FOCUS GROUPS AS USED BY EPA FOR ECONOMICS PROJECTS 

EPA ICR No. 2205.02

SUPPORTING STATEMENT

Part A

Section 1.  Identification of the Information Collection

1(a)  Title of the Information Collection:

Focus Groups as Used by EPA for Economics Projects

1(b)  Short Characterization/Abstract:

The Environmental Protection Agency (EPA) is seeking approval for a
generic information collection request (ICR) for the conduct of focus
groups and one-on-one interviews related to survey development for
economics projects.   Focus groups are groups of individuals brought
together for moderated discussions on a specific topic or issue.  These
groups are typically formed to gain insight and understanding of
attitudes and perceptions held by the public surrounding a particular
issue.  One-on-one interviews, as the term implies, are individual
interviews in which a respondent is generally asked to review materials
and provide feedback on their content and design as well as the thought
processes that the materials invoke.

Focus groups and one-on-one interviews (hereafter referred to
collectively as “focus groups”) used as a qualitative research tool
have three major purposes:

To better understand respondents’ attitudes, perceptions and emotions
in response to specific topics and concepts;

To obtain respondent information useful for better defining variables
and measures in later quantitative studies; and

To further explore findings obtained from quantitative studies.

Through these focus groups, the Agency will be able to gain a more
in-depth understanding of the public’s attitudes, beliefs, motivations
and feelings regarding specific issues and will provide invaluable
information regarding the quality of draft survey instruments.  Focus
group discussions are necessary and important steps in the design of a
quality survey.

Section 2.  Need for and use of the Collection

2(a)	Need/Authority for the Collection

Over the next three years, the Agency anticipates embarking on a number
of survey development efforts associated with a variety of economics
projects including those related to valuation of ecosystems,
children’s health risks, improvements to coastal waters, and invasive
species to name a few.  Focus groups are an important part of any survey
development process, allowing researchers to directly gauge what
specific issues are important to the public and providing a means for
explicitly testing draft survey materials.  

If this information is not collected, a vital link in developing methods
to better understand the economic benefits and costs associated with
Agency actions will be lost.   This loss will cause further delays in
the development of improved estimates of benefits and costs.

This data collection is conducted for research purposes; there are no
legal requirements.  The materials prepared for these discussions will
fully conform to federal regulations – specifically the Privacy Act of
1974 (5 U.S.C. 552a), the Hawkins-Stafford Amendments of 1988 (P.L
100-297), and the Computer Security Act of 1987.

2(b)	Practical Utility/Users of the Data

The information collected in the focus groups will be used to develop
and improve economics-related surveys.  To the extent that these surveys
are ultimately successfully administered, they will serve to expand the
Agency’s understanding of benefits and costs of a variety of actions
and could provide the means to quantitatively assess the effects of
others.  Participation in the focus groups will be voluntary and the
identity of the participants will be kept confidential.

Focus groups generally do not yield meaningful quantitative findings and
do not yield data about public opinion that can be generalized.  As
such, they cannot be used directly to estimate benefits and costs
associated with a specific environmental action.  However, program
offices engaged in survey research use focus groups as an important tool
in the survey development process to test and refine their ideas.  The
conduct of quantitative research would need to be completed to develop
new estimates of benefits or costs.

Section 3.  Non duplication, Consultations, and Other Collection
Criteria

3(a)	Non duplication

It is not expected that any of the information to be submitted to the
EPA during these focus group studies is duplicative or is already in the
possession of the Federal Government.  The proposed focus groups will
address the needs of the Agency and significantly improve our ability to
test and redefine ideas that will allow EPA to conduct further
quantitative research on various environmental economics issues.

3(b)	Public Notice Required Prior to ICR Submission to OMB

In accordance with 5 CFR 1320.8(d) on November 4, 2005, EPA published a
60-day Federal Register notice (68 FR 65938).  See Appendix 1 for a copy
of this Federal Register notice. 

3(c) 	Consultations

EPA will use in-house staff and/or outside contractors (including
possible contacts with the academic community) to develop focus group
plans for areas of interest.  According to OMB guidelines for generic
clearances for focus groups, EPA will establish an independent review
process to assure the development and implementation of high quality
focus groups by EPA.  EPA will provide OMB a copy of the survey
instrument for inclusion in the public docket.

3(d)	Effects of Less Frequent Collection

	Each focus group will be a one-time collection exercise for the
enrolled participants.

3(e)	General Guidelines

This collection does not violate any of OMB’s general guidelines for
information collections.

Information will be collected according to the guidelines in 5 CFR 1320.
 Respondents will be asked to participate in one focus group and their
participation will be voluntary. There will be no need for participants
to maintain records or submit documents or proprietary trade secrets. 
There will be complete protection of any demographic information
collection from participant—full names, phone numbers and addresses
will not be associated with responses.  

EPA has developed EPA Information Quality Guidelines (2002) to ensure
the utility, objectivity and integrity of information that is
disseminated by the Agency.  It is EPA’s intention that collection of
information under this ICR will result in information that will be
collected, maintained, and used in ways consistent with both the EPA
Information Quality Guidelines (2002) and the OMB Information Quality
Guidelines (2002).   EPA intends to conduct a pre-dissemination review
when the Agency prepares to disseminate information collected under this
ICR.

3(f)	Confidentiality

Each focus group will fully conform to federal regulations –
specifically the Privacy Act of 1974 (5 U.S.C. 552a), the
Hawkins-Stafford Amendments of 1988 (P.L 100-297), and the Computer
Security Act of 1987.  

3(g) 	Sensitive Questions

No questions will be asked that are of a personal or sensitive nature.

Section 4.  The Respondents and the Information Requested

4(a)	Respondents/SIC Codes

The target population for the focus group discussions will vary by
project, but will generally include members of the general public.

4(b)	Information Requested

Data items, including record keeping requirements

Respondent Activities

Respondents will be asked to participate in a moderated discussion on a
particular topic or issue, during which they will be asked their
thoughts, perceptions and beliefs regarding the issue.  The collection
will be a one time event and there will be no need for participants to
maintain records or submit documents or proprietary trade secrets. 
There will be complete protection of any demographic information
collection from participants -- names, phone numbers and addresses will
not be associated with responses.

Section 5.  The Information Collected – Agency Activities, Collection
Methodology, and Information Management

5(a) Agency Activities

Agency activities associated with this information collection will
include:

-- Drafting focus groups scripts and accompanying materials

-- Observing and in some cases moderating the focus group discussions

-- Summarizing focus group results and making changes to draft survey
materials as appropriate

In addition, the Agency will establish a three-member cross-office panel
to review focus group projects proposed under this ICR.  Membership on
the panel will be on a rotational basis and will consist of one
economist from the Office of Policy, Economics, and Innovation’s
National Center for Environmental Economics and two other economists
from elsewhere in the Agency.  Each of the panel members will have
experience with surveys.  Only projects that have as their primary goal
the estimation of benefits, the estimation of costs, or the elicitation
of preferences for health outcomes, safety and/or environmental goods
will be considered.  Additional details about the panel review process
can be found in the Appendix 2.  

5(b) Collection Methodology and Management

Focus group studies are directed group discussions that do not produce
quantitative data, but which enable skilled observers to infer the
underlying views and assumptions of the group that are expressed in the
discussion.  To facilitate interpretation, discussions are generally
recorded and videotaped so that both a visual record and written
transcript of the discussion are available for review.  Participants are
informed in advance that the sessions will be recorded.  Transcripts and
video tapes will be maintained in the individual project files.

5(c) Small Entity Flexibility

No information will be collected from small businesses or small
organizations or small governmental jurisdictions as a result of this
information collection.

5(d) Collection Schedule

Focus groups will be scheduled according to the needs of individual
projects.  No firm schedule for this collection has been established
otherwise.

Section 6.  Estimating the Burden and Cost of Collection

6(a)	Estimating Respondent Burden

6(b)	Estimating Respondent Costs

Estimates of respondent burden were derived from projected focus group
usage over the next three years.  Each program office was asked for the
number and size of the focus groups that they anticipate conducting for
economics projects over the next three years.  The total estimated
hourly burden imposed by this collection of information over the next
three years is approximately 3,418 hours or approximately 1,139 hours
annually. The total burden per year is valued at approximately $30,147. 
There are no capital costs or operating and maintenance costs associated
with this collection.

TABLE 1. – Average Annual Respondent Burden and Costs1

Center	

Subject	

Approximate Number of Studies	

Average Number  of Focus Groups per Study

	

Average Number of Participants per Group	

Average Hours of Duration for Each Group (includes screening)

	

Total Estimated “Respondent” Hours 

Over next 3 years

	

Total Estimated

Burden per Year ($)



Office of Policy, Economics and Innovation	

Various (e.g, coastal water valuation, children’s health valuation,
ecosystem valuation)	

7	

8	

9	

2.0	

1008	

$8,891



Office of Research and Development	

Various (e.g., health valuation, ecosystem services)	

4	

9	

9	

2.1	

680	

$5,997



Office of Water	

Various (e.g., invasive species)

	

2	

20	

9	

3	

1080	

$9,526



Office of Air and Radiation	

Various (e.g., averting behavior, Smartway)

	

5	

3	

16	

2.7	

650	

$5,733



	

TOTAL







	

3,418

	

$30,147

1  There are no capital costs or operating and maintenance costs
associated with this collection of 

  information.

2  Hourly rate ($26.46) from “Total compensation, all workers, all
civilian, 2005 – Qtr 4", U.S. Department of Labor, Bureau of Labor
Statistics, Employer Costs for Employee Compensation.

6(c)	Estimating Agency Burden and Costs

The Agency incurs costs to develop the focus group materials, organize
and conduct focus group discussions, and observe focus group
discussions.  These expenses will vary by specific project.  The table
below provides a hypothetical assessment of what the costs might be per
year based on a number of assumptions regarding the level of effort
required.  EPA person-costs are estimated using an hourly rate for a
GS-14 (step 1) based in Washington, DC.  Time spent on each step may
vary as well as the GS-level of the employees involved.  Contractor
costs will also depend on the location of focus groups, degree of
involvement in materials preparation and whether written transcripts of
each focus group are required.  The estimates presented below assume
that the Agency prepares all of the materials and that approximately 3
individuals observe each focus group. 

Estimated Average Annual Agency Burden and Costs

Task	Costs (and Person-hours) Per Focus Group Hour	Total Hours and Cost

	EPA

($43.80/

Hour)	Estimated Contractor Costs1	O&M Cost	Number of focus group
hours/year.	Total Cost/Year

Prepare Materials for Focus Group Discussion	$876

(20 hrs)	

--	

--	

348	

$304,848

Organize and conduct focus group discussion

(contractor)	--	

$4,000	

--	

348	

$1,392,000

Observe focus group discussion	$131.40

(3 hrs)

	--	--	

348	

$45,727



Total

	

$1,007.40	

$4,000	--	

348	

$1,742,575

Notes:  1includes recruiting respondents, meeting space, respondent
reimbursement for approximately 9 participants, and recording of
discussion.

6(d)	Estimating the Respondent Universe and Total Burden and Costs

6(e)	Bottom Line Burden Hours and Cost Tables

We expect focus group hours to total 3,418 over the next 3 years or
1,139 each year.  These hours will be spread over approximately 147
focus groups over the course of the 3-year time frame.

Respondent Tally

Action	Approximate Number of Focus Groups per year	 Estimated Respondent
Hours per Year	Total labor Cost per Year	Total Annual Capital Costs
Total Annual O&M costs

Focus Group Discussion	49	1139	$30,147	$0	$0



Agency Tally

	Approximate Number of Focus Groups per year	Estimated Focus Group Hours
per year	Total Capital/Startup Cost Per Year	Total Labor Cost per Year
Total Annual Cost 

Focus Group Discussion	49	348	$1,392,000	$350,575	$1,742,575



6(f)	Reasons for Change in Burden

Not Applicable

6(g) 	Burden Statement

As noted previously, we expect focus group hours to total about 3,418
over the next 3 years or 1,139 hours each year.  These hours will be
spread over approximately 147 focus groups over the course of the 3-year
time frame.  The approximate respondent burden for this collection comes
to $30,147 per year whereas the annual Agency burden is approximately
$1.7 million.

Burden means the total time, effort, or financial resources expended by
persons to generate, maintain, retain, or disclose or provide
information to or for a Federal agency.  This includes the time needed
to review instructions; develop, acquire, install, and utilize
technology and systems for the purposes of collecting, validating, and
verifying information, processing and maintaining information, and
disclosing and providing information; adjust the existing ways to comply
with any previously applicable instructions and requirements; train
personnel to be able to respond to a collection of information; search
data sources; complete and review the collection of information; and
transmit or otherwise disclose the information.  An Agency may not
conduct of sponsor, and a person is not required to respond to, a
collection of information unless it displays a currently valid OMB
control number.  The OMB control number for EPA’s regulations are
listed in 40 CFR Part 9 and 48 CFR Chapter 15.

Send comments on the Agency’s need for this information, the accuracy
of the provided burden estimates, and any suggested methods for
minimizing respondent burden, including through the use of automated
collection techniques to the Director, Collection Strategies Division,
U.S. Environmental Protection Agency (2822), 1200 Pennsylvania Ave., NW,
Washington, D.C. 20460; and to the Office of Information and Regulatory
Affairs, Office of Management and Budget, 725 17th Street, NW,
Washington, D.C. 20503, Attention: Desk Officer for EPA.  Include the
EPA ICR number and OMB control number in any correspondence.



Part B.

There are no tabulated results for this information collection.

Information gathered from focus groups is qualitative in nature.  They
allow for a more in-depth understanding of respondents’ attitudes,
beliefs, motivations, and feelings than do quantitative studies. It
serves the narrowly defined need for direct and informal opinion on a
specific topic.

Appendix 1

[Federal Register: November 4, 2005 (Volume 70, Number 213)]

[Notices]

[Page 67163-67165]

From the Federal Register Online via GPO Access [wais.access.gpo.gov]

[DOCID:fr04no05-42]

-----------------------------------------------------------------------

ENVIRONMENTAL PROTECTION AGENCY

[OA-2005-0004, FRL-7993-8]

 

Agency Information Collection Activities: Proposed Collection; 

Comment Request; Focus Groups as Used by EPA for Economics Projects, 

EPA ICR Number 2205.01

AGENCY: Environmental Protection Agency.

ACTION: Notice.

-----------------------------------------------------------------------

SUMMARY: In compliance with the Paperwork Reduction Act (44 U.S.C. 3501 

et seq.), this document announces that EPA is planning to submit a 

proposed Information Collection Request (ICR) to the Office of 

Management and Budget (OMB). This is a request for a new collection. 

Before submitting the ICR to OMB for review and approval, EPA is 

soliciting comments on specific aspects of the proposed information 

collection as described below.

DATES: Comments must be submitted on or before January 3, 2006.

ADDRESSES: Submit your comments, referencing docket ID number OA-2005-

0004, to EPA online using EDOCKET (our preferred method), by e-mail  
HYPERLINK "mailto:oei.docket@epa.gov"  

oei.docket@epa.gov , or by mail to: Environmental Protection Agency, EPA


Docket Center (EPA/DC), Office of Environmental Information, Mail Code 

2822T, 1200 Pennsylvania Avenue, NW., Washington, DC 20460.

FOR FURTHER INFORMATION CONTACT: Nathalie Simon, Office of Policy, 

Economics and Innovation, Mail Code 1809T, Environmental Protection 

Agency, 1200 Pennsylvania Avenue, NW., Washington, DC 20460; telephone 

number: 202-566-2347; fax 202-566-2363; e-mail address:   HYPERLINK
"mailto:simon.nathalie@epa.gov"  

simon.nathalie@epa.gov .

SUPPLEMENTARY INFORMATION: EPA has established a public docket for this 

ICR under Docket ID number OA-2005-0004, which is available for public 

viewing at the Office of Environmental Information (OEI) Docket in the 

EPA Docket Center (EPA/DC), EPA West, Room B102, 1301 Constitution 

Avenue, NW., Washington, DC. The EPA Docket Center Public Reading Room 

is open from 8:30 a.m. to 4:30 p.m., Monday through Friday, excluding 

legal holidays. The telephone number for the

[[Page 67164]]

Reading Room is (202) 566-1744, and the telephone number for the Office 

of Environmental Information (OEI) Docket is (202) 566-1752. An 

electronic version of the public docket is available through EPA 

Dockets (EDOCKET) at   HYPERLINK "http://www.epa.gov/edocket" 
http://www.epa.gov/edocket . Use EDOCKET to obtain 

a copy of the draft collection of information, submit or view public 

comments, access the index listing of the contents of the public 

docket, and to access those documents in the public docket that are 

available electronically. Once in the system, select ``search,'' then 

key in the docket ID number identified above.

    Any comments related to this ICR should be submitted to EPA within 

60 days of this notice. EPA's policy is that public comments, whether 

submitted electronically or in paper, will be made available for public 

viewing in EDOCKET as EPA receives them and without change, unless the 

comment contains copyrighted material, confidential business 

information (CBI), or other information whose public disclosure is 

restricted by statute. When EPA identifies a comment containing 

copyrighted material, EPA will provide a reference to that material in 

the version of the comment that is placed in EDOCKET. The entire 

printed comment, including the copyrighted material, will be available 

in the public docket. Although identified as an item in the official 

docket, information claimed as CBI, or whose disclosure is otherwise 

restricted by statute, is not included in the official public docket, 

and will not be available for public viewing in EDOCKET. For further 

information about the electronic docket, see EPA's Federal Register 

notice describing the electronic docket at 67 FR 38102 (May 31, 2002), 

or go to   HYPERLINK "http://www.epa.gov/edocket" 
http://www.epa.gov/edocket .

    Title: Focus Groups as used by EPA for Economics Projects.

    Abstract: The Environmental Protection Agency (EPA) is seeking 

approval for a generic information collection request (ICR) for the 

conduct of focus groups and protocol interview (hereafter jointly 

referred to as focus groups) related to economics projects. Over the 

next three years, the Agency anticipates embarking on a number of 

survey development efforts associated with a variety of economics 

projects including those related to valuation of ecosystems, children's 

health risks, improvements to coastal waters, and invasive species to 

name a few. Focus groups are an important part of any survey 

development process, allowing for researchers to directly gauge what 

specific issues are important to the public and providing a means for 

explicitly testing draft survey materials. Through these focus groups, 

the Agency will be able to gain a more in-depth understanding of the 

public's attitudes, beliefs, motivations and feelings regarding 

specific issues and will provide valuable information regarding the 

quality of draft survey instruments.

    The information collected in the focus groups will be used to 

develop and improve economics-related surveys. To the extent that these 

surveys are ultimately successfully administered, they will serve to 

expand the Agencies understanding of benefits and costs of a variety of 

actions and could provide the means to quantitatively assess the 

effects of others. Participation in the focus groups will be voluntary 

and the identity of the participants will be kept confidential.

    An agency may not conduct or sponsor, and a person is not required 

to respond to, a collection of information unless it displays a 

currently valid OMB control number. The OMB control numbers for EPA's 

regulations in 40 CFR are listed in 40 CFR part 9.

    The EPA would like to solicit comments to:

    (i) Evaluate whether the proposed collection of information is 

necessary for the proper performance of the functions of the Agency, 

including whether the information will have practical utility;

    (ii) Evaluate the accuracy of the Agency's estimate of the burden 

of the proposed collection of information, including the validity of 

the methodology and assumptions used;

    (iii) Enhance the quality, utility, and clarity of the information 

to be collected; and

    (iv) Minimize the burden of the collection of information on those 

who are to respond, including through the use of appropriate automated 

electronic, mechanical, or other technological collection techniques or 

other forms of information technology, e.g., permitting electronic 

submission of responses.

    Burden Statement: The only burden imposed by the focus group 

interviews on respondents will be the time required to participate in 

the focus groups and answer the associated questions. The Agency 

estimates that for economics projects anticipated over the next three 

years, 1758 participants will be needed to participate in 188 focus 

groups. In most cases, the anticipated length of the focus groups is 

2.0 hours per participant, with the average length per focus group 

equal to 2.4 hours. Based on an average hourly rate of $25.87 \a\ 

(including employer costs of all employee benefits), the Agency expects 

that the average per-respondent cost for the focus groups will be 

$62.09 and the corresponding one-time total cost to all respondents 

will be $109,151 (see table below). Since this information collection 

is voluntary and does not involve any special equipment, respondents 

will not incur any capital or operation and maintenance (O&M) costs.

------------------------------------------------------------------------
---

    \a\ Employer costs per hour worked for employee compensation and 

costs as a percent of total compensation: Civilian workers, total 

compensation, March 2005 (  HYPERLINK
"http://stats.bls.gov/news.release/ecec.t02.htm" 
http://stats.bls.gov/news.release/ecec.t02.htm ). 

  

                                    Table.--Estimated Burden to
Participants

------------------------------------------------------------------------
----------------------------------------

                                                                        
           Number of

                                                                   
Number of     participants    Average length

                Office                     Topics to include      focus
groups      per focus     of focus group

                                                                        
             group

------------------------------------------------------------------------
----------------------------------------

(1)                                    (2).....................         
   (3)             (4)            (5)

Office of Policy Economics and         Valuation of                     
    48               9              2

 Innovation.                            Improvements to Coastal

                                        Water; Valuation of

                                        Children's Health Risk,

                                        Ecological Valuation,

                                        etc.

Office of Research and Development...  Valuation of                     
    70               9              2.1

                                        environmental

                                        improvements; ecosystem

                                        services, etc.

[[Page 67165]]

Office of Air and Radiation..........

Office of Radiation and Indoor Air...  Environmental management         
     6              20              4

                                        of asthma; Indoor air

                                        quality management in

                                        schools and large

                                        buildings, etc.

Office of Transportation and Air       Encouraging fuel                 
     4               9              2

 Quality.                               efficiency through

                                        labeling (Smartway

                                        brand), etc.

Office of Water......................  Invasive species                 
    60               9              3

                                        prevention; Great

                                        Lakes, etc.

                                                               
------------------------------------------------

    Total............................  ........................         
   188           *1758            **2.4 

------------------------------------------------------------------------
----------------------------------------

*Total needed for all focus groups [sum[col (3)*(4)]].

**Average time for all focus groups [cols. (3)*(5)/188].

    Burden means the total time, effort, or financial resources 

expended by persons to generate, maintain, retain, or disclose or 

provide information to or for a Federal agency. This includes the time 

needed to review instructions; develop, acquire, install, and utilize 

technology and systems for the purposes of collecting, validating, and 

verifying information, processing and maintaining information, and 

disclosing and providing information; adjust the existing ways to 

comply with any previously applicable instructions and requirements; 

train personnel to be able to respond to a collection of information; 

search data sources; complete and review the collection of information; 

and transmit or otherwise disclose the information.

    Dated: September 26, 2005.

Al McGartland,

Office Director, National Center for Environmental Economics, Office of 

Policy, Economics and Innovation.

[FR Doc. 05-22035 Filed 11-3-05; 8:45 am]

BILLING CODE 6560-50-P

Appendix 2

Proposed Process for Review of Focus Group Submissions 

Under Generic ICR “Focus Groups as Used by EPA for Economics
Projects” 

A cross-office, standing panel will be created, consisting of three
economists with survey experience, to review requests from individuals
or teams wishing to conduct focus groups under the generic ICR.   One
member of the panel will be from NCEE.  Nominations for the other two
seats will be solicited from the Program offices through the Econ Forum
and will be decided by the Econ Forum Steering Committee.  Membership on
the panel will be on a rotational basis with each member appointed to a
1-year term.  Members will be permitted to serve up to five, consecutive
terms, but must then step down for a 12-month period before serving in
this capacity again.  In order to prevent wholesale turn-over of the
panel at one time, the following maximum term limits may be applied to
members of the first panel (if needed):

NCEE – no more than 3 consecutive terms

Program Office #1 – no more than 4 consecutive terms

Program Office #2 – no more than 5 consecutive terms.

Only relevant projects will be considered.  Relevant projects are
defined as those with an economics component.  That is, they must have
as their primary goal the estimation of benefits, the estimation of
costs, or the elicitation of preferences for health outcomes, safety
and/or environmental goods.  

Projects submitted for consideration must be entered into the Science
Inventory Database.  The Science Inventory Database is a publicly
searchable database designed to track and report peer review and other
science activities across the Agency.  Peer review work products are
divided into three categories: highly influential scientific
assessments, influential scientific information and other products. 
Creating an entry in the database will allow more public scrutiny of the
proposed research and will allow the project to be reflected in the
Agency’s Annual report to OMB summarizing peer review activities.  

Entries should clearly indicate whether or not the survey under
development will yield data that is expected to be "highly influential."
 According to EPA’s Science Policy Council Peer Review Handbook,
influential scientific or technical work products are those expected to
have “a major impact, [involve] precedential, novel, and/or
controversial issues, or the Agency has a legal and/or statutory
obligation to conduct a peer review.”  Highly influential scientific
assessments are those that “could have a potential impact of more than
$500 million in any year,” or that are considered “novel,
controversial, or precedent-setting or has significant interagency
interest.”  Our reading of these definitions would place all surveys
in the “influential scientific assessments” category. The
classification of a specific survey as “highly influential” will
need to be determined on a case by case basis.  Most surveys developed
specifically for direct input into an economic analysis for a rule or
regulation will be considered “highly influential.” However, other
survey activities could also be considered “highly influential”
depending on the subject matter. 

Supporting statements, clearly indicating peer review plans, must
accompany each request.  Individuals or teams wishing to submit a
project for consideration under this generic ICR must submit a draft
supporting statement for review by the standing panel.  Since focus
group results are not expected to yield data that can be analyzed
statistically, only Part A of the supporting statement will be expected.

In addition to the other standard requirements of the supporting
statement, the document should clearly describe the need for and purpose
of the project as well as the projected peer-review plan to assess the
quality of any resulting survey instruments.  For highly influential
projects, an external peer review panel process, as recommended by the
EPA Peer Review Handbook, will be expected under this generic ICR.  This
panel review could take one of two forms: periodic consultations with
experts in the field throughout the survey development process or a
panel review of the survey development process in advance of submitting
an ICR to OMB should the project advance to that stage.  

Time-lines for project completion should accompany the supporting
statement, highlighting hard deadlines where they exist. In assessing
the project, the review panel will consider whether in their view there
is sufficient and reasonable time to complete the survey development
given these timing constraints.  As separate ICR approval will be
required for administration of the survey once developed, the submitted
timeline should reflect the date by which the project team expects to
file the ICR for anticipated survey administration.

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