A.	Justification

1.	Necessity of Information Collection

On January 21, 2009, President Obama signed a memorandum on Transparency
and Open Government.  The memorandum directed Departments and Agencies
to promote transparency by using new technologies, by increasing
opportunities to participate in policymaking, and by expanding
collaboration among Agencies, across governments, and with external
groups and individuals.  

The eRulemaking Program, an inter-agency program led by the
Environmental Protection Agency and authorized under Section 206 of the
Electronic Government Act of 2002, operates   HYPERLINK
"http://www.regulations.gov"  www.regulations.gov  .  Regulations.gov is
a citizen-focused website that provides the public the ability to find,
view, download, bookmark, receive email alerts, establish RSS feeds, and
submit comments on proposed rulemakings and other federal actions that
solicit public comment.  Regulations.gov currently provides access to
more than 2 million documents, supports 32 partner Departments and
Agencies which promulgate more than 90% of the federal government’s
annual rulemakings, and receives millions of hits and tens of thousands
of comments each month.  Since September 2005, Regulations.gov has
received more than 250 million hits and received more than 750,000
public comments.  

In response to the Presidential memorandum, the eRulemaking Program
plans to launch the Regulations.gov ‘feedback exchange’ web site in
May 2009.  This interactive web site will showcase new technologies
being considered for Regulations.gov.   The ‘feedback exchange’ will
serve as an online environment for open government and transparency, as
it enables the public to provide direct input on future improvements to
the Regulations.gov interface, promotes innovation and collaboration,
and ensures that the eRulemaking Program can efficiently manage federal
resources by testing new tools before they are launched. 

What will it do?   The Regulations.gov ‘feedback exchange’ website
will provide the public with a preview of new technologies being
considered for Regulations.gov.   It will also enable the public to
provide feedback on these technologies.  Technologies that could be
considered for the Regulations.gov ‘feedback exchange’ include: User
Profiles; Comment Threads and Wikis; Ratings, Polls, and Tagging; an
interactive Educational Tool; and an Information Export capability.  
These technologies would be deployed iteratively, with components
deployed upon the site’s release in May 2009 and during subsequent
upgrades to the web site.   User profiles enable the public to register
on the site and pre-load submitter information for later use as well as
save their own personalized searches, RSS feeds, and email alerts
without the use of persistent cookies.  Comment Threads allow the public
to enter into virtual conversations with one another about a topic.  
Wikis enable the public to collaboratively develop and modify narrative
descriptions about a topic.   Ratings and Polls allow the public to
indicate a preference for a topic or issue via the selection of stars or
thumbs up / thumbs down icons which graphically provide an at-a-glance
indication of public sentiment and can simplify navigation.   Tagging
provides the public with the ability to tag or label information they or
someone else has posted to the site to ease navigation and to promote
the formation of common interest categories.   The Educational Tool will
inform the public about the Federal rulemaking process through
interactive text and images.  The Data Export capability enables the
public to download and review the contents of a rulemaking docket as
well as mix and match such information with other information in a new
way (also known as a “mash-up”).  The Regulations.gov “feedback
exchange” will rely on feedback from Government, Industry, Academia
and Citizenry to improve Regulations.gov as time goes on.  

What are the Benefits?  As part of the president's pledge to make the
government more open and transparent, the Regulations.gov “feedback
exchange” web site will be the citizen's back stage pass to shape and
drive the evolution of the federal government’s premier public access
rulemaking web site.  Citizens will be able to participate in an open
dialogue on the design, format, and functionality of Regulations.gov. 
Sitting in the director’s chair, the public will be able to clearly
identify and see other ideas on the kinds of new Internet technologies
it would like Regulations.gov to use to access, participate in, and
understand federal rulemaking.  

The ‘feedback exchange’ also can serve as a laboratory to explore
the statutory and policy impacts of emerging Internet technologies on
the federal rulemaking process, fostering innovative approaches to
involve citizens in federal decision-making.   Enhancing access to
rulemaking information through new forms of communication and
collaboration can help transform government and realize the vision of
and open and transparent government by "democratizing" regulatory
decisions.  The site will be continuously operated and maintained to
freely interact and solicit feedback with the Public to promote
innovation through engagement.

Finally, the Regulations.gov ‘feedback exchange’ will conserve
taxpayer resources through a low-cost, controlled approach to pilot and
evaluate new technologies before they are deployed on the live
Regulations.gov web site.

What information collections are needed?  This information collection
request is being submitted in order to fulfill the citizen engagement
and feedback aspects of this important initiative.  The end users will
be provided opportunities to provide information feedback and ratings in
fulfillment of the President’s open government and transparency
agenda.  This information collection request will enable these
capabilities to be included on the Regulations.gov ‘feedback
exchange’.  The four elements addressed in this information collection
request are a five star rating system, a request for user email and URL
address on the registration section, support for the ability of users to
tag or label content on the site, and support/oppose functionalities
that are proposed by the federal government for Regulations.gov.  

Rating  The rating system seeks to give visitors the ability to identify
which topics or functionalities and user comments visitors found most
useful and interesting.  The ability to provide ratings on Internet
sites is commonplace and routine for web sites that provide information,
allow public browsing, support public interaction, and enable
categorization. Ratings provided by users would not be in response to
specific questions, but rather would solicit the users’ reaction to a
topic or specific functionality.  A rating of 1 star would indicate a
low priority or preference for a topic or functionality while a rating
of 5 stars would indicate a high priority or preference for a topic or
functionality.   Site visitors could then view the top rated topics or
system functionalities ranked by other users (for example, a visitor
could view the top five highest rated functionalities or the top five
highest rated visitor comments). 

Registration  The web site registration capability seeks to give
visitors the ability to establish ‘profiles’ on the site to support
user-defined tailoring of information and features to meet his or her
needs.  Registration is common and routine for web sites that provide
information, allow public browsing, support public interaction, and
enable categorization.  For the Regulations.gov ‘feedback exchange’,
visitors will be able to voluntarily register on the site by providing
their email address, user name, and relative URLs.  

Tagging  The tagging or labeling capability seeks to give visitors the
ability to self-identify information about themselves (e.g.,
Professional Category, such as ‘Academic / Professor”) or to label
or categorize information they provided or others provided.  Tagging is
common and routine for web sites that provide information, allow public
browsing, support public interaction, and enable categorization. For the
Regulations.gov ‘feedback exchange’, visitors will be able to
voluntarily select tags or labels about themselves and create tags about
information they have submitted or others have submitted.  

Support or Oppose Comment Form  The ‘support or oppose’ comment form
seeks to give visitors the ability to enter comments that are
categorized as ‘support’ or ‘oppose’. These fields enable
categorization of comments.  For the Regulations.gov ‘feedback
exchange’, visitors will be able to voluntarily enter text in comment
fields labeled ‘support’, ‘oppose’ or ‘general’ and which
are viewable by other visitors as such.  

2.	Needs and Uses

The ratings information collected from the public will help the
eRulemaking Program, the Office of Management and Budget, and the
Program’s partner Agencies understand how potential features presented
on the Regulations.gov ‘feedback exchange’ are valued by
respondents.  It is the intention of the eRulemaking Program team to
leverage the rating responses to provide feedback to the public as to
how the possible new functionalities and tools are collectively viewed
by those choosing to rate them.  The information will not be used to
generalize to all users or potential users.  

The email address collection on the Registration section is part of the
registration process to enable site visitors to provide comments, rate
content, or tag information. The email address field is required for
registration. During the system registration and user profile set-up
process, to satisfy security requirements, users receive a dynamic,
temporary URL to link back to the system and complete the user profile
registration. This security feature is required in order to log-in to
the system and use the user profile, due to the fact that federal
government websites cannot utilize persistent cookies. Users have the
option to sign up for e-mail notifications. The e-mail address required
for system registration is used for e-mail notifications only if the
user chooses to receive e-mail notifications. Topic discussions and
comments can still be viewed by those users who choose not to register.
The URL collection on the Registration section is also part of the
registration process to enable site visitors to provide access to
supplemental or related information. The URL address field is optional
for registration.

The information collected for tagging or the support / oppose comments
will be used by registered users to further categorize comments when
viewing information in the system. When users self-identify themselves,
it enables the eRulemaking Program to stratify and better understand the
needs of different user groups.  This is a common method to gauge and
understand customer feedback, for example, the American Customer
Satisfaction Index.  

3.	Efforts to Minimize Burden

To limit respondent burden, the rating questions are short, require only
a response of one star through five stars or a thumbs up / thumbs down,
and are purely voluntary.  The public is not required to provide its
ratings.  For those in the public who decide to participate, the
abbreviated list of questions and potential responses simplifies their
participation.

To limit the public’s burden on the site, users only need to provide
their email address to be able to submit comments, rate content, and tag
information and receive e-mail notifications.  The public is not
required to provide relative URL addresses.

Participation on the ‘favor or oppose’ comment form is not required
and can be completed on a voluntary basis.  Additionally, the form is
defined as a single field brief and makes use of selection boxes to
minimize the amount of text required to be entered for submission.  

Participation on the tagging or labeling functionality is not required
and can be completed on a voluntary basis.  Additionally, the form makes
use of selection boxes to minimize the amount of text required to be
entered for submission.  

4.	Efforts to Identify Duplication

Ratings relate specifically to possible new functionalities and tools
considered for   HYPERLINK "http://www.regulations.gov" 
www.regulations.gov  and do not duplicate what other agencies are doing.
 This is a new capability that does not exist within any other
inter-agency rulemaking and public notice and comment portals.  The
email and URL address fields on the Registration section enabling users
to create a user account is a new capability that does not exist within
any other rulemaking and public notice and comment portals.   Similarly,
the tagging or labeling functionality and the ‘favor or opposed’
comment form are new capabilities that do not exist within any other
inter-agency rulemaking and public notice and comment portals. 

5.	Minimizing Burden on Small Businesses

Small businesses are not specific targets of the Regulations.gov
‘feedback exchange’ rating efforts or information collection
efforts.  However, if they visit the Regulations.gov ‘feedback
exchange’ website they will be presented with the opportunity to
provide ratings, register on the site, submit narrative statement
feedback in favor of or opposed to a topic, and tag or label information
about themselves or a topic.  We ensure that rating questions and icons,
registration form, and tagging and labeling capabilities are not
redundant and include only requests for information relevant to the
specific data sets on the ‘feedback exchange’.

6.	Consequences of Less Frequent Collection

This clearance involves establishing a single type of rating to be used
for possible functionalities and tools on Regulations.gov, email and URL
address fields on the Registration section, fields allowing the public
to submit feedback in favor or opposed to a topic, and fields enabling
the public to tag or label information about themselves or a topic.  The
voluntary responses to these information collection opportunities will
determine the frequency of the information collection.

7.	Consistency with OMB Guidelines

The Environmental Protection Agency, as managing partner of the
inter-agency eRulemaking Program, will collect the information in a
manner that complies with OMB guidelines.

8.	Consultation Outside the Agency

The inter-agency eRulemaking Program has conferred with the Office of
Management and Budget, its 32 partner Departments and Agencies,
including the Program’s managing partner, to determine that the
ratings approach is desired, within scope of the Regulations.gov
‘feedback exchange’ project, and in alignment with the
Administration’s transparency and open government memorandum.  

The eRulemaking Program also has conferred with the Office of Management
and Budget and its 32 partner Departments and Agencies to determine that
the email/URL address fields on the Registration section, fields
allowing the public to submit feedback in favor or opposed to a topic,
and fields enabling the public to tag or label information about
themselves or a topic are all desired, within scope of the
Regulations.gov ‘feedback exchange’, and will provide value to the
public.  

9.	Paying Respondents

The federal government will not provide payment or other forms of
remuneration to respondents to its Regulations.gov ‘feedback
exchange’ information collections.

10.	Assurance of Confidentiality

The Regulations.gov ‘feedback exchange’ website will not provide
visitors with any assurance of confidentiality.  

11.	Justification for Sensitive Questions	

Questions are carefully composed and structured to avoid being sensitive
in nature to respondents.

12.	Estimate of Hour Burden

For the ratings, it is estimated that 5,000 ratings will be submitted,
on an annualized basis.  Each of the ratings is estimated to take 5
seconds and therefore it is anticipated that 417 minutes per year will
be required to submit the data set ratings.  Approximately 7 annual
burden hours are requested based on these estimations.  Based upon
similar ratings methods, we believe that this is an accurate estimate.

For the email and URL address fields on the Registration form, it is
estimated that 1,000 user profiles will be created each year.  It is
estimated that completing the email address field on the contact form
will take 10 seconds and therefore it is anticipated that 167 minutes
per year will be required to submit the email address field on the
contact form.  Approximately 3 annual burden hours are requested based
on these estimations.  Based upon similar contact form methods, we
believe that this is an accurate estimate.

For the tagging of content, it is estimated that 1,000 tags will be
submitted each year.  It is estimated that completing the tag will take
30 seconds and therefore it is anticipated that 500 minutes per year
will be required to submit the nomination form.  Approximately 8 annual
burden hours are requested based on these estimations.  Based upon
similar form methods, we believe that this is an accurate estimate.

For the submission of support or oppose comments, it is estimated that
1,000 support or oppose comments will be submitted each year.  It is
estimated that completing the nomination form will take 1 minute and
therefore it is anticipated that 1,000 minutes per year will be required
to submit the nomination form.  Approximately 17 annual burden hours are
requested based on these estimations.  Based upon similar form methods,
we believe that this is an accurate estimate.

Therefore the total burden for this ICR is 35 hours (7 hours for
ratings, 3 hours for email address, 8 hours for tagging content, and 17
hours for completing support or oppose comments).  The total number of
respondents is 1,000 and the total number of responses is 7,000.

13.	Estimate of Cost Burden

We do not expect respondents to incur any costs other than that of
their time expended.  The information requested is of the type and scope
normally provided online and without additional research time required. 
Therefore, respondents are not expected to incur any costs or burden for
responding to this voluntary rating procedure.

14.	Cost to Federal Government

Electronic surveys are virtually cost-free.  The Environmental
Protection Agency is incurring no additional costs for hosting the
information collection forms and will incur no additional costs for
storing the anticipated responses.  It is estimated that one federal
staff person will spend two hours a week to review and monitor the
comments posted on the site or total of 104 hours a year. The system
automatically categorizes comments and users.  This information will be
integrated into the existing framework that the eRulemaking Program
utilizes to analyze public feedback.  The average annual Agency cost is
estimated to be $4,600.  This is based on the average hourly labor rate
for a GS-12, step 1 of $44.24.  (This rate is from the Office of
Personnel Management “2008 General Schedule” which excludes locality
rates of pay).

15.	Reason for Change in Burden

There is no change in burden.

16.	Project Schedule

The Environmental Protection Agency released the Regulations.gov
‘feedback exchange’ to the public in May 2009.	

17.	Request to Not Display Expiration Date

The Regulations.gov ‘feedback exchange’ requests not displaying the
expiration date since this will be an on-going website.	

18.	Exceptions to the Certification

There are no exceptions.

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