Supporting Statement

Tribal Capacity:  Determining the Capability to Participate in the
National Environmental Information Exchange Network

U.S. Environmental Protection Agency

October 2008Table of Contents

	Page

Part A of the Supporting Statement	1

Identification of the Information Collection	1

Title of the Information Collection	1

Short Characterization/Abstract	1

Need for and Use of the Information Collection	1 

Need/Authority for the Information Collection	1

Practical Utility/Users of the Data	2

Non-duplication, Consultations, and Other Collection Efforts	2

Non-duplication	2

Public Notice Required Prior to ICR Submission to OMB	2

Consultations	3

Effects of Less Frequent Collection	3

General Guidelines	3

Confidentiality	3

Sensitive Questions	3

The Respondents and the Information Requested	3

Respondents’ NAICS Codes	3

Information Requested	3

The Information Collected – Agency Activities, Collection Methodology,


	and Information	3	

Agency Activities	3

Collection Methodology and Management	4

Small Entity Flexibility	4

Collection Schedule	4

Estimating the Burden and Cost of the Collection	4

Estimating Respondent Burden	4

Estimating Respondent Costs	4

Estimating Agency Burden and Costs	4

Burden Statement	5

Part B of the Supporting Statement	5 ICR Supporting Statement

Part A of the Supporting Statement

This Supporting Statement is for EPA ICR number 2299.01, Tribal
Capacity:  Determining the Capability to Participate in the National
Environmental Information Exchange Network, OMB Control No. 2025-new. 
As required by the Paperwork Reduction Act (PRA) (44, U.S.C. 3501 et
seq.), EPA has solicited comments on specific aspects of the proposed
information collection and, receiving none, is submitting the ICR to OMB
for review and approval.

Identification of the Information Collection:  

Collection Title:  Tribal Capacity:  Determining the Capability to
Participate in the National Environmental Information Exchange Network.

Abstract:  The National Environmental Information Exchange Network
(Exchange Network) is an Internet-based approach to exchange
environmental data among partners, specifically states, territories and
tribes.  Built on the principles of applying data standards; providing
secure, real-time access; and electronically collecting and storing
accurate information, the Exchange Network enables participants to
control and manage their own data while making it available to partners
via requests over a secure Internet connection.  By facilitating the
efficient exchange of environmental information among interested parties
at all levels of government, the Exchange Network has begun to transform
the way information is shared.  

While some Indian Tribes have been active partners in the Exchange
Network, overall tribal participation is limited.  EPA has issued grants
that fund infrastructure and other support needed to share data on the
Network to just over 50 tribes or less than 10 percent of the more than
500 federally recognized tribes.  Of these, eight have exchanged data
over the Network and another five are developing the infrastructure
required to do so.

To expand tribal participation in the Exchange Network, EPA has been
working with the National Congress of American Indians (NCAI) under a
series of cooperative agreements.  NCAI is planning to conduct a
baseline assessment survey to obtain data to help identify barriers and
other factors that are limiting tribal participation in the Network. 
The survey will focus on gathering information related to collection and
dissemination of environmental data; information technology
infrastructure, capacity, and needs; and awareness of the Exchange
Network.  The survey will be distributed to all federally recognized
tribes that are members of NCAI.  Response to the survey is voluntary. 
NCAI will use the findings of this survey to design programs to broaden
tribal participation.

Need for and Use of the Information Collection

Need/Authority for the Information Collection:  EPA plans to use a
survey questionnaire, administered by and to the constituency/membership
of the National Congress of American Indians, in order to design
programs to broaden tribal participation in the Exchange Network. 

Since 2002, the U.S. EPA has been supporting the implementation of the
Exchange Network through its National Environmental Information Exchange
Network Grant Program. The program provides funding for states,
territories, and Federally Recognized Indian tribes and has played an
enormous role in the current success of the Exchange Network. 

Increased tribal participation in the Network will improve environmental
decision making and further environmental results nationwide. 

Practical Utility/Users of the Data:  EPA will use the data collected
through this survey to strengthen tools available to tribes to further
environmental information management objectives of the Exchange Network
and improve environmental decision making on and around Indian lands. 
These improved tools will facilitate tribal participation in the Network
and will make tribal data accessible to all Network partners, public and
private sector decision makers, and the public.

Non-Duplication, Consultations, and Other Collection Criteria

Non-Duplication:  The Office of Information Collection of the Agency’s
Office of Environmental Information has made every reasonable attempt to
ensure that this survey does not request data and information currently
available through less burdensome mechanisms.  EPA continues to work
closely with the National Congress of American Indians to obtain the
best available information on tribal participation in the Exchange
Network and tools needed to facilitate this participation.  NCAI has
developed the appropriate survey mechanism to elicit the needed
stakeholder information with the minimum amount of burden on their
tribal members.

Public Notice:  EPA published the PRA-required Federal Register notice
on May 12, 2008, announcing our intent to conduct a baseline assessment
survey of tribal stakeholders in the Exchange Network through the
National Congress of American Indians (NCAI).  The comment period under
this notice was 60 days.  

Pursuant to section 3506(c )(2)(A) of the Paperwork Reduction Act, EPA
specifically solicited comments and information to enable us to:

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.

Evaluate the accuracy of the Agency’s estimate of burden of the
proposed collection of information, including the validity of the
methodology and assumptions used.

Enhance the quality, unity, and clarity of the information to be
collected.

Minimize the burden of the collection of information on those who are to
respond.

EPA received no comments to the May 2008 Federal Register notice
regarding the Tribal Capacity survey.  No major revisions to the survey
tool were, therefore, required or made.

Consultations:  As previously stated, the Agency continues substantive
dialogue with the National Congress of American Indians, through its
existing cooperative agreement, to determine the need for, expectations
of, and data analysis expected through this information collection.  
Additionally, discussions of this survey and potential improvements
garnered from it have been presented to the Exchange Network Leadership
Council (ENLC) and the Information Management Work Group (IMWG) to fully
meet the priorities reflected in the “Exchange Network Strategic
Plan,” July 2007.  

Effects of Less Frequent Collection:  The Tribal Capacity ICR is a one
time only data collection activity for the respondents.

General Guidelines:  EPA will conduct data collection, through NCAI, in
accordance with the Paperwork Reduction Act guidelines in 5 CFR 1320.6
and EPA’s Quality Assurance Guidance.  Information to be disseminated
will comply with EPA’s Information Quality Guidelines, which were
developed for implementing OMB’s Guidelines for Ensuring and
Maximizing the Quality, Objectivity, Utility, and Integrity of the
Information Disseminated by Federal Agencies.

Confidentiality:  EPA and NCAI have developed the survey tool to
eliminate responses which contain Personally-Identifiable Information or
Confidential Business Information.  No confidential information is
requested within the survey.

Sensitive Questions:  No sensitive questions pertaining to private or
personal information will be asked in the survey.

Respondents and Information Requested

Respondents NAICS Codes:  NCAI will notify its membership of
federally-recognized tribes of the availability of the survey mechanism.
 Federally-recognized tribes are classified under the North American
Industry Classification System (NAICS) identification number 921150,
American Indian and Alaska Native Tribal Governments.

Information Requested:  The NCAI survey tool is attached to this
Supporting Statement.  EPA, through its cooperative agreement with NCAI,
plans to conduct a survey to collect and understand current tribal
collection, exchange, security and submission of environmental data. 
The survey will also request information on availability of IT staff,
dedicated data systems, and future needs to improve environmental data
management.  

NCAI and EPA designed the questionnaire to include many burden-reducing
features.  To that end, most questions are multiple-choice with comment
fields to provide tribe-specific information in support of the answer. 
Analysis will utilize the multiple-choice answers as well as the
substance of the comments included in each response.

Information Collected – Agency Activities, Collection Methodology, and
Information

Agency Activities:  EPA, in cooperation with NCAI, has developed the
attached survey tool, sought public comment, developed this ICR,
collaborated with the ENLC and IMWG, and discussed potential analysis
and programmatic recommendations resulting from this survey.  NCAI will
distribute the survey, provide assistance to respondents in completing
their responses, receive and review responses, and summarize and analyze
data resulting from the survey responses.  Following this analysis, NCAI
will make recommendations to EPA on programmatic improvements to
increase tribal participation in the Network.  EPA will present program
changes to the ENLC and IMWG for review and approval.

Collection Methodology and Management:  NCAI will notify its membership
of the survey mechanism, available through the “Survey Monkey”
website, and provide hard copy (if requested) to respondents unable to
use the online tool.  Respondents will be offered 60 calendar days in
which to respond to the survey.

Small Entity Flexibility:  The survey has been designed to facilitate
responses from tribal environmental data/program managers.  Most
respondents will represent small tribal governments with limited
resources.  EPA and NCAI continue to collaborate to reduce the burden of
responding on these small entities.

Collection Schedule:  Upon approval by OMB, the survey will be provided
to NCAI’s membership within 30 calendar days.  Following the 60
calendar day response period, NCAI expects to make recommendations to
EPA on programmatic improvements within 90 calendar days of the end of
the response period.  EPA expects to implement any changes within the FY
2010 National Environmental Information Exchange Network Grants program.

Estimating the Burden and Cost of the Collection

Respondent Burden:  NCAI will provide the survey to the more than 350
tribal governments that are NCAI members.  The annual public reporting
and recordkeeping burden for this collection of information is estimated
to average 30 minutes per response.  Additionally, NCAI will provide
assistance to its entire membership to increase the response rate to the
survey and reduce the burden of finalizing responses. 

 

Respondent Costs:  The direct labor cost to respondents to complete the
survey equals the time to read and understand the questions, gather the
information, and complete the survey form.  The non-labor costs each
respondent will incur include access and use to a computer with an
Internet connection.  Labor costs will comprise the majority of the
financial burden imposed on respondents.  Because EPA will not require
respondents to purchase any goods, including equipment or machinery, to
respond to the survey, we do not expect capital costs to result from
completing the survey.  

Agency Burden and Costs:  Burden and costs for collection and analysis
of data resulting from this survey will be borne by NCAI under
cooperative agreement with EPA.  Increasing tribal participation in the
Exchange Network is an identified task under the Cooperative Agreement. 
No costs to EPA are expected beyond invoiced time and labor under the
Cooperative Agreement.

Burden Statement:  The survey will be distributed to over 350 federally
recognized tribes that are members of NCAI.  Response to the survey is
voluntary.  EPA and NCAI estimate a total of 250 potential respondents,
each responding once to this one-time only survey.  The estimated total
burden is 125 hours.  No additional costs are expected.

##########

Part B of the Supporting Statement							

Questionnaire Objectives, Key Variables, and Other Preliminaries 

Objectives:  NCAI will use questionnaire information to expand
participation in the Exchange Network from tribal partners and increase
customer satisfaction from this constituency.   

 

Key Variables:  The questionnaire attempts to understand individual
tribe’s environmental information collection needs, storage methods,
submission processes, and exchange mechanisms.  By understanding these
variables, NCAI will be better prepared to offer process improvements to
increase tribal participation and improve environmental data management.
 

Other Preliminaries:  NCAI will provide the questionnaire to the over
350 tribes currently members of their organization.  They will make
calls and provide hardcopy surveys to those tribal organizations unable
or unwilling to fill out the survey online.  The survey has been
developed in SurveyMonkey and been assigned EPA form number 5800-01. 
NCAI will note within their distribution emails and listserves that
participation in this survey is voluntary.    

Statistical Approach for the Survey.  NCAI expects a very high response
rate to the questionnaire.  NCAI will analyze the individual surveys for
themes which may generate recommendations to improve participation in
the Exchange Network.  No statistical limitations on responses will be
necessary.

Pretests and Pilot Tests.  NCAI previously surveyed their membership on
topics of common concern to determine current and future needs of their
constituency.  No pre-tests or pilots will be necessary for this
questionnaire.  Recommendations will be made from the survey data based
on tribal needs, Exchange Network strategic goals, and NCAI knowledge of
their members.

Collection Methods and Follow-Up.  The SurveyMonkey tool is attached to
this Supporting Statement.  A link to the questionnaire will be sent to
each member tribe of NCAI and will be highlighted on the NCAI website. 
NCAI meetings, conventions, conference calls, and direct calls to tribes
will be used to ensure the widest possible audience has the opportunity
to respond to the survey.  

 

Data Preparation and Analysis.  NCAI will analyze individual surveys for
themes which may generate recommendations to improve participation in
the Exchange Network.  Network governance bodies (e.g., ENLC, NOB) will
be notified of the results of this survey and provided recommendations
that may increase tribal participation within the Exchange Network. 
Cross-media and cross-government solutions will be sought to efficiently
broaden the Exchange Network across all levels of government.

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