1 - Acas Ssa 20201210

ATSDR Communication Activities Survey (ACAS)

OMB Control No. 0923-0055

Reinstatement with Change

Information Collection Request

Supporting Statement Part A –

Justification

Project Officer

Matt Sones, PhD, MPH

Communication/Program Evaluation Team Lead

Division of Community Health Investigations

Agency for Toxic Substances and Disease Registry

4770 Buford Highway, Atlanta, GA 30341

Office: 770.488.0731

Email: zgi2@cdc.gov

December 10, 2020

Table of Contents

A.1. Circumstances Making the Collection of Information Necessary 3

A.2. Purpose and Use of the Information Collection 5

A.3. Use of Improved Information Technology and Burden Reduction 7

A.4. Efforts to Identify Duplication and Use of Similar Information 8

A.5. Impact on Small Businesses or Other Small Entities 8

A.6. Consequences of Collecting the Information Less Frequently 9

A.7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5 9

A.8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency 9

A.9. Explanation of Any Payment or Gift to Respondents 10

A.10. Protection of the Privacy and Confidentiality of Information Provided by Respondents 10

A.11. Institutional Review Board (IRB) and Justification for Sensitive Questions 14

A.12. Estimates of Annualized Burden Hours and Costs 14

A.13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers 16

A.14. Annualized Cost to the Federal Government 16

A.15. Explanation for Program Changes or Adjustments 17

A.16. Plans for Tabulation and Publication and Project Time Schedule 22

A.17. Reason(s) Display of OMB Expiration Date is Inappropriate 23

A.18. Exceptions to Certification for Paperwork Reduction Act Submissions 23

Goal of the study: Ascertain effectiveness and assess the consistency of ATSDR activities delivery and respondent perceptions across sites and over time; determine how effectively ATSDR’s site team engages community members; and discover how well ATSDR provides effective, clear and consistent communication and information through the activities they implement in communities.

Intended use of the resulting data: Provide suggestions to standardize and ensure consistent delivery of ATSDR activities, improve implementation of activities, help ATSDR and communities address environmental issues in the most impactful manner. The data will be used to show site differences in delivery of activities, respondent knowledge, perceptions, and community interactions.

Methods to be used to collect: ACAS will be conducted in two modes (hardcopy, online), and the SMS Text Survey will provide an option to take a brief cell phone survey. After the community meeting takes place (post only); with community meeting members (one group); survey questions establish time before the community meeting and after the meeting, as well as before ATSDR came into the community and after the agency came into the community (baseline embedded)

Subpopulation to be studied: Community members and agency stakeholders at sites where ATSDR is engaged in environmental public health activities. The community members may include, but are not limited to, the general public, community leaders, faith-based leaders, and business leaders. The agency stakeholders may include, but are not limited to, state and local environmental health department employees, such as environmental health assessors, toxicologists, and departmental officials.

How data will be analyzed: Stata^®, using a simple paired t-test of the difference in proportions, analysis of variance (ANOVA), and/or mediation/moderation analysis.

Part A. Justification

A.1. Circumstances Making the Collection of Information Necessary

In 1980, Congress created the Agency for Toxic Substances and Disease Registry (ATSDR) to implement the health-related sections of laws that protect the public from hazardous wastes and environmental spills of hazardous substances. The Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), commonly known as the "Superfund" Act, provided the Congressional mandate to remove or clean up abandoned and inactive hazardous waste sites and to provide federal assistance in toxic emergencies (Attachment A1-A3). As the lead agency within the Public Health Service for implementing the health-related provisions of CERCLA, ATSDR is charged to assess the presence and nature of health hazards at specific Superfund sites, to help prevent or reduce further exposure and the illnesses that result from such exposures, and to expand the knowledge base about health effects from exposure to hazardous substances. ATSDR determines public health implications associated with hazardous waste sites and other environmental releases. This information collection request (ICR) supports ongoing site investigations conducted by other agencies, addresses community health concerns, and results in recommendations for preventing harmful exposures and conducting additional scientific study.

ATSDR administers programs and site activities in communities to advance the science of environmental public health (EPH); to support environmental public health practice; to educate partners and policy makers about environmental health risks and protective measures; to promote environmental justice and reduce health disparities related to environmental exposures; and to provide unique scientific and technical expertise to advance public health science and practice. ATSDR provides liaison, technical advice, and consultation to the Environmental Protection Agency (EPA), other federal, tribal, and state agencies, private organizations, community groups, and individuals. ATSDR also conducts and evaluates exposure pathway analyses and other exposure screening analyses to identify impacted communities, to include exposure investigations (biologic sampling, personal monitoring, etc. under ATSDR Exposure Investigations [EIs], OMB Control No. 0923-0048, expiration date 04/30/2022), exposure-dose reconstruction, and related environmental assessments.

ATSDR’s goal for this ICR is to continue to ascertain the effectiveness, and to evaluate the differences and consistency, of ATSDR activity delivery and respondent perceptions across sites and over time; determine how effectively ATSDR’s site team engages community members; and discover how well ATSDR provides effective, clear and consistent communication and information on how to promote healthy and safe environments and prevent harmful exposures through the activities they implement in communities. This will help ATSDR understand whether its activities are helping communities address environmental issues and how it may improve activities to make a greater impact within the communities served.

ATSDR is seeking a three-year Paperwork Reduction Act (PRA) clearance for this reinstatement with change ICR titled the “ATSDR Communication Activities Survey (ACAS)” (OMB Control No. 0923-0055, expiration date 06/30/2020). Based on its recent experience, ATSDR proposes to revise the ACAS to improve its utility and efficiency, and to pilot test a brief text-based survey method.

The purpose of pilot testing the text-based survey is to provide a shorter alternative to the current ACAS survey. During the administration of the initial ACAS survey one of the primary concerns that was raised was that it was too long and required too many resources (personnel and time) to administer and analyze. During the initial administration of the survey, ATSDR utilized a contractor to administer the survey and analyze the data. ATSDR no longer has this contract to help administer the survey and analyze survey data. ATSDR currently does not have sufficient staff to administer this lengthy survey on a regular basis, therefore, an abbreviated four-question survey was developed so that current ATSDR field staff can easily administer the survey during public meetings in a very short amount of time. The four questions in the text-based survey were selected because they address some of ATSDR’s key performance indicators.

ATSDR is requesting an increase in the annual number of responses from 334 in 2017 to 534 in 2020 (+ 200 responses), and an increase in the annual time burden from 49 hours in 2017 to 58 hours in 2020 (+9 hours). Details on the proposed revisions, including the potential need for COVID-19 precautions, are discussed in Section A.15.

The 60-day Federal Register Notice was published on 04/03/2020 (Attachment B) and is further discussed in Section A.8.

A.2. Purpose and Use of the Information Collection

To effectively implement the above mentioned ATSDR programs, the agency works with communities by listening to and understanding their health concerns and seeking their guidance on where, when, and how to take public health actions. Communities in proximity to hazardous waste sites are concerned that they are being exposed to hazardous substances being released into the environment. ATSDR activities implemented in communities involve a two-way exchange of information between ATSDR health assessors, the site team, and community members. Community members are key participants in ATSDR activity implementations and communications within the community and should be actively involved in decisions that impact their community.

The ACAS will be administered in communities where the agency implements activities to address environmental risks. For each engaged community, the ACAS will be used to assess a standardized set of effectiveness indicators for ATSDR site-specific activities including respondent involvement, knowledge, satisfaction, observations, opinions, and ATSDR community engagement, interactions, and educational outreach efforts to inform communities. This survey will help ATSDR understand its impact, how it may improve the activities implemented in communities, and how to make a greater impact in helping communities address environmental issues. ATSDR plans to administer its standardized survey to community members and agency stakeholders. The community members may include, but are not limited to, the general public, community leaders, faith-based leaders, and business leaders. The agency stakeholders may include, but are not limited to, state and local environmental health department employees, such as environmental health assessors, toxicologists, and departmental officials. In summary, using the ACAS, ATSDR aims to measure respondent involvement and knowledge of site activities; respondent opinions on ATSDR site activities, their community capacity to deal with environmental contamination, their personal risk for exposure, and environmental concerns; respondent demographics; and any additional feedback. The ACAS will be conducted via two modes, which are further discussed in Section A.10.

This information is needed to support ATSDR’s mission to serve the public through responsive public health actions to promote healthy and safe environments and prevent harmful exposures. ATSDR activities implemented in communities have the potential to reduce and minimize harmful toxic environmental exposures through community engagement, interactions, educational outreach efforts, and informing communities. Information collected from the ACAS will be used to help ATSDR standardize and ensure consistent delivery of ATSDR activities, improve implementation of activities, and help ATSDR and communities understand and improve ATSDR activities to make a greater significant impact in addressing environmental issues in the communities they serve.

Survey findings will allow ATSDR to improve its activities implemented at each site. The ACAS will be administered at the public meeting toward the end of the site activities, at which time ATSDR will release its findings to the community. During 2018, ATSDR implemented the ACAS to evaluate its risk communication efforts. One hundred and twenty-five surveys were collected from seven sites (62% paper/38% online). The results of the survey were as follows. The survey found that 73% of respondents believed ATSDR understood their health concerns, but 33% of respondents believed ATSDR had not given all the information they needed. Seventy four percent of respondents correctly identified ATSDR’s role at a site, but only 36% correctly identified the conclusion about the environmental risk. However, respondents thought their knowledge increased since ATSDR arrived (+31%). Collective-efficacy: 61.6% of respondents indicated that after ATSDR’s work finished, their community was more prepared to handle environmental risk(s). All emotion responses indicated a negative change (scale -1 to 1). Overall, the ACAS demonstrated the first efforts at quantifying ATSDR’s risk communication efforts and contributed to a lack of literature on environmental health communication outcomes. Results indicate ATSDR’s communication has impact on proximal outcomes (perceived knowledge, simple recall knowledge, collective-efficacy), but may not have as much impact on trust and emotions. Thus, the recent 2018 results were used to inform our proposed modifications to the ACAS instrument and methods to improve the agency’s future communication efforts with communities (detailed in Section A.15),

The ACAS received an NCEH/ATSDR Honor award for Excellence in Program Evaluation and was selected for a poster presentation at the 2019 Annual Meeting of the American Public Health Association.

A.3. Use of Improved Information Technology and Burden Reduction

The ACAS will be offered in two modes (hardcopy and online [Attachment F1-F2]) allowing respondents to complete questions in the most convenient manner of their choosing. The aim is to have the hardcopy ACAS self-administered, right after the public community meeting. If this not a convenient time for the respondent, it may be completed online using SurveyMonkey^®. An online survey allows respondents to complete the questions at their convenience and take as much time as they need. Due to the absence of embedded skip patterns, we do not expect the use of improved technology for the online survey to reduce the time to complete the survey (estimated as 15-minutes per response for both modes); however, ATSDR anticipates the flexibility offered via two collection modes will maximize the response rate and increase the quality of the agency’s data.

At select sites, ATSDR will be administering a very abbreviated four-question version of the survey via SMS (text) messaging. It is anticipated that we will utilize the abbreviated survey at very large community meetings where administering paper surveys is not practical or feasible.

From our time burden table in Section A.12, we estimate that 46.6 percent of the requested 58 hours of time burden will be spent using improved information technology (n=27 hours for the online ACAS and SMS Text Survey) as follows:

• A total of 16 burden hours per year (12 hours for community members and four hours for stakeholders) will result in 27.6 percent of the total burden hours being conducted using online survey methods (Attachment F2).

• A total of 11 burden hours per year (eight hours for community members and three hours for stakeholders) will result in 19.0 percent of the total burden hours being conducted using SMS text messaging (Attachment H).

Only the minimum amount of information necessary for the goals of this ICR will be collected.

A.4. Efforts to Identify Duplication and Use of Similar Information

ATSDR searched the literature and program records and documents and found no evidence of any current efforts by outside entities to ascertain the effectiveness and evaluate the differences and consistency of ATSDR activities including: efforts at delivery or implementation, community engagement, interactions, educational outreach efforts, and respondent perceptions across sites and over time; efforts to determine how effectively ATSDR’s site team engages community members; and efforts to discover how well ATSDR provides effective, clear and consistent communication and information on how to promote healthy and safe environments and prevent harmful exposures through the activities they implement in communities. This agency undertaking is unique and will allow ATSDR to continue to query the usefulness of our activities implemented in communities. No similar data are available from other sources known to the Division.

A.5. Impact on Small Businesses or Other Small Entities

No small businesses will be involved in this data collection.

A.6. Consequences of Collecting the Information Less Frequently

The purpose of this request is to ensure collection of data that are not otherwise available at each engaged site. Specifically, without this data, there would be:

• No information or timely feedback via the survey about the effectiveness of ATSDR activities including community engagement, interactions, educational outreach efforts, and informing communities. The survey is designed to measure the effectiveness of ATSDR’s ability to convey health risks and how people should respond to them.

• No information on the differences or consistency of ATSDR activities delivery or implementation, and respondent perceptions across sites and over time

• Less effective ATSDR activities implementation to assist communities and stakeholders in addressing environmental issues

• Limitations to effective and timely assessment of activities of government agencies to fulfill their public health mission.

There are no legal obstacles to reduce the burden.

A.7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

There are no special circumstances with this information collection package. This request fully complies with the regulation 5 CFR 1320.5 and participation will be voluntary.

A.8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

1. The 60-day Federal Register Notice was published on 04/03/2020, Vol. 85, No. 65; pp. 18977 (Attachment B). No public comments were received.

2. ATSDR developed the ACAS in 2017 using contractor support. Since that time, ATSDR has not had to consult with any outside partners, and staff are maintaining the data collection system.

A.9. Explanation of Any Payment or Gift to Respondents

In 2017, ATSDR was approved to provide incentives in the form of gift cards to community members who agreed to take the ACAS to increase ACAS response rates. As part of this reinstatement with change ICR, ATSDR will not continue to offer incentives.

A.10. Protection of the Privacy and Confidentiality of Information Provided by Respondents

Based on the proposed changes to this ICR, on 08/04/2020, the CDC Chief Privacy Officer (CPO) determined that the Privacy Act does not apply to this data collection from community members and from agency stakeholders. The Privacy Impact Assessment (PIA) is found in Attachment C.

Items of Information to be collected –

The following Information in Identifiable Form (IIF) Categories apply to this information collection. Collecting this information is necessary for ATSDR to contact the respondent who elected to take an online survey or a telephone text survey. ATSDR will delete the email address from the database as soon as the online response to the ACAS is received (Attachment F2). Through the Poll Everywhere software, ATSDR utilizes but will not save cell phone numbers during the SMS Text Survey polling ([Attachment H).

❑ Email Address (for administering the online ACAS [Attachment E&F2])

❑ Telephone number (for administering the SMS Text Survey [Attachment H])

ATSDR does not plan to retrieve responses for data analysis using any IIF. No contact information will be collected for those who wish to take the paper ACAS.

Overview of the Data Collection Systems –

ATSDR typically conducts community meetings at sites where agencies implement activities to address environmental issues. ATSDR will choose sites that will have community meetings to administer the ACAS or the SMS Text Survey only one time at the end of the community meeting. This is a post-only design where data is collected after the community meeting is held to limit burden.

Administration of the ACAS –

For each engaged community, the ACAS will be used to assess a set of effectiveness indicators for ATSDR site-specific activities including respondent involvement, knowledge, satisfaction, observations, opinions, and ATSDR community engagement, interactions, and educational outreach efforts to inform communities. These questions will help ATSDR understand how its activities are making an impact in addressing environmental issues in the communities it serves.

After each of approximately six to seven such meetings per year, ATSDR will have a table set up at the entrance where they will hand out a fact sheet to the community meeting attendees (Attachment D). The fact sheet explains what ATSDR does, and the purpose of ATSDR’s site activities and the survey options.

At the end of the meeting there will be an announcement to ask interested community meeting attendees to sign in with trained ATSDR staff (Attachment E). To protect the individual privacy of respondents, the survey administrators will first only record whether they prefer to take the ACAS in-person or online (Attachments F1-F2). Only if the online mode is preferred, respondents will be asked to record their email addresses on the ACAS Sign In Sheet (Attachment E).

Written consent will not be administered. The fact sheet and the sign in sheet will explain how respondents are asked to give voluntary consent. They will indicate they are 18 years of age or older and consent to participate in the survey by proceeding to answer questions on the survey. The first page of the ACAS will reiterate how respondents are asked to give voluntary consent.

The ACAS will preferably be self-administered by hardcopy (Attachment F1), right after the public community meeting. If this not a convenient time for the participant, the ACAS may be completed online via SurveyMonkey^® link (Attachment F2). An email containing the link to take the survey (Attachment G) will be sent to those that would like to take the survey online.

Proposed changes to the ACAS are detailed in Section A.15. The ACAS indicators below will measure ATSDR’s effectiveness in the following areas, which are mapped to the following questions:

• respondent affiliation (Question 1)

• how respondent received information from ATSDR and how they prefer to receive ATSDR information (Questions 2)

• knowledge and understanding of site activities (Questions 3-6)

• knowledge of how to reduce or prevent hazardous exposures at the site (Questions 7-9)

• knowledge of whom to contact at ATSDR (or state/local agency) (Question 10)

• observations and opinions of ATSDR site activities, including ATSDR’s understanding of respondent health concerns and whether respondent thinks ATSDR gave the information they need to address their environmental-related health concerns (Questions 11-14)

• observations and opinions of the community, and the community’s ability to address environmental issues (Question 15)

• questions on how the respondent feels at the time of taking the survey about his or her risk of exposure to possible environmental hazards at the site (Question 16)

• demographic questions to understand the make-up of the community participants as an aid in tailoring messages and activities to the audience (Questions 17-23)

• environmental concerns (Question 24)

• any additional feedback (Question 25)

These indicators will help ATSDR ascertain the effectiveness and evaluate the differences and consistency of ATSDR activities delivery and respondent perceptions across sites and over time; determine how effectively ATSDR’s site team engages community members; and discover how well ATSDR provides effective, clear and consistent communication and information on how to promote healthy and safe environments and prevent harmful exposures through the activities they implement in communities. This will help ATSDR understand whether their activities are helping the communities address environmental issues and how they may improve ATSDR’s activities to make a greater impact within the communities they serve.

The data collection tool is a survey consisting of 25 Likert-scale or open-ended questions divided into 7 sections.

• Section One (three questions) measures respondent involvement in site activities. The questions help ATSDR measure activities implemented in the communities, when and how the respondent first learned about potential hazards in their community, if they live or work near the site, how they prefer to receive communication about potential hazards in their community, and whether or not respondents have shared ATSDR information with others.

• Section Two (seven questions) measures respondent knowledge and understanding of ATSDR site activities. The focus of these questions is to gain insight into participant awareness of the information ATSDR has communicated to the community including understanding of the environmental hazard(s) at the site, what ATSDR does in communities, what respondents should do to prevent contact with potential hazards, what they should do if they come in contact with potential hazards, and ATSDR contact information.

• Section Three (four questions) attempts to learn about respondent observations and opinions about ATSDR site activities and whether respondents feel like ATSDR understands their health concerns and has given all the information needed to address health concerns.

• Section Four (one question) learns about respondent observations and opinions about their community and their community’s ability to address environmental issues.

• Section Five (one question) asks the respondent to answer how they feel about their risk of exposure at the time of taking the survey.

• Section Six (seven questions) asks about respondent demographics including age, gender, race/ethnicity, employment, education, and number of children.

• Section Seven (two open-ended questions) asks respondents if they have any other concerns related to environmental hazards that the survey didn’t ask or if they have any further feedback.

Administration of the Abbreviated SMS Text Survey –

At select sites per year, where it is deemed that text messaging surveys will be more effective due to meetings with large numbers of attendees, an abbreviated SMS Text Survey will be offered in lieu of the paper or online ACAS. There will be no sign-in sheet for the SMS Text Survey. Respondents in the SMS Text Survey will give voluntary consent via SMS response only. Respondents will not have to provide their phone number, or any contact information.

ATSDR will administer the SMS Text Survey in the following manner. Respondents will be notified by ATSDR that at the end of the meeting that a voluntary four-question survey will be administered via text messaging. At the beginning of the survey, a PowerPoint slide with the burden statement and consent will be shown (Attachment H). Respondents who consent will be asked to text a code to enable them to participate in the SMS survey, after which each of four questions (three taken from the ACAS survey Questions 6, 9, and 14 and one additional one) will be shown. Then they will respond by texting their answers to the questions to a number generated by Poll Everywhere™ software. Results of the survey will be displayed in real time on the screen.

How ACAS and SMS Text Survey Responses will be Stored and Managed –

ACAS responses from all completed paper surveys will be entered in SurveyMonkey^®, along with the online responses, and stored in Stata^® statistical software package used for managing, analyzing and graphing data. Responses from all SMS based surveys will be stored in Excel spreadsheets for managing, analyzing, and graphing data. No IIF will be used in ATSDR reports and all IIF will remain private to the extent allowed by law.

A.11. Institutional Review Board (IRB) and Justification for Sensitive Questions

The ACAS collection will not yield data that can be generalized. The NCEH/ATSDR Human Subjects Contact has determined that this data collection is not research (Attachment I). The purpose of this non-research activity is to assess or improve a public health program or service. Intended benefits of the project are primarily or exclusively for the respondents or their community. Knowledge that is generated does not extend beyond the scope of the activity.

No information will be collected that is of a personal or sensitive nature.

A.12. Estimates of Annualized Burden Hours and Costs

Estimated time and cost burden information for respondents is shown in Table A.12.1 and in Table A.12.2, respectively.

ATSDR will continue to recruit an annual total of approximately 167 individuals per year (n=24-28 individuals per site each year), aged 18 and older, to participate in the ACAS where ATSDR is holding a public community meeting. ATSDR is estimating that 200 additional individuals will participate in the SMS Text Survey where meeting attendance is high. As previously estimated in 2017, the mix of respondents will be approximately 75 percent community members (n=275 per year) and 25 percent agency stakeholders (n=92 per year).

When the ACAS is offered, we estimate that approximately 28.1 percent of annual respondents will choose the self-administered ACAS (Attachment F1), and 17.4 percent will choose the online ACAS (Attachment F2). We estimate that 54.5 percent of the annual respondents will take the abbreviated SMS Text Survey (Attachment H). The total time burden requested is 58 hours per year.

Table A.12.1: Estimated Annualized Burden Hours

Type of Respondents	Form Name	No. of Respondents	No. of Responses per Respondent	Avg. Burden per Response (in hrs.)		Total Burden (in hrs.)
Community Members	ACAS Sign-In Sheet	125	1	2/60		4
	Hardcopy ACAS	77	1	15/60		19
	Online ACAS	48	1	15/60		12
	SMS Text Survey	150	1	3/60		8
Agency Stakeholders	ACAS Sign-In Sheet	42	1	2/60		1
	Hardcopy ACAS	26	1	15/60		7
	Online ACAS	16	1	15/60		4
	SMS Text Survey	50	1	3/60		3
Total					58

Estimates for the average hourly wage for community members and agency stakeholders are based on the May 2019 National Occupational Employment and Wage Estimates (see http://www.bls.gov/oes/current/oes_nat.htm#11-0000). We assume that the mean community member hourly wages are $25.72 based on all occupations. We assume that mean agency stakeholder hourly wages are $37.47 based on Occupation Code 19-2041 (Environmental Scientists and Specialists). There are no costs to the respondents or participants other than their time. The total respondent cost burden requested per year is $1,668.01.

Table A.12.2: Estimated Annualized Burden Costs

Type of Respondent	Form Name	Total Burden Hours	Hourly Wage Rate	Total Respondent Costs
Community Members	ACAS Sign In Sheet	4	$25.72	$102.88
	Hardcopy ACAS	19	$25.72	$488.68
	Online ACAS	12	$25.72	$308.64
	SMS Text Survey	8	$25.72	$205.76
Agency Stakeholders	ACAS Sign In Sheet	1	$37.47	$37.47
	Hardcopy ACAS	7	$37.47	$262.29
	Online ACAS	4	$37.47	$149.88
	SMS Text Survey	3	$37.47	$112.41
Total				$1,668.01

A.13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers

There will be no direct costs to the respondents other than their time to participate in the ACAS.

A.14. Annualized Cost to the Federal Government

There are no equipment costs. The only costs to the federal government would be the hourly wage and travel for ATSDR staff for data collection activities and associated tasks.

The survey data collection tool was prepared by ATSDR staff. ATSDR will recruit, obtain consent from respondents, and administer the survey once per respondent after each community meeting in-person, or send an email link for an online survey, or by phone. Data analysis of the survey findings and reporting including a draft document for internal and external dissemination will be conducted by ATSDR as well. The estimated cost to the federal government is $19,049 per year. Table A.14.1 describes how this cost estimate was calculated.

Table A.14.1: Estimated Annualized Cost to the Federal Government

Staff (FTE)	Average Hours per Collection	Average Hourly Rate	Average Cost
ATSDR Project Officer (GS-14/10, FTE) Review and oversee OMB package preparation, project management, quality control	100	$70.75	$7,075
ATSDR Project Staff (GS-13, FTE) Data collection, oversight, consulting states to implement survey, consultation with staff lead on OMB package preparation, quality control	200	$59.87	$11.974
Total ATSDR Staff Cost			$19,049
Estimated Annual Cost of Information Collection			$19,049

A.15. Explanation for Program Changes or Adjustments

ATSDR has assessed its recent uses of the ACAS and proposes several changes to increase the utility and efficiency of this survey.

Changes in ACAS Methods

Based on the agency’s experience, ATSDR is changing the following ACAS methods to improve the utility and efficiency of the information collection: dropping incentives for community members; dropping the telephone ACAS; and pilot testing an abbreviated cell phone survey. Table A.15.1 shows how these changes were addressed across attachments previously approved by OMB in 2017.

Table A.15.1: Summary of Attachment Changes

Attachment		Change in Methods by Attachment
		Drop Incentives	Drop Telephone ACAS	Add SMS Text Survey
Att_D	Community Meeting Fact Sheet	X – delete incentives		X – add SMS Text Survey
Att_E	ACAS Sign-In Sheet	X – delete incentives	X – delete name, address, type of respondent; keep survey mode requested, email address (only for those who choose online ACAS)*	X –not used for SMS Text Survey
Att_E1*	Sign-In Sheet Aid	X – delete form in entirety	X – delete form in entirety	X –not used for SMS Text Survey
Att_F1	Hardcopy ACAS †	X – delete incentives	---	X –not used for SMS Text Survey
Att_F2	Online ACAS †	X – delete incentives	---	X –not used for SMS Text Survey
Att_F3	Telephone ACAS ‡	X – delete form in entirety	X – delete form in entirety	X –not used for SMS Text Survey
Att_G	Initial Email for Online ACAS Link	X – delete incentives	---	X –not used for SMS Text Survey
Att H * (renumbered)	Reminder Emails for Online ACAS; replace with SMS Text Survey	X – delete email in entirety	X – delete email in entirety	X – add SMS Text Survey
Att I * (renumbered)	Thank You Letter for Online ACAS; replace with Research Determination	X – delete thank you letter in entirety	X – delete thank you letter in entirety	---
* Att_E - delete name and address; no longer mailing incentives; record email address only for those who choose online ACAS Att E1 – removed in its entirety because the respondent type will be removed from the ACAS Sign-in Sheet (Att E). Att H – formerly Reminder Emails for Online ACAS – removed due to lack of ATSDR resources; replace with new Att H (SMS Text Survey) Att_I - formerly Thank You Letter for Online ACAS – removed; no longer mailing incentives; replace with new Att I (Research Determination)
† Att_F1 and Att_F2 – see question modification below
‡ Att_F3 - delete in entirety; During 2018, 125 surveys were collected from seven sites (62% paper/38% online). Given that no telephone surveys were requested by respondents, ATSDR proposes to eliminate this ACAS mode of collection.

Changes to ACAS

ATSDR has modified the consent statement because the agency is no longer collecting participant contact information on the ACAS Sign In Sheet (Attachment E) for those who choose the hardcopy ACAS (Attachment F1), but will collect email addressed for those who choose the online ACAS (Attachment F2).

In 2020, ATSDR seeks to add three additional questions to the survey. These new questions will address data gaps identified during the first administration of the survey. ATSDR is also removing one 2017 question because it did not provide useful data.

Table A.15.2: ACAS Question Modifications (Attachment F1-F2)

	2020 (replace/add)	2017 (remove)
Question 1 (replace)	Please identify yourself. 1 Community member 2 Federal, State, or Local health or environmental department employee 3 Other.	Before this public meeting, when did you first find out about the environmental risk(s) at (insert name of site here)__________________________________________________? 1 I didn’t know about it before this meeting 2 I don’t remember 3 Specify Month and Date or Approximate time of year (e.g., Summer 2015)____________________
Question 13 (add)	How would you rate the overall readability of ATSDR’s report on this site? 1 Very easy to read 2 Somewhat easy to read 3 Somewhat difficult to read 4 Very difficult to read 5 I have not read the report	n/a
Question 14 (add)	Please rate your overall experience with ATSDR on a scale of 1 to 5 with 5 being the best experience possible. _1 2 3 4 5	n/a
Additional Changes	Former Questions 13 – 23 renumbered as Questions 15 – 25, with addition of two new questions.	n/a

Changes in Burden Estimation for the ACAS

The preliminary ACAS time burden estimate was obtained in 2017 as follows. A community meeting was held in July 2015, in Lockhart, SC, related to the Bennett Landfill fire in Chester, SC. Eight months after this community meeting was held, trained ATSDR contractors pilot tested the ACAS data collection tool among 5 community meeting attendees. The 2017 estimate for burden hours was based upon this pilot test. In the pilot test, the average time to complete the survey data collection tool including time for reviewing instructions, gathering needed information and completing the survey, was approximately 30 minutes. Based on the pilot test results, ATSDR reduced the number of questions and the ACAS time burden to 15 minutes per response, regardless of data collection mode. This estimate remains unchanged in the 2020 ACAS, as replacing one question and adding two more are not expected to appreciably change the 15-minute time burden per response (Attachment F1-F2).

In 2017, we estimated that approximately 80 percent of respondents would choose the self-administered hardcopy ACAS (n=100 community members and n=34 agency stakeholders per year), 15 percent will choose the online ACAS (n=19 community members and n=6 agency stakeholders per year), and 5 percent will choose the telephone ACAS (n=6 community members and n=2 agency stakeholders per year, or 6 over the next three years).

Our experience showed that more respondents chose the online survey than initially expected, and that no respondents chose the telephone survey. During 2018, 125 surveys were collected from seven sites (62% paper/38% online). Thus, we updated our estimates for 2020 such that 62 percent of ACASs will be self-administered by hardcopy (n=77 community members and n=26 agency stakeholders per year), 38 percent of ACASs will be administered online via SurveyMonkey^® (n=48 community members and n=16 agency stakeholders per year), and the telephone survey option will be eliminated.

Changes in Burden Estimation by Adding the SMS Text Survey

For the SMS Text Survey (Attachment H), ATSDR anticipates that an additional 200 respondents will consent to this abbreviated SMS text survey each year. The consent statement for the SMS Text Survey is the same as for the hardcopy ACAS (Attachment F1) because ATSDR will not use the sign-in sheet to collect respondent cell phone numbers (Attachment E) for meetings where the number of participants is large and the SMS Text Survey will be administered. We estimate that the SMS Text Survey will take three minutes per response.

Table A.15.#: SMS Text Survey (Attachment H)

	2020	Source
Question 1	Has ATSDR helped you to better understand the environmental risk(s) at this site? 1 Yes 2 No 3 Some, But Not All 4 Don’t know	ACAS Question 6 (original)
Question 2	Since ATSDR came into your community, do you NOW know more about what you and your family should do to avoid contact with the environmental risk(s) at the site? 1 Yes 2 No 3 Don’t know	ACAS Question 9 (original)
Question 3	Please rate your overall experience with ATSDR on a scale of 1 to 5 with 5 being the best experience possible. _1 2 3 4 5	ACAS Question 14 (new)

Therefore, ATSDR will recruit and sign up an annual total of approximately 367 individuals per year (n=52-61 individuals per site each year, adding 200 SMS Text respondents to the 167 ACAS respondents), aged 18 and older, where ATSDR is holding a public community meeting. As previously described in 2017, the mix of respondents will be approximately 75 percent community members (n=275 per year) and 25 percent agency stakeholders (n=92 per year). Of the 367 who sign up, we estimate that approximately 28.1 percent of respondents (n=103) will choose the self-administered ACAS (Attachment F1), 17.4 percent (n=64) will choose the online ACAS (Attachment F2), and 54.5 percent (n=200) will choose the abbreviated SMS Text Survey (Attachment H).

Table A.15.3: Summary of Changes to Burden Estimation from 2017 to 2020.

Type of Respondents	Form Name	No. of Responses		Total Burden (in hrs.)		Net Change in 2020
		2017	2020	2017	2020	Responses	Hours
Community Members	ACAS Sign-In Sheet	125	125	4	4	0	0
	Hardcopy ACAS	100	77	25	19	-23	-6
	Online ACAS	19	48	5	12	+29	+7
	Telephone ACAS	6	---	2	---	-6	-2
	SMS Text Survey	---	150	---	8	+150	+8
Agency Stakeholders	ACAS Sign-In Sheet	42	42	1	1	0	0
	Hardcopy ACAS	34	26	9	7	-8	-2
	Online ACAS	6	16	2	4	+10	+2
	Telephone ACAS	2	---	1	---	-2	-1
	SMS Text Survey	---	50	---	3	+50	+3
Total		334	534	49	58	+200	+9

Thus, ATSDR is requesting an increase of 200 responses and an increase of 9 burden hours in 2020. These increases are based on the addition of the proposed pilot of the abbreviated SMS Text Survey. Eliminating the telephone ACAS and redistributing the respondents to hardcopy ACAS and online ACAS modes of collection results in no net change in the number of responses and no net change in the ACAS time burden.

Potential Changes due to the COVID-19 Pandemic

Over the next three years, ATSDR may find it necessary to modify its meeting logistics due to the COVID-19 pandemic, and its information collection may be adapted to incorporate COVID-19 precautions. Adaptations might include changing to virtual meetings as an alternate meeting format. In this case, ATSDR may need to reinstate the use of the previously approved Telephone ACAS, which ATSDR has planned to discontinue, in addition to increasing the use of the Online ACAS (Attachment F2). Where ATSDR needs to attend in-person meetings, the use of social distancing, hygiene practices, and the use of face masks will be incorporated, ATSDR will incorporate safe practices based on its own field experience, in addition to a commitment to adhere to the CDC guidelines and with state and local ordinances at that point in time.

A.16. Plans for Tabulation and Publication and Project Time Schedule

Results of this survey will be shared internally with ATSDR leadership and staff across the agency and disseminated externally to stakeholders and partners through annual reports and budget performance narratives that will be posted via the internet. The data will help ATSDR understand whether their activities are helping the communities address environmental issues and how they may improve ATSDR activities to make a greater impact within the communities they serve. SurveyMonkey^® will be used for a simple analysis of the survey data and the online tool can produce the following types of analysis: charts; trends; data tables; basic statistics that show you the minimum, maximum, mean, median, and standard deviation. ATSDR will tabulate the frequency of the responses to each question (e.g., the number that responded yes, no, or don’t know), and the percentage of responses to each question. In addition, the Likert scale will be calculated based on how they feel about the risk they face in terms of the 11 emotions. ATSDR will report the number and percentage of responses to each of the questions and develop a composite score to characterize the respondents’ overall emotional response. It may include a comparison of the percentage that responded with more positive emotions less those that responded with more negative emotions, calibrated for whether the emotion itself is positive or negative. For the questions about the demographics, ATSDR will report the number and percentage of responses for each. It will create cross-tabulations between these date and other responses to the questionnaire. Stata^® statistical software will be used for managing, analyzing, and graphing data. Survey data will be analyzed using a simple paired t-test of the difference in proportions, analysis of variance (ANOVA), and/or mediation/moderation analysis.

Project Time Schedule

• Prepare OMB package………………………………………………………………. (COMPLETE)

• Submit OMB package………………………………………….…………………….. (COMPLETE)

• OMB approval………………………………………………………………..………… (3-6 months)

• Administer surveys at chosen site………….……………………….………… (24-28 weeks)

• Collect, enter, quality control, and analyze data……………………….… (4-6 weeks)

• Prepare report…………………………………………………….…………………… (2 weeks)

• Disseminate community results/reports………………...………………… (x weeks)

A.17. Reason(s) Display of OMB Expiration Date is Inappropriate

We are requesting no exemption.

A.18. Exceptions to Certification for Paperwork Reduction Act Submissions

There are no exceptions to the certification. These activities comply with the requirements in 5 CFR 1320.9.

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