce the burden on the public. You must address the following:
a. Is the electronic submission of responses possible
b. If a form is involved, is it available for public printing off the Internet* If so, please include the url.
c. Will the results of the information collection be made available to the public over the Internet?

If the answer to any of those questions is “no”, are there plans to do so? Why not? A separate aspect of the question is your use of technology. This is of particular concern in the case of interviews. Will your interviewers use laptops or other computers to directly enter the answers being provided? If not, why not?

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.

Describe your efforts to identify duplication with other collections (under other OMB Control Numbers or collections by states, etc.) which may be gathering the same or similar information. If the same or similar information is available, describe why it cannot be used or modified for the purposes described in "2" above.

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

If the collection will have a significant impact on small entities such as small businesses, organizations, or government bodies, describe the methods used to minimize the burden on them. If not, state “this collection will not involve small business or small entities.

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.

Address both parts of the question: not conducting the collection AND doing it less frequently. Generally one or two paragraphs are sufficient.

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.
Explain the need for any inconsistencies in your collection.

8. Provide information on 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.

The first sentence should read: “A Federal Register Notice published on (Month, Day, Year) followed by, in parentheses, the Federal Register citation, e.g. 73 FR 12345, solicited public comment. No comments were received” (OR if there were pertinent comments, describe and respond to comments or describe how you responded directly to the commenter).

In order to receive approval, you must also request comments directly from respondents or other non-NPS stakeholders. Consultation should have occurred within 12-18 months of a renewal, even if the collection has not changed. You may use formal or informal means of reaching out to respondents, but need to describe representatives' specific responses on the usefulness of the information you collect, clarity of instructions and whether burden and cost are accurate and reasonable. You need to end up with at least two comments if possible, on any or all of these aspects. "No comment" counts as a comment, as long as it is actually stated. You must include your responses to any criticisms or suggestions made as part of these comments.

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

OMB is generally opposed to payments or gifts for information submissions, so if you are proposing to do so provide a good justification for it.

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

You must cite a specific authority for promising confidentiality. If there is no applicable authority, and you do plan to protect the information, please describe the management, operational and technical safeguards, but do not state that information will be confidential.

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.

The justification should include the reasons why the questions are necessary, the specific uses for the information, the explanation to be given to the respondents, and any steps taken to obtain their consent.

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 item 13.

Although this submission may be a revision to an approved collection, and thus describes only the new or changed requirements in Question 2, this answer should state the total new burden hours and how much this figure is increased/decreased from the previous burden (if any) for the requirement. NOTE: You are NOT required to stick to the estimated numbers in the Federal Register Notice for this collection.

  • a. The statement must provide the number of respondents expected annually, the frequency of their responses, the total number of responses expected, the average response time per respondent, and the total annual response time (in hours) for the collection. Response time includes not only the time necessary to complete the form or answer the questions, but also the time needed to gather the information (unless it was already being gathered for other purposes), to have it reviewed by lawyers or accountants, etc. Explain how you arrived at these estimates.
  • b. Remember that figures should be annualized. For example, if a permit will be valid for three years, and you expect 300 respondents the first year and none the second and third years, use the average of 100 respondents. If the burden per response is expected to vary widely, show the expected range of responses and explain the variance.
  • c. If the collection will involve more than one form or other means of information collection, provide burden estimates for each form.
  • d. Provide estimates of annualized labor cost to respondents for the hour burden for the collection, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for the collecting the information should not be included here (see Item 14 below).
13. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information.

This bears repeating - do NOT include the labor cost (wage equivalent) of the burden hours described in Question 12 (above).

Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (a) to achieve regulatory compliance with requirements not associated with the information collection, (b) for reasons other than to provide information or keep records for the government, or (c) as part of customary and usual business of private practices.

Operations and maintenance costs include the costs of mailing, faxing or calling in information, making paper copies, notary costs, and electronic transmission from vessel monitoring systems. Paint and brushes for vessel and gear marking would also fall under this category. Regular maintenance of any equipment whose initial costs fall under “capital and start-up” would also belong here.

14. Provide estimates of annualized costs 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.

Include here a description of the method used to estimate costs to the Federal government, which should show the quantification of hours, operational expenses (such as equipment, overhead, printing, and staff support), and any other expense which would not have been incurred without this collection of information. Even if there will be no costs beyond the normal labor costs for staff, please provide average staff hourly rate x estimated hours per year.

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

Program changes are new collections or changes in requirements. Adjustments are re-estimates of the number of respondents, responses and/or the response times for existing requirements. Please be more specific than, e.g. “Changes were due to the requirement that _____". List at least net changes and the specific reasons for them. If this is a new collection, and hence obviously there are no changes from a previous version, simply state “This is a new collection”.

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.

Address any complex analytical techniques that will be used. Provide a time schedule for the collection, publication, and other actions. Also, will the results of the collection be made available on your organization’s web pages? If not, why not?

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.

Self-explanatory

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

Self-explanatory - There are virtually never exceptions.
Supporting Statement B
[TITLE OF COLLECTION]

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

If your collection does not employ statistical methods, just say that and delete the following five questions from the format – UNLESS your proposed information collection is a survey. OMB has recently clarified that Part B must be completed for all survey requests, whether or not statistical analysis will be applied. In addition to statistical analysis, Part B addresses the description of the target group of respondents, the sampling plan, and plans to maximize response rates and address non-response.

When statistical methods will be used to tabulate data, the following documentation must be provided to the extent that it applies to the methods proposed.

1. Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection methods to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons) in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the collection as a whole. If the collection had been conducted previously, include the actual response rate achieved during the last collection.

Note: response rate means: Of those in your respondent sample, from what percentage do you expect to get the required information (if this is not a mandatory collection). The nonrespondents would include those you could not contact, as well as those you contacted but who refused to give the information.

2. Describe the procedures for the collection of information including:

  • Statistical methodology for stratification and sample selection,
  • Estimation procedure,
  • Degree of accuracy needed for the purpose described in the justification,
  • Unusual problems requiring specialized sampling procedures, and
  • Any use of periodic (less frequent than annual) data collection cycles to reduce burden.
If you are selecting a uniform respondent universe, you may be using simply a random numbers table to select a sample.

Stratified sampling is often used when the sampling population can be split into non-overlapping strata that individually are more homogeneous than the population as a whole (e.g. gender and age groups). If there are no obvious "dividing lines", grid lines can be used to divide the population. Random samples are taken from each stratum (or class) and the results are combined to estimate a population mean. Stratified sampling is most successful when the variance within each stratum is less than the overall variance of the population

3. Describe methods to maximize response rates and to deal with issues of non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield "reliable" data that can be generalized to the universe studied.

Any aspect of your plan which makes it easier and more attractive to comply with the request for information, would tend to maximize response rate. This would include:

  • Such steps as pre-notification and various types of follow-up with those who did not respond at the first opportunity (give details, e.g. intervals for follow-up, type(s) of follow-up, how many times you will follow up)
  • Making the questions as simple and brief as possible
  • Already having a good working relationship with this group and/or the group’s perception that actions based on the information collected would be helpful to them.
All NPS submissions are required to identify a plan to address nonresponse. This means that a large enough number of respondents didn’t give information so that there is a possibility that their answers as a group might have differed significantly from those who did respond. Following up with non-respondents – resending surveys or sending a shorter version of the survey, trying a phone interview if possible, etc. are all effective strategies.

4. Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of test may be submitted for approval separately or in combination with the main collection of information.

Pilot surveys of 10 or more are often conducted, and must go through the PRA approval process.

5. Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency.

Self-explanatory.

Last updated: September 26, 2016

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