# Supporting Statement for Department of the Interior's Programmatic Clearance for Customer Satisfaction Surveys {#supporting-statement-for-department-of-the-interiors-programmatic-clearance-for-customer-satisfaction-surveys .unnumbered}

(OMB Control Number 1040-0001) EXTENSION/RENEWAL version March 8, 2005

A.  Justification:

Introduction:

The Department of the Interior (DOI) is requesting an extension/renewal
of its 3-year programmatic clearance for customer satisfaction surveys,
originally approved by the Office of Management and Budget (OMB) in
January 2002 and expiring on March 31, 2005. The programmatic clearance
enables Interior bureaus and offices to conduct customer research
through external surveys such as questionnaires and comment cards. This
information is being collected to improve the services and products that
DOI provides to the public and thus better carry out part of its
statutory mission. Information collected under the 3-year programmatic
clearance has led to a number of improvements. For example, customer
feedback has helped the Bureau of Land Management improve the timeliness
of several of its permitting processes. A survey of visitors to Fish and
Wildlife Refuges has identified two key issues being addressed by FWS to
help improve visitor satisfaction with refuge law enforcement and to
address differences in way minority groups perceive their experiences at
the refuge. The data have also been used to help Interior assess
organizational performance and accountability through GPRA strategic
planning and performance measurement. DOI anticipates that the
information obtained under a renewal of the programmatic clearance will
continue to lead to revisions in certain agency processes and policies,
development of guidance related to DOI's customer services, and
additional improvements in the way we serve the Nation.

The existing approved information collection (ICR) covers most of the
organizational agencies in DOI with the exception of the National Park
Service (NPS). With this renewal request, we ask that all Interior
organizational units and bureaus be covered, including the NPS, under
the scope of this request. NPS will retain its Programmatic Clearance
for Social Science surveys; by including NPS within the scope of this
request, NPS will have authority to conduct customer satisfaction
surveys using an expedited process. This then enables participating DOI
bureaus and offices to perform their customer surveys under one
programmatic clearance, providing a centralized review for these within
Interior. Under this proposed renewal/extension, DOI requests that OMB
review the procedures and questions for these surveys as a program.
Under the procedures proposed here, DOI will conduct the necessary
quality control, including assurances that the individual survey
instrument comports with the guidelines of the programmatic clearance,
and will submit the particular survey instrument and methodology for
expedited review to OMB as we are ready to deploy a specific information
collection.

**Who Will Be Impacted by This Renewal?**

Under the proposed programmatic clearance renewal, Interior will seek
satisfaction information from its customers. DOI defines the term
"Customers" in the following manner:

> ***[Customer:]{.underline}*** Anyone who uses DOI resources, products,
> or services. This includes internal customers (anyone within DOI) as
> well as external customers (e.g., the American public, representatives
> of the private sector, Tribes, academia, and other government
> agencies). Depending upon their role in specific situations and
> interactions, citizens and DOI stakeholders and partners may also be
> considered customers.
>
> We define "Stakeholder" to mean groups, individuals, or Tribes who
> have an expressed interest in and who seek to influence the present
> and future state of DOI's resources, products, and services.
>
> We define "Partner" to mean those groups, individuals, Tribes and
> government agencies who are formally engaged in helping DOI accomplish
> its mission, or with whom DOI has a joint responsibility or mission.

1\. **Explain the circumstances that make the collection of information
necessary. Identify any legal or administrative requirements that
necessitate the collection. Attach a copy of the appropriate section of
each statute and regulation mandating or authorizing the collection of
information.**

Interior will request extension/renewal of its Programmatic Clearance
for Customer Satisfaction Surveys so that we may better fulfill our
Departmental or program specific statutory mission as well as our
government-wide responsibilities to provide excellence in government by
proactively consulting with those we serve. Customer data are needed to:

1.  Meet requirements of the Government Performance and Results Act
    (GPRA)

2.  Meet requirements of the Program Assessment Rating Tool (PART)

3.  Realize the President's Management Agenda (PMA)

4.  Meet requirements of Interior's Citizen-Centered Customer Service
    Policy

5.  Meet requirements of Executive Order 12862

6.  Fulfill our responsibilities to provide excellence in government by
    proactively consulting with those we serve to identify opportunities
    to improve our information, services, and products to better meet
    their needs.

**GPRA:**

The Government Performance and Results Act (GPRA) of 1993 (Pub.L. No.
103-62) sets out to "improve Federal program effectiveness and public
accountability by promoting a new focus on results, service quality, and
customer satisfaction" (Section 2.b.3, see Attachment 1). In order to
fulfill this responsibility, DOI's bureaus and offices must collect data
from their respective user groups to (1) better understand the needs and
desires of the public and (2) respond to those needs and desires
accordingly.

In September 2003, Interior published its new GPRA Strategic Plan for FY
2003-2008. That plan contains a number of performance measures that
directly correspond to customer, partner, and stakeholder satisfaction
with specific services of Interior and its bureaus and offices (see
Attachment 2). To accurately report whether or not we met targets set
for these performance measures, it is imperative for Interior's bureaus
and offices to collect data from those we serve. Renewal of the
Programmatic Clearance for Customer Satisfaction Information is critical
to the Department's ability to collect those data in the way that we do
over the next three years as we progress toward achieving the goals and
end-outcomes of our new GPRA Strategic Plan.

**PART:**

The Program Assessment Rating Tool (PART) was introduced to agencies in
FY 2002 as a means to review the effectiveness of government programs.
PART is a standardized and systematic process for rating program
performance. The results of a PART assessment are used in annual
performance plans and report required by GPRA. PARTed programs are
required to establish long-range and annual performance goals as well as
efficiency measures. In many cases, Interior program managers must
collect information from their customers and partners to determine how
well they are performing regarding a specific PART measure (see
Attachment 3 for list of customer satisfaction-oriented measures). The
reinstated Programmatic Clearance for Customer Satisfaction Surveys will
be a tool used to assist us in obtaining data needed to implement
recommendations culminating from a program assessment under PART.

**The President's Management Agenda:**

In August 2001, the Office of Management and Budget (OMB) released the
President's Management Agenda (PMA), a five-point plan to improve
Federal management and program performance in order to make government
more citizen-centered and accountable for results. The PMA targets the
government's most apparent deficiencies in core management capabilities
where the opportunity to improve performance is greatest. The five
elements of the PMA include: Strategic Management of Human Capital;
Competitive Sourcing; Improved Financial Performance; Expanded
Electronic Government and Budget and Performance Integration. In 2001,
the Secretary of the Interior released her "Plan for Citizen-Centered
Governance: Adding Customer Value by Linking Accountability,
Modernization, and Integration." The Citizen-Centered Plan outlined
Interior's strategy for improving the delivery of DOI programs and
services to those we serve. It is our blueprint for weaving the PMA into
the management fabric at Interior. In order to ensure the "customer
value" of our activities, Interior must consult and communicate with our
customers to obtain their feedback regarding their satisfaction with our
services. The renewal of our Programmatic Clearance for Customer
Satisfaction Surveys enables us to obtain data that tell us whether or
not we are providing "customer value."

**Interior's Citizen-Centered Customer Service Policy:**

In July 2003, Interior established a new Department-wide policy that
admonishes its bureaus and offices to consult and communicate with
customers to integrate their feedback into our programs and business
processes in order to improve our service to them (see Attachment 4). It
specifically asks Interior bureaus and offices to obtain customer
satisfaction data on an annual basis and to use these data to implement
programmatic improvements. The renewal of our Programmatic Clearance
will assist these organizations in complying with the Departmental
policy. The new policy also complement's the Secretary of the Interior's
vision for effective Interior program management, which she describes as
the 4 C's: Conservation through Cooperation, Consultation, and
Communication. The 4 C's reflect the Secretary's goal of involving
others, including communities, partners, customers, and stakeholders, in
carrying out our mission by actively working with them, obtaining
feedback and input into our program and business processes, plans, and
practices.

**Executive Order 12862:**

Executive Order (E.O.) 12862 (September 11, 1993---see Attachment 5)
aimed at "ensuring the Federal Government provides the highest quality
service possible to the American people" fortifies our mandate by the
Secretary of the Interior and the Administration to provide
"citizen-centered government." The E.O. discusses surveys as a means for
determining the kinds and qualities of service desired by the Federal
Government's customers and for determining satisfaction levels for
existing service. These voluntary customer surveys will be used to
ascertain customer satisfaction with DOI's bureaus and offices in terms
of services and products. Previous customer surveys have provided useful
information to DOI's bureaus and offices for assessing how well we
deliver our services and products, making improvements, and reporting on
annual performance goals as set out in GPRA-related documents. The
results are used internally, and summaries are provided to the OMB on an
annual basis and are used to satisfy the requirements and spirit of E.O.
12862.

Furthermore, E.O. 12862 requires agencies to provide a "means to address
customer complaints." To that end, bureaus and offices may use customer
comment cards as an opportunity for customers to provide feedback to the
agencies on the service they have received.

In addition to GPRA and E.O. 12862, the statutes, regulations, and
Secretarial Orders that created each of the bureaus and offices further
enhance the need to engage the public and deliver quality products and
services to our customers.

**2. Indicate how, by whom, and for what purpose is the information to
be used. Except for a new collection, indicate the actual use the agency
has made of the information received from the current collection.**

Chiefly, these data are being collected to improve the service and
products that the participating Interior bureaus and offices provide to
the public, and thus better carry out part of our statutory mission.
Interior managers use customer satisfaction data to support all aspects
of planning, from buildings, roads, and interpretive exhibits, to
technical systems. In conducting their management, planning, and
monitoring activities, managers also use the information to allocate
effectively their limited personnel and financial resources to the
highest priority elements.

Information collected under the existing 3-year programmatic clearance
has led to a number of improvements in the way DOI carries out its
mission and serves the public. For example, customer feedback has helped
the Bureau of Land Management (BLM) improve the timeliness of several of
its permitting processes. A survey of visitors to Fish and Wildlife
Refuges (FWS) identified key issues impacting visitor satisfaction that
are currently being addressed by FWS including satisfaction with refuge
law enforcement and differences in satisfaction between races that visit
refuge sites. Information collected by the U.S. Geological Survey (USGS)
regarding existing and proposed transportation systems at Kilauea
National Wildlife Refuge are being used to design alternative means for
transporting visitors to the Refuge in response to visitor
dissatisfaction with crowded parking areas. A survey conducted by the
Bureau of Reclamation (BOR) has helped Reclamation managers identify
satisfaction levels with water delivery systems, and to identify
improvements.

DOI anticipates that the information obtained will continue to be used
in revising certain agency processes and policies, and developing
guidance related to the agency's customer services. These changes will
continue to improve the services DOI provides to the public and, in
turn, allow DOI to carry out more effectively a part of its statutory
mission.

NOTE: Interior's Programmatic Clearance for Customer Satisfaction
Surveys is limited to non-controversial information collections that do
not attract attention to significant, sensitive, or political issues.
Examples of significant, sensitive or political issues include: seeking
opinions regarding political figures; obtaining citizen feedback related
high-visibility and high-impact issues like the reintroduction of wolves
in Yellowstone National Park, the delisting of specific Endangered
Species, or drilling in the Arctic National Wildlife Reserve. The
Programmatic Clearance is intended to collect customer satisfaction data
only.

## I. Types of Questions Asked {#i.-types-of-questions-asked .unnumbered}

There are six topic areas that the participating bureaus and offices are
proposing to obtain information voluntarily from their customers and
stakeholders. It is not expected that any one survey will cover all the
topic areas; rather, these topic areas serve as a "guideline menu" from
which the agencies will develop their questions. Under the proposed ICR,
the Department, its offices, and bureaus will develop questions that fit
within the generally understood confines of the topic area. Questions
may be asked in languages other than English (e.g., Spanish), where
appropriate.

All information collection instruments will be designed and deployed
based upon acceptable statistical practices and sampling methodologies,
and will be used to obtain consistent, valid, data that are
representative of the sample, account for non-response bias, and target
response rates at or above 70%.

a.  **[Delivery, quality and value of products, information, and
    services :]{.underline}**

> The range of questions envisioned for this topic area will focus on
> customer satisfaction with aspects of information, products, and
> related services offered by DOI. Information, products, and services
> include written reports, press releases, computer modules, workshops
> and seminars, or technical assistance. Respondents may be asked for
> feedback regarding the following attributes of the information,
> service, and products provided:

-   Timeliness (Was the information, service, product provided to you in
    a timely manner?) (Was the information itself timely?)

-   Consistency (Was the quality of the service consistent with your
    expectations?)

-   Accuracy (Were the data provided accurate?)

-   Ease of Use and Usefulness (Was the product easy to use? Was the
    information useful to you?)

-   Ease of Information Access (Were you able to find the information
    you needed easily?)

-   Helpfulness (Was the information helpful?)

-   Quality (Was the information of high quality?)

-   Value for fee paid for information/product/service (Was the cost of
    the product, information or service appropriate for the value?)

    a.  **[Management practices:]{.underline}**

> This area covers questions relating to how well customers are
> satisfied with Interior management practices and processes, what
> improvements they might make to specific processes, and whether or not
> they feel specific issues were addressed and reconciled in a timely,
> courteous, responsive manner. Questions within this area may involve
> feedback regarding how well Interior engaged customers on a specific
> topic. They may also seek opinions from customers regarding how well
> Interior programs are managing and administering specific processes
> (for example, the Bureau of Land Management may ask customers how well
> it is administering its permitting processes.)

b.  **[Mission management:]{.underline}**

> Questions will ask customers and partners to provide satisfaction data
> related to Interior's ability to protect, conserve, provide access to,
> provide scientific data about, and preserve natural, cultural, and
> recreational resources that we manage, and how well we are carrying
> out our trust responsibilities to American Indians, Native Alaskans,
> and Insular Areas. Questions will specifically ask customers and
> partners to provide satisfaction data related to each of its four
> mission areas as described in its GPRA Strategic Plan: Resource Use,
> Resource Protection, Serving Communities, and Recreation.
>
> **d. [Rules, regulations, policies:]{.underline}**
>
> This area focuses on obtaining feedback from customers regarding
> fairness, adequacy, and consistency in enforcing rules, regulations,
> and policies for which Interior is responsible. It will also help us
> understand public awareness of rules and regulations and whether or
> not they are articulated in a clear and understandable manner. It will
> not seek opinions from customers regarding the appropriateness of
> regulatory rulings themselves.
>
> **e. [Interactions with DOI Personnel and Contractors]{.underline}**
>
> Questions developed under this topic area will focus on obtaining
> customer feedback regarding attributes of interactions with Interior
> office and bureau employees, as well as Interior contractors.
> Attribute questions will range from timeliness and quality of
> interactions to skill level of staff providing the assistance, as well
> as their courtesy and responsiveness during the interaction.

f.  **[General demographics:]{.underline}**

> Some general demographics may be used to augment satisfaction
> questions in order to better understand the customer so that we can
> improve how we serve that customer. Demographics data will range from
> asking customers how many times they have used an Interior service or
> visited an Interior facility in the past X timeframe to their ethnic
> group and race. \[Note: sensitivity and prudence will be used in
> developing and deploying questions under this topic area so that the
> customer does not perceive an intrusion upon his/her privacy.
> Additionally, these questions will ONLY be asked as long as the data
> are critical to understanding customer satisfaction and the character
> of the customer base.\] Demographics may also be used as part of a
> non-response bias strategy to ensure responses are representative of
> the contact universe.

##  How are data used?

# Managers and program specialists use these data to identify: {#managers-and-program-specialists-use-these-data-to-identify .unnumbered}

-   Service needs of customers

-   Strengths and weaknesses of services

-   Ideas or suggestions for improvement of services from our customers

-   Barriers to achieving customer service standards

-   Changes to customer service standards

-   Baselines to measure change in improving service delivery over time

-   Improving public trust in government

## III. Strategic Plan/Annual Performance Plan Measures {#iii.-strategic-planannual-performance-plan-measures .unnumbered}

In fulfilling the requirements of GPRA, DOI and all of its bureaus and
offices have created a new Strategic Plan in coordination with their
respective stakeholders. GPRA requires the DOI to report annually on its
progress toward achieving the goals outlined in the Annual Performance
Plan. Some of the data collected will be used as the basis for or in
support of specific performance measures. These data are reported within
Interior's Annual Performance and Accountability Report, which is
audited by an independent contractor for accuracy and validity.

For example, within Interior's Strategic Plan for 2003-2008, the USGS
must provide data to show customer satisfaction with the science it
provides for specific program areas including geologic hazards. The FWS,
NPS, and BLM must provide data regarding the satisfaction of visitors
with their recreation experience on public lands managed by these
bureaus. The BIA must provide data to show beneficiary satisfaction with
its trust management programs. To provide data needed for these and
other Strategic Plan performance measures, the bureaus must use various
information collection instruments such as surveys and questionnaires.

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, e.g., permitting electronic submission of
    responses, and the basis for the decision for adopting this means of
    collection. Also describe any consideration of using information
    technology to reduce burden \[and specifically how this collection
    meets GPEA requirements\].**

Improved information technology will be used, when possible, to reduce
the burden on the public and to comply with requirements of the
Government Paperwork Elimination Act (GPEA). E-mails may be used to
introduce and distribute information collection instruments to a sample
of customers. In some cases, the instruments may be web-enabled so that
respondents can complete them online, enabling the response analysis to
be automated. We estimate that about 10% of our responses will be
collected electronically. In all cases, appropriate non-response bias
strategies will be used to ensure that responses are representative of
the contact universe. Electronic media will not be used to select
sampling frames for surveys to be conducted under the generic clearance.

In addition, under the existing Programmatic Clearance, DOI has
eliminated paperwork by electronically converting the supporting
statements for individual instruments required as part of the
Programmatic Clearance process. DOI program managers may submit their
statements using an electronic form. The entire package is also
electronically submitted to the OMB OIRA Desk Officer for review. The
process has worked well under the existing Programmatic Clearance,
eliminating paper, and expediting the review and approval process.

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.**

This effort does not duplicate any other survey being done by DOI or
other Federal agencies. Other Federal agencies are conducting user
surveys but are not soliciting comments on the delivery of DOI or DOI
bureau/office products and services. As part of this effort, DOI
consulted with other agencies, including the Department of Agriculture
and the U.S. Environmental Protection Agency, who conduct surveys of
similar customers.

DOI is keeping abreast of what other Federal agencies are doing
regarding customer surveys. The participating bureaus and offices work
in partnerships with the Interagency Customer Forum (coordinated by the
Federal Consulting Group). The Forum identifies and develops
crosscutting performance goals, shares customer service methodologies
and related information, and ensures comparability of data to eliminate
redundancy.

Furthermore, DOI's Customer Forum, which includes representatives of the
bureaus in DOI, regularly meets to discuss the crosscutting issues and
data needs in the customer service arena. Recent discussions have
resulted in a recommendation to conduct a general public survey that
would obtain customer satisfaction data from a given sample and would
then be used by all DOI recreation-providing bureaus (BOR, BIA, BLM,
NPS, and FWS), thus eliminating the need for each bureau to conduct its
own recreation satisfaction-oriented survey. That general public survey,
if funded, will likely take place within the next 3 years.

The existing Programmatic Clearance has eliminated the need for DOI
bureaus to conduct customer satisfaction surveys on their own,
centralizing information collection requests through a single review
office, with the exception of requests from the National Park Service.
Under this renewal request, we seek to include the NPS in the scope of
the Programmatic Clearance, thus centralizing ALL DOI customer
satisfaction-oriented information collection requests.

5.  **If the collection of information impacts small businesses or other
    small entities (Item 5 of OMB Form 83-I), describe any methods used
    to minimize burden.**

One of the main purposes of this effort is to gather information needed
without putting a significant additional burden on small entities. Small
samples will be used to select respondents, and the number of questions
on the surveys will be kept to a minimum. Small entities, as well as
DOI, will benefit from the government's increased responsiveness to
their needs. Use of electronic means also have the potential to reduce
the burden on 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.**

Without this information collection, DOI will not be able to determine
the kind and quality of service customers want, their level of
satisfaction, or ways to improve customer service in a timely manner.
The Programmatic Clearance for Customer Satisfaction Information enables
bureaus and offices within the Department of the Interior to collect
customer satisfaction data in an expedited manner, which not only helps
us obtain data from customers more quickly, but enables us to respond to
customer concerns in a manner that better meets customer expectations.

7\. **Explain any special circumstances that would cause an information
collection to be conducted in a manner: (i) requiring respondents to
report more often than quarterly, (ii) requiring respondents prepare
written responses in fewer than 30 days after receipt, (iii) requiring
respondents to submit more than an original and two copies of any
document, (iv) retain records for more than 3 years; (v) 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; (vi)
the use of a statistical data classification that has not been reviewed
and approved by OMB; (vii) that includes a pledge of confidentiality not
supported by authority established in statute or regulation; requiring
respondents to submit proprietary trade secrets or other confidential
information.**

This renewal request contains no special circumstances with respect to 5
CFR 1320.5 (2) (i) and (iii-viii) with the exception of (ii). We are
asking respondents to send back their responses in fewer than 30 days
after receipt of the survey. On these types of surveys, respondents
normally will respond rather quickly if they intend to respond at all.
The first survey (for each bureau's customer line) will provide our
baseline data, and we will consider all responses until the time we make
the final baseline report. These are voluntary surveys and respondents,
of course, are not obligated to respond.

8.  **If applicable, provide a copy and identify the date and page
    number of publication in the Federal Register of the agency's
    notice, required by 5 CFR 1320.8 (d), soliciting comments on the
    information collection prior to submission to OMB. Summarize public
    comments received in response to that notice \[and in response to
    the PRA statement associated with the collection over the past three
    years\] and describe actions taken by the agency in response to
    these comments. Specifically address comments received on cost and
    hour burden. Describe efforts to consult with persons outside of 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 \[Please list the names,
    titles, addresses, and phone numbers of persons contacted.\]
    Consultation with representatives of those from whom information is
    to be obtained or those who must compile records** **should occur at
    least once every 3 years---even if the collection of information
    activity is the same as in prior periods. There may be circumstances
    that may preclude consultation in a specific situation. These
    circumstances should be explained.**

As required in 5 CFR 1320.11, DOI provided the 60-day review and comment
process with a notice published in the *Federal Register* on May 10,
2004 (Volume 69, Number 90, page 25916-25918), soliciting comments on
DOI's planned and existing customer research (see Attachment 6).

***Public Comments***

Only 1 comment was received from the public notice. The comment came
from B. Sachau of Floram Park, NJ, via e-mail on May 14, 2004. Mr.
Sachau objected to the information collection, noting that "it has been
going on for fifty years and the comments should be quite indicative by
now....Judging by the way public comments on proposals are ignored, it
is clear that any (sic) thing that customers say to this agency will
similarly be ignored. This agency does what the top politicians tell it
to do." Mr. Sachau further expressed concern about requesting race or
ethnicity data, noting that in his opinion, "We are Americans and that
is enough. This constant divisiveness practiced by what race uses the
park/forests is dividing." We responded to Mr. Sachau on June 24, 2004
stating that while we could not comment on the political issues raised
in his e-mail, we could address his concerns about Interior's use of
customer satisfaction information. We noted that Interior takes
seriously its mission to conserve and protect America's public lands. In
order to assess how we can improve or where we are falling short, we ask
those we serve for feedback. We further stated that it would be a
tremendous oversight on our part if we never asked the public for
feedback regarding ways we can improve and serve it better, and further
we would lose the benefit of ideas for improvement from the public if we
did not consult with it. We also agreed with Mr. Sachau that asking race
or ethnicity (and other demographics data) should be handled properly
and carefully. (See Attachment 7, copy of our response to Mr. Sachau and
his original message.) Mr. Sachau did not respond.

After receiving Mr. Sachau's message, the Information Collection Officer
for the Programmatic Customer Satisfaction Survey discussed the issue of
collecting race, ethnicity, and other demographics data with the DOI
Customer Forum. She informed the Forum that she will not accept requests
for information collections containing demographics questions UNLESS
THERE IS A COMPELLING CASE for the data. This policy is further
documented in the Forum's meeting summary of June 16, 2004 (Attachment
8), which was distributed after the meeting to the DOI Customer Forum
members. Forum members were instructed to share this action with their
program managers.

***Non-DOI Contacts***

DOI consulted with several non-DOI contacts to obtain their comments on
our renewal plan. The following individuals were contacted:

> Kevin Coray, Coray-Gurnitz Consulting, Managing Partner (professional
> survey designer and consultant), 2300 9^th^ Street South, Ste 300B,
> Arlington, VA 22204, tel: 703.685.7001
>
> Katie Lundstrum, Coray-Gurnitz Consulting, Associate (professional
> survey designer and consultant), 2300 9^th^ Street South, Ste 300B,
> Arlington, VA 22204, tel: 703.685.7001
>
> Brian Forist, University of Idaho (NPS partner; manages NPS Social
> Science Programmatic Clearance), 1300 Eye Street, Washington, DC, tel:
> 202.513.7190
>
> Steve Hollenhorst, University of Idaho, Professor and Department Head,
> Dept of Conservation Social Sciences (Director of NPS Visitor Services
> project), Moscow, ID 83844-1139, tel: 208.885.7911

The following comments were received from these non-DOI employee
contacts:

-   July 2, 2004: Steve Hollenhorst, University of Idaho: Suggested that
    70% response rate is an unreasonable expectation for partner and
    cooperator contacts. He noted that in his experience, 50-40% is more
    realistic. We responded that OMB requires that we take necessary
    actions to achieve a 70% or more response rate.

-   June 17, 2004: Brian Forist, University of Idaho: Suggested that we
    streamline section B of the supporting statement. We reconciled
    within the final draft.

***DOI Program Managers***

In addition, DOI asked all internal DOI program managers who had used
the original Programmatic Clearance for Customer Satisfaction Surveys
for comments regarding our intent to renew and our supporting statement.
About 55 DOI program managers were asked to comment on the Federal
Register notice and draft supporting statement on May 3, 2004. They were
reminded to comment again on June 17, 2004. (See Attachment 9---e-mail
to DOI Program Managers requesting comments.)

The following comments were received from internal DOI program managers:

-   June 17, 2004, C. Raphael, USGS: Change typo related to Paperwork
    Reduction Act reference in Federal Register Notice (Response: typo
    was corrected on June 18.)

-   July 2, 2004, R. Halbe, FWS: Simply noted that she had not comments
    on the supporting statement, nor had she received any comments from
    the public regarding the FWS Refuge Survey conducted in 2002.

-   July 2, 2004, J. Renaud, NPS: Several comments aimed at clarifying
    and strengthening the supporting statement. All comments were
    reconciled within the final draft.

**9. Explain any decision to provide any payment or gift to respondents,
other than remuneration of contractors or grantees.**

Incentives, remuneration, and gifts are generally deemed inappropriate
as part of plans for information collections conducted within the scope
of the Programmatic Clearance for Customer Satisfaction Surveys. In some
cases, the provision of gifts and incentives to customer satisfaction
survey respondents may appear to be a conflict of interest. However,
there may be extraordinary circumstances under which remuneration may be
appropriate within the scope of this program. For example, focus group
participants might be reimbursed for expenses incurred to travel to the
focus group interview site. In the cases of information collections that
seek to use incentives under extraordinary circumstances, Interior
program managers must describe the proposed incentive, how it will be
offered to respondents, and provide a justification of its use within
the supporting statement, which is required as part of each information
collection request under this package.

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

We protect information submitted by respondents that is considered
confidential or proprietary under the Freedom of Information Act and in
accordance with each bureau's regulations on protecting these data.
Respondents are informed of this assurance on the survey instruments
used during the course of the survey and/or interview.

**11. Provide additional justification for questions of a sensitive
nature, such as sexual behavior and attitudes, religious beliefs, and
other matters that are commonly considered private.**

The questions used on these surveys will not be of a sensitive nature.

**12. Provide estimates of the hour burden of the collection of
information.**

Based on experience with the existing Programmatic Clearance, the
addition of NPS to the scope of the Clearance, and our plans to conduct
a general public survey within the next 3 years regarding visitor
satisfaction at lands managed by Interior, we estimate that there are
approximately 60,000 respondents submitting surveys annually and that it
takes approximately 15 minutes to complete each survey. We also estimate
that there are approximately 60,000 respondents submitting comment cards
annually and that it takes 3 minutes to complete each comment card.
Given these estimates, DOI anticipates a budget of 18,000 hours per year
for these proposed collections.

We estimate, based on a \$15 per hour valuation of volunteer time and
the projected budget hours, an approximate aggregate cost to respondents
of \$270,000. Burden includes the total time, effort, or financial
resources expended to generate, maintain, retain, or disclose or provide
the information, including: (1) reviewing instructions; (2) developing,
acquiring, installing, and utilizing technology and systems for purposes
of collecting, validating, verifying, processing, maintaining,
disclosing, and providing information; (3) adjusting the existing ways
to comply with any previously applicable instructions and requirements;
(4) training personnel to respond to a collection of information; (5)
searching data sources; (6) completing and reviewing the collection of
information; and (7) transmitting or otherwise disclosing information.

**13. Provide an estimate of the total annual (non-hour) cost burden to
respondents or recordkeepers resulting from the collection of
information.**

We have identified no reporting and recordkeeping "non-hour cost"
burdens associated with this proposed collection of information.

**14. Provide an estimate of annualized cost to the Federal
Government.**

The bureaus and offices will, on a case-by-case situation, determine if
it is more efficient and cost effective to develop and analyze these
surveys in-house or to turn to private or other non-government entities
to provide that service. Based on the existing Programmatic Clearance,
we estimate an aggregated expense for all participating bureaus/offices
in the Department of \$1.2 million per annum.

**15. Explain the reasons for any program changes or adjustments
reported in Items 13 or 14 of the OMB Form 83-I.**

There are no program changes or adjustments for this renewal.

**16. For collections of information whose results will be published,
outline plans for tabulation and publication.**

Each information collection considered under the Programmatic Clearance
will describe how the data will be used. Each information collection
will provide to OMB the specific tabulation methods used to synthesize,
analyze and aggregate data collected.

These data will be collected annually, with information collections
scheduled to correspond to the time period that will gain the greatest
response rates for the given group.

The aggregate information will be published annually and available on
the Internet as well as through discrete publications that will best
reach the respective groups.

**17. If seeking approval to not display the expiration date for OMB
approval of the information collection, explain the reasons that display
would be inappropriate.**

We will display OMB's expiration date on the information collection
instruments.

**18. Explain each exception to the certification statement identified
in Item 19, "Certification for Paperwork Reduction Act Submissions," of
OMB Form 83-I?**

We are requesting no exceptions to the certification statement.

B. Collection of Information Employing Statistical Methods.

**1. Describe (including the numerical estimate) the potential
respondent universe and any sampling or other respondent selection
method to be used. Data on the number of entities (i.e., establishments,
State and local government units, households, or persons) in the
universe covered by the collection and in the correspondent 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.**

Our potential respondent universe consists of DOI's customers. DOI
defines the term "customers" in the following manner:

> ***[Customer:]{.underline}*** Anyone who uses DOI resources, products,
> or services. This includes internal customers (anyone within DOI) as
> well as external customers (e.g., the American public, representatives
> of the private sector, Tribes, academia, other government agencies).
> Depending upon their role in specific situations and interactions,
> citizens and DOI stakeholders and partners may also be considered
> customers.
>
> We define "Stakeholder" to mean groups, individuals or Tribes who have
> an expressed interest in and who seek to influence the present and
> future state of DOI's resources, products, and services.
>
> We define "Partners" to mean groups, individuals, Tribes and
> government agencies who are formally engaged in helping DOI accomplish
> its mission, or with whom DOI has a joint responsibility/mission.

Based on experience with the existing Programmatic Clearance, the
addition of NPS to the scope of the Clearance, and our plans to conduct
a general public survey within the next 3 years regarding visitor
satisfaction at lands managed by Interior, we estimate that there are
approximately 60,000 respondents for each survey, and 60,000 respondents
submitting comment cards annually. Respondent types include coal
operators, contractors/vendors, environmental groups, other governments
(state, local, foreign), grant recipients, American Indians/Alaska
Natives, industry groups, insular governments, interested publics
(including community and specific-interest groups), law enforcement,
mining companies, public information centers, scientific data users,
universities/educators, utility companies, and visitors/recreationists.

Based on previous experience with the existing Programmatic Clearance,
we anticipate response rates at or above levels needed to obtain
statistically viable results. We will take steps to maximize response
rates and ensure that these are integrated as part of the survey
methodology in the supporting statement for each information collection
to be considered under the clearance.

2.  **Describe the procedures for the collection of information
    (statistical methodology, etc.).**

3.  **Describe methods to maximize response rates and to deal with
    issues of non-response.**

4.  **Describe any tests of procedures or methods to be undertaken.**

All requests to collect information under the auspices of this proposed
renewal will be carefully evaluated to ensure consistency with the
intent, requirements, and boundaries of this programmatic clearance.
Program managers and investigators planning to submit information
collection requests under this Programmatic Clearance are strongly
encouraged to pretest any information collection instruments to be used.
Further, we strongly encourage use of the Programmatic Clearance to
obtain approval to conduct any pretesting that falls under the
requirements of the Paperwork Reduction Act (i.e., more than nine
individuals are being surveyed, etc.). In these cases, requests for
approval to pretest surveys will be subject to the same requirements
(i.e., a supporting statement, copy of the instrument, etc.) as a
standard information collection.

Interior's Office of Planning and Performance Management will conduct an
administrative review of each request and oversee technical reviews of
each request to ensure statistical validity and soundness. All
information collection instruments will be designed and deployed based
upon acceptable statistical practices and sampling methodologies, where
appropriate, and will be used to obtain consistent, valid, data that are
representative of the sample, account for non-response bias, and target
response rates at or above levels needed to obtain statistically useful
results.

All submissions under the program of expedited approval must include a
description of the survey methodology. This description must be specific
and describes, as appropriate, each of the following: (a) respondent
universe, (b) the sampling plan and all sampling procedures, including
how individual respondents will be selected, (c) how the instrument will
be administered, (d) expected response rate and confidence, and (e)
strategies for dealing with potential non-response bias. A description
of any pre-testing and peer review of the methods and/or instrument is
highly recommended. Further, all submissions under the Programmatic
Clearance will describe how data will be presented to managers and any
others that will use results of the surveys, particularly in cases where
response rates were lower than anticipated. In these cases, program
managers must take steps to ensure that the appropriate caveats and
explanations are provided with data presentations and reports so that
users of the data understand that there may be possible biases
associated with the data.

Interior has established a form that program managers must use to access
the original Programmatic Clearance for Customer Satisfaction Surveys
(Attachment 10). The form addresses all points mentioned above.

C. What is 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?

This submission was originally prepared in consultation with Coray
Gurnitz Consulting, Arlington, VA. (Contact: Roy Wright, M.P.A., and
Kevin Coray, Ph.D. (703) 685-7001). The renewal was prepared by Sheri L.
Harris, Office of Planning and Performance Management, Department of the
Interior. Statistical aspects of the design were reviewed by Brian
Forist, University of Idaho (NPS Partner); Dr. Steve Hollenhorst,
University of Idaho (Director of NPS Visitor Services Program); and Dr.
Steve Gillespie, statistician, USGS.

DOI's Office of Planning and Performance Management (PPP), in concert
with other statistical experts in DOI, will serve as the "secondary
office of control," coordinating the customer research efforts of DOI
and ensuring that statistical aspects of the design remain consistent
with this submission.

Effective January 31, 2005, PPP revised its policy for managing the
Programmatic Clearance for Customer Satisfaction Surveys. PPP requires
that a qualified statistician review and approve the proposed
information collection prior to submission of the collection to PPP.
Further, PPP requires that the appropriate bureau/office Information
Collection Officer review and approve the proposed information
collection prior to submission of the collection to PPP. PPP will
conduct an administrative and technical review of the collection ONLY
after it has been through the two aforementioned reviews at the bureau
and office level. PPP will work with a qualified statistician to conduct
the final technical review at the Departmental level prior to submitting
the information request to OMB. (Contact: Office of Planning and
Performance Management (202) 208-1818)

Respective Interior bureau and office program managers, their
contractors, and statistical staff, will actually collect and/or analyze
information collected via individual collection efforts under this
generic clearance.