A. Justification 

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.

According to Part B section 5201 of the Elementary and Secondary Education Act, one of the 

established purposes of the Charter Schools Program at the US Department of Education (ED) is 

to encourage “States to provide support to charter schools for facilities financing in an amount 

more nearly commensurate to the amount the States have typically provided for traditional public 

schools”. To help achieve this purpose, the Charter School Program needs reliable data to 

understand the current facilities landscape for charter schools. There were discussions on the 

struggles of charter schools for equitable and adequate access to facilities and facilities financing, 

yet there are no official studies, reports, or analyses explicitly discussing the facility landscape of 

charter schools and the similarities and differences between charter school and traditional public 

school facilities. The Charter Schools Program, through the National Charter School Resource 

Center, administers a questionnaire conducted by the Colorado League of Charter Schools to 

gather data on charter schools facilities. This data helps to assess the true facilities challenges of 

the charter schools and what actions ED and the SEAs must take to better financially support the 

facilities needs of quality charter schools. 

In the summer of 2007, the Colorado League of Charter Schools (the League) launched its 

Facilities 2010 Task Force, which was established to address charter school facility needs. One 

of the initiatives of the Facilities 2010 Task Force was to develop a survey that inventoried the 

facilities landscape in Colorado. The League conducted the survey in Colorado in 2008 and the 

survey results helped to increase the amount of funds from the state and created additional 

opportunities to gain leverage for charter school facilities. Since 2008 the Colorado legislature 

has increased charter school access to facilities funding by increasing the amount of the state 

grant funding for charter school facilities, increasing the state moral obligation program for 

charter schools, created greater access for charter schools to the state competitive grant program 

and increased access for charter schools to local revenue. In addition, there has been an increase 

in charter schools in district space. These successes are evidence that this survey can incite 

positive change, increase the involvement of state legislature to mitigate the financial issues of 

charter schools to obtain equitable facilities, and ensure charter schools receive an amount for 

facilities that is more commensurate with the amount provided for traditional public schools.

The League customized and administered this survey in Texas, Indiana, Georgia, Rhode Island, 

New York, New Jersey, Arkansas, Michigan, Massachusetts, Idaho, Tennessee, South Carolina 

and California. CSOs in participating states have reported that the survey results have provided 

the charter school facilities discussion in their states credibility regarding the problems facing 

charter schools and have resulted in legislative and other gains in their state towards charter 

school facility equity. CSOs have also reported that the results allow them to continue to push 

the facilities discussion forward for future changes. Some example of results include, in New 

Jersey after the results were published the state announced $125 million dollars in Qualified 

School Construction Bonds to support construction, expansion or enhancement of charter 

schools, the South Carolina CSO reports that the Charter Facility Tax Bill passed during the 
2013-2014 legislative session is a direct result of the South Carolina survey results, in Idaho the 

CSO reported "The facilities report helped charter schools in Idaho, for the very first time, get 

some facility dollars from the state, about $120 per student in 2013-14 and $180 in 2014-15", the 

Massachusetts Development Finance Agency was awarded $2,671,388 by the US DOE to help 

charter schools to issue guarantees on behalf of charter schools to guarantee a portion of a loan 

or bond made to a charter school to improve its school facility, and in Texas the data has been 

used to support school finance litigation. 

ED would like to continue to use and administer this survey in additional states and compile the 

data from all states into a facilities database. ED plans to conduct this survey in approximately

three to four states per year, depending on the size of the state and local resources of the CSO to 

support the survey. This database will provide comprehensive information about the facilities for 

charter schools and the issues that charter school face in trying to obtain adequate facilities. The 

League will produce a report and an analysis summarizing the findings per state.

The attached survey currently represents about 90% of the questions that will be asked to each 

state. The survey will be customized to include state-specific questions. 

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a 

new collection, indicate the actual use the agency has made of the information received 

from the current collection.

How and by whom:

The US Department of Education’s Charter Schools Program contracts with the National Charter 

School Resource Center (Charter School Center) to provide resources and information to the 

public and charter school stakeholders in pursuit of the Charter School Program’s statutory 

mission. Through this contract, the Charter School Center will subcontract with the Colorado 

League of Charters Schools that will administer the survey, collect the resulting information, and 

establish the facilities database. The League will coordinate the selection of participating states; 

provide financial, logistical, and training support for charter school organization personnel and 

charter school personnel involved in collecting the data; and conduct the data analysis resulting 

in state specific reports. The League will also aggregate the resulting data into a database 

supporting the analysis and the report at the project’s conclusion. 

The Charter School Center will partner with the Colorado League of Charter Schools (the 

League) and the National Alliance of Public Charter Schools (the Alliance) to administer this 

survey. The League has past experience and knowledge of administering the survey and the 

Alliance has contacts and strong relationships with state charter school organizations that have 

relationships with charter schools within their states. These relationships will help the Charter 

School Center streamline communication with the schools they wish to survey and help them 

ensure as many charter schools as possible participate in the survey. 

The survey has been launched in ten (10) states since 2012, including California which is in 

progress. The school based data gathering is concentrated during months most practical for 

school schedules. The survey will be administered to the appropriate staff and collected through 

web-based technology. Participating states will continue to be chosen based on a combination of 
factors including size of a state’s charter sector and capacity and support from the partner charter 

support organization (CSO). From previous survey collections conducted by the League, it 

discovered most charter schools are highly motivated and willing to complete the survey, even 

despite the length of the survey. The charter school community understands the impact and 

potential benefits of completing the survey. The subsequent analysis and reports will be 

produced within a few months after the completion of the data collection. The aggregation of 

data and subsequent report will be produced at the project’s conclusion.1

Contractors are hired to provide technical assistance and to collect measurements of the facilities 

and classrooms. There are several questions with the survey that pertain to measurements of the 

facilities. These contractors will assist in minimizing the burden for the charter schools 

completing the survey. The contractors will use a combination of floor plans, blueprints, and 

electronic measuring devices to capture the square footage of facilities, classrooms, and 

specialized educational spaces. 

A number of benefits come from involving contractors in the measurement process of the charter 

schools surveyed. The League has discovered --from their previous surveys-- that many charter 

schools are not in traditional school buildings and many are leasing space with different interior 

build outs that have occurred over the years, which means blueprints are not always available or 

accurate. Even when a school has purchased or built a new building, the blueprints are often 

drawn to the plan, not necessarily to the build. The League will specify to the contractors that 

when accurate blueprints are available, they can absolutely use them. However, we would 

recommend that a random set of rooms be checked to verify accuracy. 

In addition, another critical benefit to using the contractor is they will conduct schools visits and 

will therefore have an opportunity to check in with the schools to see if they have any questions 

about the survey or help them to complete the survey, if needed. The League has obtained higher 

response rates with the use of contractors. In early states that had a mix of contractors and 

leaders doing the measuring, there were far fewer follow-up questions and errors in the survey

data from the contractors than from the leaders.

The survey may look daunting with over 300 questions. However, due to the skip logic, 

respondents can skip a large number of questions that do not apply to them and by having the 

contractors conduct the measurements, the school leader will not have to answer those questions. 

The school leaders will answer approximately 80 questions, utilizing approximately 1-1.5 hours 

of the leader’s time. In addition, there is great support for the survey, so the length of the survey

does not deter schools from responding. The individual schools understand policy decisions 

made at the state legislative level are driven by data and effective advocacy and policy-making 

needs data. The League has experienced varied total participation rates, from 36% to 100%, with 

 

1 The League conducted an initial assessment of the 100+ Colorado schools that participated in the original survey

work (completed in 2008) to determine how frequently the data would need to be updated to ensure the data is still 

an accurate reflection of the conditions. Based on the results, the League recommends that at least three years needs 

to elapse before deploying a refresher survey. In addition, the refresher survey will only be given to schools that 

have substantial facility changes, and these schools will be able to build on their previous information. The refresher 

information input into the database will help to quickly capture the changes in conditions of facilities. This 

information will help to assess if the previous data collected has influenced these changes and whether they are 

positive or negative.
only one state registering less than 50% participation. We have found that the response rate 

varies for a number of reasons, including typical membership response to CSO sponsored 

surveys, CSO relationship to members and percent of membership of the charter schools in the 

state organization. We have not received any response from schools that participation in the 

survey has been affected by the length of the survey. 

For what purpose:

The purpose of this study is to create a charter school facilities database that identifies prominent 

strengths and shortcomings in multiple states’ facility landscape. The database will help to 

aggregate all the information collected to be easily retrieved for the public and interested parties. 

The information collected can help ED and SEAs understand the financial pressure charter 

schools have to gain adequate facilities. This information will be able provide valid data to 

permit analysis of the variation in quality of charter school facilities and to enable states to 

develop policy responses which increase support and funding to charter schools for facilities. 

With the information collected, a report and policy analysis will be completed for each state. In

addition, this survey will be analyzed to properly identify the challenges and barriers for charter 

schools to build to finance, or to obtain adequate facilities. 

The analysis will compare the charter schools facilities data related to measurement to traditional 

public school facilities. The results of each state’s survey are compared to the most conservative 

of relevant construction standards for public school facilities. In addition, the League contracted 

Paul Huttoni, a prominent school architect, to identify applicable standards for our use in each 

state and for each educational model and facility type. As stated before, this information and 

analysis can incent positive change and encourage states to develop initiatives which will 

provide support to charter school facilities.

3. Describe whether, and to what extent, the collection of information involves the use of 

automated, electronic, mechanical, or other technological collection techniques or forms of 

information technology, e.g. permitting electronic submission of responses, and the basis 

for the decision of adopting this means of collection. Also describe any consideration given 

to using technology to reduce burden.

A web-based survey system is used to distribute and collect the surveys. This web-based survey 

system will highly reduce the recordkeeping and data entry burden, as well as any lag time 

between completing and receiving surveys. Lastly, this method will reduce the need of any paper 

surveys, which will be available through a PDF if any respondent needs to print the survey. 

The notations entered on the survey regarding the skip logic are embedded in the web-based 

survey tool, which will allow respondents to skip questions that are inapplicable to them. No 

school has ever had to complete every question of the facilities survey, thus the burden to 

respondents is reduced. 

Having contractors (rather than school leaders/respondents) complete the measurement portion 

of the data collection efforts reduces the time and burden for the school leader/respondent and 

also increase our confidence in the reliability and validity of the resulting data. 
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.

There is currently no analysis of the physical conditions and environment of charter school 

facilities. To our knowledge, this is the only comprehensive survey to properly assess the current 

and future efforts of charter schools to improve or maintain their facilities. 

The League receives from the CSO a list of all charter schools in the state, along with their 

school code and physical location. To date, there not have been any reports of schools receiving 

the survey more than once. As stated in item 2, contractors will also be used to properly measure 

each facility and classroom size to avoid duplicate and/or inaccurate measurements. 

5. If the collection of information impacts small businesses or other small entities (Item 8b 

of IC Data Part 2), describe any methods used to minimize burden.

The surveys will be administered directly to charter schools, which are not considered small 

businesses or small entities. However, in helping to administer these surveys, the Charter School 

Center may use the assistance of charter support organizations (CSOs). CSOs vary in size so 

there may be some CSOs that would be considered small businesses. Financial, logistical, and 

training support is provided for CSO personnel involved in collecting the data. 

In addition, as stated above, contractors will be hired by the state partners for technical assistance 

and for the collection and data entry of the measurement of the facilities and classrooms. These 

contractors will lessen a number of potential burdens to charter schools, including time, finances, 

and labor. 

6. Describe the consequences 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.

As stated above, one of the purposes of the Charter School Program office is to encourage the 

States to provide support to charter schools for facilities financing in an amount more nearly 

commensurate to the amount the States have typically provided for traditional public schools. 

This survey will help the Charter School Program office gain a better perspective of the 

conditions of charter schools’ facilities. The analysis of the survey may help to develop new 

ideas to meet the purpose. Without information from this survey, the Charter School Program 

office may be blind to the legislative and financial issues facing charter school facilities. Data 

collection on a yearly basis allows for the Charter School Program office to collect more data 

and for more states to participate in the project. The landscape on a state and national basis for 

charter schools changes frequently and collecting data less frequently would have an adverse 

effect on the ability to substantively impact state level charter school facilities discussion. 

7. Explain any special circumstances that would cause an information collection to be 

conducted in a manner:
 requiring respondents to report information to the agency more often than 

quarterly;

 requiring respondents to prepare a written response to a collection of information in 

fewer than 30 days after receipt of it;

 requiring respondents to submit more than an original and two copies of any 

document;

 requiring respondents to retain records, other than health, medical, government 

contract, grant-in-aid, or tax records for more than three years;

 in connection with a statistical survey, that is not designed to produce valid and 

reliable results than can be generalized to the universe of study;

 requiring the use of a statistical data classification that has not been reviewed and 

approved by OMB;

 that includes 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 that unnecessarily impedes 

sharing of data with other agencies for compatible confidential use; or

 requiring respondents to submit proprietary trade secrets, 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.

There are no special circumstances that require the information collection to be conducted in 

any of the manners described above. 

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 describe actions taken by the 

agency in response to these comments. Specifically address comments received on cost 

and hour burden.

The Department published 60-and-30-day federal register notices seeking public comment 

and received none. 

Describe efforts to consult with persons outside the agency to obtain their views on the 

availability of data, frequency of collection, the clarity of instruction and record 

keeping, disclosure, or reporting format (if any), and on the data elements to be 

recorded, disclosed, or reported.

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.

10

As previously mentioned, there is no national database, report, or analysis on the state of charter 

school facilities. ED has held conversations with several organizations including the Local 

Initiatives Support Corporation and the Low Income Investment Fund regarding the need for 

more information about charter school facilities. A few organizations have published reports 

regarding financing for charter schools, but until the League began its survey work, an inventory 

of the charter school facilities had never been done. 

ED has held conference calls with members of the League and the National Alliance for Public 

Charter Schools (Alliance) to discuss the state surveys and understand the impact of the finalized 

data in comparing charter schools to traditional public schools. In addition, the League and 

Alliance informed ED about the process for conducting these surveys and how they were able to 

ensure the appropriate questions were being asked. To develop the best possible set of data and 

information about charter school facilities and their need, the League commissioned an 

experienced charter school architect2to help them compile the questions. These questions were 

then distributed to the League’s Facilities 2010 Task Force for additional feedback. A draft 

survey was then field tested with a small group of charter schools to ensure clarity and 

comprehensiveness of the items. Based on this information, as well as visits to a number of 

charter schools, further revisions to the questionnaire were made. The League and Alliance also 

include state-specific questions based on discussions with state representatives and charter 

schools within that particular state.

9. Explain any decision to provide any payment or gift to respondents, other than 

remuneration of contractors or grantees.

No gifts or payments will be made to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the 

assurance in statute, regulation, or agency policy.

The respondents are assured that identifying school information will not be published without 

prior consent of the school. When specifically requested by a school, all identifying information 

about the school (including school number) is removed if data is shared with a third party. 

11. Provide additional justification for any questions of a sensitive nature, such as sexual 

behavior and attitudes, religious beliefs, and other matters that are commonly considered 

private. The justification should include the reasons why the agency considers the questions 

necessary, the specific uses to be made of the information, the explanation to be given to 

persons from whom the information is requested, and any steps to be taken to obtain their 

consent.

 

2

Paul Hutton is the founder of Hutton Architecture Studio and has had a 32-year career in architecture. Paul has been a practicing architect in 

Colorado since 1980, is a LEED® Accredited Professional, and has been a member of the American Solar Energy Society since 1986. He 

attended Princeton University, and has graduate degrees in both Architecture and Environmental Planning from the University of Virginia. He is 

a frequent presenter at national conferences, and has extensive experience in the standards and design of educational facilities.
No questions in this information collection are of a sensitive nature. 

12. Provide estimates of the hour burden of the collection of information. The statement 

should:

 Indicate the number of respondents, frequency of response, annual hour burden, 

and an explanation of how the burden was estimated. Unless directed to do so, 

agencies should not conduct special surveys to obtain information on which to 

base hour burden estimates. Consultation with a sample (fewer than 10) of 

potential respondents is desirable. If the hour burden on respondents is expected 

to vary widely because of differences in activity, size, or complexity, show the 

range of estimated hour burden, and explain the reasons for the variance. 

Generally, estimates should not include burden hours for customary and usual 

business practices.

 If this request for approval covers more than one form, provide separate hour 

burden estimates for each form and aggregate the hour burdens in item 16 of IC 

Data Part 1.

 Provide estimates of annualized cost to respondents of the hour burdens for 

collections of information, identifying and using appropriate wage rate 

categories. The cost of contracting out or paying outside parties for information 

collection activities should not be included here. Instead, this cost should be 

included in Item 14.

Based on previous efforts, we have determined the survey takes a respondent approximately one 

to one and one-half hours to complete. Further information is included below. All the answers to 

the questions are used to assess each charter school’s facility.

This information request covers one form.

Number of respondents (estimated) 369 (based on an average of 123 charter 

schools per state)

Frequency of response once 

Annual hour burden/Annual burden 1-11⁄2 hours, an annual burden total of 1,107 

hours. This time is often split between two or 

three individuals—often the principal, the 

business manager, and/or the principal’s 

assistant. 

How was this burden estimated? Based on conversations with respondents and 

state level contractors regarding the time it 

takes for respondents to complete the survey. 

Annual cost to respondents $46 (at most) per hour for each respondent

$46-69 per respondent, on average

$16,974- $25,461 (estimated) across all 

respondents annually
13. Provide an estimate of the total annual cost burden to respondents or record keepers 

resulting from the collection of information. (Do not include the cost of any hour burden 

shown in Items 12 and 14.)

 The cost estimate should be split into two components: (a) a total capital and startup cost component (annualized over its expected useful life); and (b) a total 

operation and maintenance and purchase of services component. The estimates 

should take into account costs associated with generating, maintaining, and 

disclosing or providing the information. Include descriptions of methods used to 

estimate major cost factors including system and technology acquisition, expected 

useful life of capital equipment, the discount rate(s), and the time period over which 

costs will be incurred. Capital and start-up costs include, among other items, 

preparations for collecting information such as purchasing computers and software; 

monitoring, sampling, drilling and testing equipment; and acquiring and 

maintaining record storage facilities.

 If cost estimates are expected to vary widely, agencies should present ranges of cost 

burdens and explain the reasons for the variance. The cost of contracting out 

information collection services should be a part of this cost burden estimate. In 

developing cost burden estimates, agencies may consult with a sample of 

respondents (fewer than 10), utilize the 60-day pre-OMB submission public 

comment process and use existing economic or regulatory impact analysis associated 

with the rulemaking containing the information collection, as appropriate.

 Generally, estimates should not include purchases of equipment or services, or 

portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory 

compliance with requirements not associated with the information collection, (3) for 

reasons other than to provide information or keep records for the government, or 

(4) as part of customary and usual business or private practices.

There is no capital, start-up, or maintenance cost to respondents.

14. Provide estimates of annualized cost to the Federal government. Also, provide a

description of the method used to estimate cost, which should include quantification of 

hours, operational expenses (such as equipment, overhead, printing, and support staff), 

and any other expense that would not have been incurred without this collection of 

information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a 

single table.
Aggregate cost estimate from Items 12 and 14

12. Cost to respondents, year 1 $16,974- $25,461

14. Total annual cost burden, year 1 $286,202- $294,689

15. Explain the reasons for any program changes or adjustments to #16f of the IC Data 

Part 1 Form.

No changes or adjustments.
16. For collections of information whose results will be published, outline plans for 

tabulation and publication. Address any complex analytical techniques that will be used. 

Provide the time schedule for the entire project, including beginning and ending dates of 

the collection of information, completion of report, publication dates, and other actions.

Once completed, the analysis and database will be published on the National Charter School 

Resource Center website http://www.charterschoolcenter.org/ and the Charter School Facilities 

Initiative website http://www.facilitiesinitiative.org. State CSOs may also publish their 

respective state reports on their websites. No complex analytical techniques will be used, but 

descriptive statistics or frequencies may be used to populate the reports generated based on 

various criteria. 

Proposed Schedule

Task Completion date

Review current survey for any changes and 

submission to OMB

July 2014

Survey administration September- February 2014/15 (survey

administration will not take the entire length, 

but will be window during this time frame)

Data Collection and Analysis January- April 2015/15 (will be conducted 

during a window in this time frame)

Report Completion February- September 2015

Database Completion September 2015

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.

The expiration date will be displayed on the information collection.

18. Explain each exception to the certification statement identified in the Certification of 

Paperwork Reduction Act.

There is no exception to the certifications.