1
Information
Collection
Request
Supporting
Statement
 
Part
A
1.
Identification
of
the
Information
Collection
1(
a)
Title
of
the
Information
Collection
Delisting
the
Fish
Tainting
Beneficial
Use
Impairment
in
the
Saginaw
River/
Bay
Area
of
Concern
1(
b)
Short
Characterization/
Abstract
Chemical
odors
and
tastes
associated
with
harvested
fish
were
frequently
reported
from
the
1940s
through
the
1970s
in
the
Saginaw
and
Tittabawassee
Rivers,
and
in
the
Saginaw
Bay.
In
the
1994
Remedial
Action
Plan
Update,
the
Michigan
Department
of
Natural
Resources
reported
that
no
off­
flavor
was
detected
in
taste
tests
conducted
on
fish
taken
from
these
waters.
Since
taste
and
odor
complaints
related
to
edible
fish
taken
from
both
Saginaw
River
and
Bay
have
disappeared
in
recent
years,
this
project
will
conduct
a
survey
of
local
residents
and
anglers
to
determine
if
taste
and
odor
problems
in
fish
fillets
have
abated
to
the
extent
that
delisting
of
the
beneficial
use
impairment
may
be
recommended
for
the
Area
of
Concern
(
AOC).

2.
Need
for
and
Use
of
the
Collection
2(
a)
Need/
Authority
for
the
Collection
The
Saginaw
River
and
Bay
was
designated
by
the
International
Joint
Commission
(
IJC)
as
one
of
the
major
pollution
areas
in
the
Great
Lakes
in
1973,
a
year
after
the
first
Great
Lakes
Water
Quality
Agreement
between
the
United
States
and
Canada
was
signed
 
a
commitment
by
both
countries
to
cooperatively
manage
their
shared
water
resources
and
recommend
actions
for
protection.
Objectives
were
specified
that
would
reduce
nuisance
conditions
and
the
discharge
of
substances
toxic
to
human,
animal,
and
aquatic
life.
Saginaw
River/
Bay
was
designated
as
one
of
43
Areas
of
Concern
(
AOCs)
because
degraded
water
quality
conditions
impaired
certain
beneficial
uses
as
defined
by
the
Agreement.
The
1988
Saginaw
River/
Bay
RAP
cited
12
impairments
of
the
14
categories
specifically
listed
by
the
IJC
for
the
Saginaw
River/
Bay
AOC,
including
tainting
of
fish
(
i.
e.,
taste
and
odor
concerns).

2(
b)
Practical
Utility/
Users
of
the
Data
Taste
and
odor
complaints
related
to
fish
taken
from
either
Saginaw
Bay
or
the
lower
portions
of
the
Saginaw
River
watershed
have
nearly
disappeared
in
recent
years.
Given
the
magnitude
of
the
historical
problem
of
fish
tainting
in
the
bay
and
the
river,
a
survey
of
anglers
and
community
representatives
will
be
conducted
to
determine
if
a
significant
problem
still
exists,
and
if
it
does,
whether
it
is
confined
to
specific
areas
where
contributing
sources
can
be
addressed.
The
State
of
Michigan
may
petition
for
delisting
of
the
fish
tainting
BUI
if
the
project
confirms
that
restored
conditions
are
being
met.
2
EPA
will
also
use
the
information
received
to
monitor
the
progress
of
cleanup
activities
taking
place
in
the
watershed.

3.
Non
duplication,
Consultations,
and
Other
Collection
Criteria
3(
a)
Non
duplication
All
information
requested
from
respondents
under
this
ICR
can
be
broken
into
2
samples:
general
population
and
anglers
within
the
Saginaw
Bay
Watershed.

3(
b)
Public
Notice
Required
Prior
to
ICR
Submission
In
compliance
with
the
1995
PRA,
any
agency
developing
a
non­
rule
related
ICR
must
solicit
public
comments
for
a
60­
day
period
prior
to
submitting
the
ICR
to
OMB.
The
announcement
of
a
public
comment
period
for
an
initial
or
renewal
ICR
must
be
made
in
the
Federal
Register.
The
60­
day
comment
period
was
initiated
on
Dec.
16,
the
date
the
FR
Notice
was
published.

3(
c)
Consultations
No
respondents
have
been
consulted
concerning
this
ICR.

3(
d)
Effects
of
Less
Frequent
Collection
This
collection
is
one
time
only
 
it
will
not
have
periodic
reporting
or
record
keeping.

3(
e)
General
Guidelines
This
collection
does
not
violate
any
OMB
guidelines.

OMB
guidelines:

Justify
any
provision
under
which
respondents
would:


Report
information
to
the
Agency
more
often
than
quarterly

Prepare
a
written
response
to
a
collection
of
information
in
fewer
than
30
days
after
receipt
of
a
request

Submit
more
than
an
original
and
two
copies
of
any
document

Retain
records,
other
than
health,
medical,
government
contract,
grant­
in­
aid,
or
tax
records
for
more
than
three
years

Participate
in
a
statistical
survey
that
is
not
designed
to
produce
data
that
can
be
generalized
to
the
universe
of
the
study

Utilize
a
statistical
data
classification
that
has
not
been
reviewed
and
approved
by
OMB
3

Receive
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

Submit
proprietary,
trade
secret,
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.

3(
f)
Confidentiality
All
collected
information
will
be
stored
on
contractor
(
Public
Sector
Consultants
Inc.)
personal
computers.
Other
than
EPA
staff,
only
the
contractor
will
be
viewing
this
information.
All
hardcopies
will
be
stored
on
contractor
premises.

3(
g)
Sensitive
Questions
There
are
no
sensitive
questions
asked
in
this
questionnaire.

4.
The
Respondents
and
the
Information
Requested
4(
a)
Respondents/
SIC
Codes
All
respondents
to
this
ICR
will
be
members
of
the
general
public,
including
anglers
and
non­
anglers.
SIC
codes
do
not
apply
in
this
instance.

4(
b)
Information
Requested
i)
Data
items,
including
record
keeping
requirements
All
record
items
are
reporting
items
 
records
will
not
need
to
be
retained
by
respondents.
The
respondents
will
need
to
complete
a
questionnaire
and
return
it
to
the
contractor
for
analysis.

ii)
Respondent
Activities
Members
of
the
public,
including
anglers,
will
receive
the
questionnaire
via
U.
S.
Mail.
The
respondents
will
need
to
review
the
survey's
purpose
and
brief
instructions
in
order
to
complete
the
questionnaire.
The
questions
that
are
being
asked
should
be
easily
answered
by
the
respondents.
The
respondents
will
then
need
to
transmit
the
completed
questionnaire
back
to
the
contractor
in
a
postage­
paid
return
envelope.

5.
The
Information
Collected
 
Agency
Activities,
Collection
Methodology,
and
Information
Management
4
5(
a)
Agency
Activities
Agency
activities
associated
with
completing
the
public
questionnaire
consist
of
the
following:

Review
and
approve
questionnaire
developed
by
contractor;
Review
survey
analysis
conducted
by
contractor;
Review
and
approve
recommendations
resulting
from
the
survey
data.
Distribute
survey
results
to
EPA
program
managers
and
the
Michigan
Department
of
Environmental
Quality
5(
b)
Collection
Methodology
and
Management
In
collecting
and
analyzing
the
information
associated
with
this
ICR,
the
contractor
will
use
a
hardcopy
survey
distributed
via
U.
S.
Mail.
EPA
will
oversee
the
contractor
to
ensure
the
accuracy
and
completeness
of
collected
information
by
reviewing
data
collection
and
analysis
techniques.
Postage­
paid
envelopes
will
be
provided
to
respondents
to
return
the
completed
questionnaire.

5(
c)
Small
Entity
Flexibility
No
small
entities
are
required
to
respond
to
this
collection
request.
It
is
a
survey
of
the
general
public.

5(
d)
Collection
Schedule
The
following
dates
reflect
the
intended
dates
associated
with
this
information
collection.

These
dates
are
only
estimates.

Questionnaire
sent
out
to
proposed
respondents:
August
15,
2005
Due
date:
September
15,
2005
6.
Estimating
the
Burden
and
Cost
of
the
Collection
6
(
a),
(
b)
Annual
Respondent
Burden
and
Cost
EPA
estimates
no
financial
burden
nor
costs
for
respondents.
There
is
no
equipment,
machinery
and/
or
construction
necessary
for
this
information
request;
therefore
there
are
no
capital
and/
or
operations
and
maintenance
costs
associated
with
this
ICR
for
the
respondents
or
the
Agency.
Respondents
will
be
provided
a
postage­
paid
envelope
to
return
the
mail
survey.

6
(
c)
Estimating
Agency
Burden
and
Cost
EPA
estimates
an
average
hourly
labor
cost
of
$
70.00
for
managerial
staff
and
$
45.00
for
technical
staff.

6
(
d)
Estimating
the
Respondent
Universe
and
Total
Burden
and
Costs
5
Estimating
the
respondent
universe:
There
is
a
total
of
7,680
surveys
that
will
be
mailed.
There
is
no
financial
burden
nor
costs
to
survey
respondents.

6
(
e)
Bottom
Line
Burden
Hours
The
development
of
the
survey
instrument,
mailing
lists,
and
mailing
costs
are
estimated
to
total
$
12,300.
Thus
EPA's
cost
burden
is
$
12,300
because
the
survey
is
being
conducted
by
a
private
contractor.

6
(
f)
Burden
Statement
The
respondent
burden
is
estimated
to
average
.5
hours
per
respondent.
A
total
of
1,536,
or
20
percent,
of
respondents
are
expected
to
reply
to
this
request.
This
estimate
includes
completing
the
questionnaire
by
and
sending
it
back
to
the
contractor.

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
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
are
listed
in
40
CFR
Part
9
and
48
CFR
Chapter
15.

Information
Collection
Request
Supporting
Statement
 
Part
B
1)
Introduction
The
goal
of
this
project
is
to
assess
current
taste
and
odor
concerns
relating
to
locally
caught
fish
in
the
Saginaw
River/
Bay
Area
of
Concern.
Survey
research
will
be
used
to
assess
public
opinion
relating
to
chemical
odors
and
tastes,
associated
with
fish
harvested
in
the
Saginaw
River,
the
Tittabawassee
River,
and
Saginaw
Bay
(
frequently
reported
from
the
1940s
through
the
1970s).
The
outcome
of
the
survey
research
will
dictate
next
steps.
A
petition
for
delisting
of
the
fish
tainting
BUI
will
be
initiated
if
the
project
confirms
that
restored
conditions
are
being
met.
If
a
significant
problem
still
exists,
the
survey
design
will
be
able
to
identify
specific
areas
where
contributing
sources
remain
and
recommend
actions.

2)
Sections
1
and
2:
Survey
Objectives,
Key
Variables,
and
Survey
Design
6
Survey
Objectives
A
survey
of
anglers
and
community
representatives
will
be
conducted
to
determine
if
fish
tainting
and
odors
still
exists
in
edible
fillets,
and
if
it
does,
whether
it
is
confined
to
specific
areas
where
contributing
sources
can
be
addressed.
A
petition
for
delisting
of
the
fish
tainting
BUI
will
be
initiated
if
the
project
confirms
that
restored
conditions
are
being
met.

Key
Variables
Fishermen
are
likely
to
have
opinions
about
the
quality
of
fishing
in
the
watershed,
whether
they
are
actively
fishing
the
area
or
are
merely
talking
to
friends
who
are
actively
fishing
the
area.
If
fishermen
themselves
do
not
perceive
an
increase
in
the
quality
of
fish
stock
or
decreases
in
the
problems
with
taste
and
odor,
then
the
project
is
not
likely
to
succeed.
However,
talking
only
to
fishermen
is
likely
to
yield
a
biased
read
of
public
opinion
 
statewide,
fishing
licenses
are
sold
to
one
of
every
ten
residents.
Therefore,
the
project
managers
and
the
EPA
cannot
use
the
survey
results
as
a
definitive
guide
to
what
the
public
perceives,
since
roughly
90
percent
are
not
fishermen.

A
potential
divide
between
the
opinions
of
fishermen
and
the
general
public
on
issues
of
contamination
and
fish
quality
is
no
more
or
less
likely
than
differences
in
opinion
between
any
group
with
specialized
knowledge
and
the
general
public.
This
project,
however,
complicates
or
exacerbates
the
potential
divide
in
two
ways:

 
Environmental
issues,
especially
ones
that
seek
to
declare
a
past
problem
"
solved"
or
"
remediated",
are
often
accompanied
by
intense
public
opinion
that
may
often
be
based
on
past
knowledge/
perceptions
rather
than
the
current
situation.
Therefore,
any
debate
may
need
to
be
coordinated
with
an
education/
outreach
campaign
to
educate
the
general
public
on
how
conditions
have
changed
from
previous
years.

In
this
specific
area,
there
is
an
existing
water
quality
issue
in
the
Tittabawassee
River
surrounding
the
potential
contamination
with
Dioxin
from
the
nearby
Dow
Chemical
Company
manufacturing
facility.
This
issue
has
been
extremely
visible
in
the
local
community
as
a
result
of
Department
of
Environmental
Quality
and
EPA
efforts
to
negotiate
a
cleanup
settlement.
Therefore,
conducting
a
companion
survey
of
the
general
public
will
help
 
gauge
their
general
knowledge
of
improved
water
quality
issues
in
the
watershed
and
fish
stock
(
as
existing/
potential
consumers
of
locally­
caught
fish),

 
test
whether
(
and
how
strongly)
the
public
links
the
dioxin
issue
to
the
delisting
issue,
even
if
the
two
are
scientifically
unrelated,
and
 
examine
public
opinion
about
delisting
in
particular.
7
A
general
public
survey
alone,
however,
would
overstate
the
perception
of
precisely
the
members
of
the
public
that
lack
the
specialized
knowledge
 
remember,
only
approximately
1
in
10
Michigan
residents
have
a
fishing
license.
A
combination
approach
that
seeks
to
elicit
and
examine
the
perceptions
of
both
fishermen
and
the
general
public
will
provide
the
best
information
to
the
project
team.

Survey
Design
Survey
Design
Development,
production,
and
execution
of
survey
instrument
(
single
page,
2
sides),
data
analysis,
report
writing,
and
petition
for
delisting
(
if
applicable)
will
be
conducted.
The
critical
test
for
any
such
process
and
associated
criteria
is
to
insure
that
it
is
rigorous,
scientifically
defensible,
and
allows
for
full
review
and
comment
from
interested
and
affected
stakeholders.

Two
samples
 
all
type
1
counties
(
regardless
of
size)
and
all
type
2
counties
(
regardless
of
size)
will
be
drawn.
Both
groups
have
well
over
100,000
people
(
population
and
fishermen),
so
rules
of
large
samples
apply.
Surveying
either
population
for
each
county
type
requires
384
interviews
with
a
margin
of
error
of
+/­
5
percent.
Therefore,
4
surveys
(
type
1&
2,
fishermen
and
population)
would
require
1,536
completed
interviews
(
384
x
4
=
1,536).
To
achieve
the
20
percent
response
rate,
7,680
surveys
(
1,536
/
.2
=
7,680)
will
be
mailed.
8
Category
County
Fish
License
Sales
Population
(
2000
Census)
Sales
per
1,000
people
1­
large
Bay
21,088
110,157
191
1­
large
Genesee
36,726
436,141
84
1­
large
Midland
11,488
82,874
139
1­
large
Saginaw
19,360
210,039
92
1­
mid
Isabella
8,316
63,351
131
1­
mid
Tuscola
6,727
58,266
115
1­
small
Arenac
8,824
17,269
511
1­
small
Gladwin
8,818
26,023
339
2­
large
Lapeer
7,620
87,904
87
2­
large
Livingston
13,553
156,951
86
2­
large
Oakland
53,835
1,194,156
45
2­
mid
Gratiot
4,502
42,285
106
2­
mid
Mecosta
12,810
40,553
316
2­
mid
Montcalm
12,200
61,266
199
2­
mid
Sanilac
5,627
44,547
126
2­
mid
Shiawassee
6,149
71,687
86
2­
small
Clare
14,954
31,252
478
2­
small
Huron
11,648
36,079
323
2­
small
Iosco
21,752
27,339
796
2­
small
Ogemaw
7,111
21,645
329
2­
small
Osceola
5,091
23,197
219
2­
small
Roscommon
23,335
25,469
916
Total
321,534
2,868,450
112
When
grouped,
the
totals
look
like
this:

Category
Population
License
sales
1­
large
839,211
88,662
1­
mid
121,617
15,043
1­
small
43,292
17,642
Total,
type
1
1,004,120
121,347
2­
large
1,439,011
75,008
2­
mid
260,338
41,288
2­
small
164,981
83,891
Total,
type
2
1,864,330
200,187
The
distribution
of
both
population
and
sales
when
grouped
is
good
news
on
the
survey
side;
all
categories
have
at
least
15,000
data
points,
which
is
plenty
to
draw
a
sample
from.
