1 Information Collection Request Supporting Statement   Part A 1. Identification of the Information Collection 1( a) Title of the Information Collection Delisting the Fish Tainting Beneficial Use Impairment in the Saginaw River/ Bay Area of Concern 1( b) Short Characterization/ Abstract Chemical odors and tastes associated with harvested fish were frequently reported from the 1940s through the 1970s in the Saginaw and Tittabawassee Rivers, and in the Saginaw Bay. In the 1994 Remedial Action Plan Update, the Michigan Department of Natural Resources reported that no off flavor was detected in taste tests conducted on fish taken from these waters. Since taste and odor complaints related to edible fish taken from both Saginaw River and Bay have disappeared in recent years, this project will conduct a survey of local residents and anglers to determine if taste and odor problems in fish fillets have abated to the extent that delisting of the beneficial use impairment may be recommended for the Area of Concern ( AOC).

2. Need for and Use of the Collection 2( a) Need/ Authority for the Collection The Saginaw River and Bay was designated by the International Joint Commission ( IJC) as one of the major pollution areas in the Great Lakes in 1973, a year after the first Great Lakes Water Quality Agreement between the United States and Canada was signed   a commitment by both countries to cooperatively manage their shared water resources and recommend actions for protection. Objectives were specified that would reduce nuisance conditions and the discharge of substances toxic to human, animal, and aquatic life. Saginaw River/ Bay was designated as one of 43 Areas of Concern ( AOCs) because degraded water quality conditions impaired certain beneficial uses as defined by the Agreement. The 1988 Saginaw River/ Bay RAP cited 12 impairments of the 14 categories specifically listed by the IJC for the Saginaw River/ Bay AOC, including tainting of fish ( i. e., taste and odor concerns).

2( b) Practical Utility/ Users of the Data Taste and odor complaints related to fish taken from either Saginaw Bay or the lower portions of the Saginaw River watershed have nearly disappeared in recent years. Given the magnitude of the historical problem of fish tainting in the bay and the river, a survey of anglers and community representatives will be conducted to determine if a significant problem still exists, and if it does, whether it is confined to specific areas where contributing sources can be addressed. The State of Michigan may petition for delisting of the fish tainting BUI if the project confirms that restored conditions are being met. 2 EPA will also use the information received to monitor the progress of cleanup activities taking place in the watershed.

3. Non duplication, Consultations, and Other Collection Criteria 3( a) Non duplication All information requested from respondents under this ICR can be broken into 2 samples: general population and anglers within the Saginaw Bay Watershed.

3( b) Public Notice Required Prior to ICR Submission In compliance with the 1995 PRA, any agency developing a non rule related ICR must solicit public comments for a 60 day period prior to submitting the ICR to OMB. The announcement of a public comment period for an initial or renewal ICR must be made in the Federal Register. The 60 day comment period was initiated on Dec. 16, the date the FR Notice was published.

3( c) Consultations No respondents have been consulted concerning this ICR.

3( d) Effects of Less Frequent Collection This collection is one time only   it will not have periodic reporting or record keeping.

3( e) General Guidelines This collection does not violate any OMB guidelines.

OMB guidelines:

Justify any provision under which respondents would:

Report information to the Agency more often than quarterly

Prepare a written response to a collection of information in fewer than 30 days after receipt of a request

Submit more than an original and two copies of any document

Retain records, other than health, medical, government contract, grant in aid, or tax records for more than three years

Participate in a statistical survey that is not designed to produce data that can be generalized to the universe of the study

Utilize a statistical data classification that has not been reviewed and approved by OMB 3

Receive 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 which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or

Submit proprietary, trade secret, 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.

3( f) Confidentiality All collected information will be stored on contractor ( Public Sector Consultants Inc.) personal computers. Other than EPA staff, only the contractor will be viewing this information. All hardcopies will be stored on contractor premises.

3( g) Sensitive Questions There are no sensitive questions asked in this questionnaire.

4. The Respondents and the Information Requested 4( a) Respondents/ SIC Codes All respondents to this ICR will be members of the general public, including anglers and non anglers. SIC codes do not apply in this instance.

4( b) Information Requested i) Data items, including record keeping requirements All record items are reporting items   records will not need to be retained by respondents. The respondents will need to complete a questionnaire and return it to the contractor for analysis.

ii) Respondent Activities Members of the public, including anglers, will receive the questionnaire via U. S. Mail. The respondents will need to review the survey's purpose and brief instructions in order to complete the questionnaire. The questions that are being asked should be easily answered by the respondents. The respondents will then need to transmit the completed questionnaire back to the contractor in a postage paid return envelope.

5. The Information Collected   Agency Activities, Collection Methodology, and Information Management 4 5( a) Agency Activities Agency activities associated with completing the public questionnaire consist of the following:

Review and approve questionnaire developed by contractor; Review survey analysis conducted by contractor; Review and approve recommendations resulting from the survey data. Distribute survey results to EPA program managers and the Michigan Department of Environmental Quality 5( b) Collection Methodology and Management In collecting and analyzing the information associated with this ICR, the contractor will use a hardcopy survey distributed via U. S. Mail. EPA will oversee the contractor to ensure the accuracy and completeness of collected information by reviewing data collection and analysis techniques. Postage paid envelopes will be provided to respondents to return the completed questionnaire.

5( c) Small Entity Flexibility No small entities are required to respond to this collection request. It is a survey of the general public.

5( d) Collection Schedule The following dates reflect the intended dates associated with this information collection.

These dates are only estimates.

Questionnaire sent out to proposed respondents: August 15, 2005 Due date: September 15, 2005 6. Estimating the Burden and Cost of the Collection 6 ( a), ( b) Annual Respondent Burden and Cost EPA estimates no financial burden nor costs for respondents. There is no equipment, machinery and/ or construction necessary for this information request; therefore there are no capital and/ or operations and maintenance costs associated with this ICR for the respondents or the Agency. Respondents will be provided a postage paid envelope to return the mail survey.

6 ( c) Estimating Agency Burden and Cost EPA estimates an average hourly labor cost of $ 70.00 for managerial staff and $ 45.00 for technical staff.

6 ( d) Estimating the Respondent Universe and Total Burden and Costs 5 Estimating the respondent universe: There is a total of 7,680 surveys that will be mailed. There is no financial burden nor costs to survey respondents.

6 ( e) Bottom Line Burden Hours The development of the survey instrument, mailing lists, and mailing costs are estimated to total $ 12,300. Thus EPA's cost burden is $ 12,300 because the survey is being conducted by a private contractor.

6 ( f) Burden Statement The respondent burden is estimated to average .5 hours per respondent. A total of 1,536, or 20 percent, of respondents are expected to reply to this request. This estimate includes completing the questionnaire by and sending it back to the contractor.

Burden means the total time, effort, or financial resources expended by persons to generate, maintain, retain, or disclose or provide information to or for a Federal agency. This includes the time needed to review instructions; develop, acquire, install, and utilize technology and systems for the purposes of collecting, validating, and verifying information, processing and maintaining information, and disclosing and providing information; adjust the existing ways to comply with any previously applicable instructions and requirements; train personnel to be able to respond to a collection of information; search data sources; complete and review the collection of information; and transmit or otherwise disclose the information. An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB control number. The OMB control numbers for EPA's regulations are listed in 40 CFR Part 9 and 48 CFR Chapter 15.

Information Collection Request Supporting Statement   Part B 1) Introduction The goal of this project is to assess current taste and odor concerns relating to locally caught fish in the Saginaw River/ Bay Area of Concern. Survey research will be used to assess public opinion relating to chemical odors and tastes, associated with fish harvested in the Saginaw River, the Tittabawassee River, and Saginaw Bay ( frequently reported from the 1940s through the 1970s). The outcome of the survey research will dictate next steps. A petition for delisting of the fish tainting BUI will be initiated if the project confirms that restored conditions are being met. If a significant problem still exists, the survey design will be able to identify specific areas where contributing sources remain and recommend actions.

2) Sections 1 and 2: Survey Objectives, Key Variables, and Survey Design 6 Survey Objectives A survey of anglers and community representatives will be conducted to determine if fish tainting and odors still exists in edible fillets, and if it does, whether it is confined to specific areas where contributing sources can be addressed. A petition for delisting of the fish tainting BUI will be initiated if the project confirms that restored conditions are being met.

Key Variables Fishermen are likely to have opinions about the quality of fishing in the watershed, whether they are actively fishing the area or are merely talking to friends who are actively fishing the area. If fishermen themselves do not perceive an increase in the quality of fish stock or decreases in the problems with taste and odor, then the project is not likely to succeed. However, talking only to fishermen is likely to yield a biased read of public opinion   statewide, fishing licenses are sold to one of every ten residents. Therefore, the project managers and the EPA cannot use the survey results as a definitive guide to what the public perceives, since roughly 90 percent are not fishermen.

A potential divide between the opinions of fishermen and the general public on issues of contamination and fish quality is no more or less likely than differences in opinion between any group with specialized knowledge and the general public. This project, however, complicates or exacerbates the potential divide in two ways:

  Environmental issues, especially ones that seek to declare a past problem " solved" or " remediated", are often accompanied by intense public opinion that may often be based on past knowledge/ perceptions rather than the current situation. Therefore, any debate may need to be coordinated with an education/ outreach campaign to educate the general public on how conditions have changed from previous years.

In this specific area, there is an existing water quality issue in the Tittabawassee River surrounding the potential contamination with Dioxin from the nearby Dow Chemical Company manufacturing facility. This issue has been extremely visible in the local community as a result of Department of Environmental Quality and EPA efforts to negotiate a cleanup settlement. Therefore, conducting a companion survey of the general public will help   gauge their general knowledge of improved water quality issues in the watershed and fish stock ( as existing/ potential consumers of locally caught fish),

  test whether ( and how strongly) the public links the dioxin issue to the delisting issue, even if the two are scientifically unrelated, and   examine public opinion about delisting in particular. 7 A general public survey alone, however, would overstate the perception of precisely the members of the public that lack the specialized knowledge   remember, only approximately 1 in 10 Michigan residents have a fishing license. A combination approach that seeks to elicit and examine the perceptions of both fishermen and the general public will provide the best information to the project team.

Survey Design Survey Design Development, production, and execution of survey instrument ( single page, 2 sides), data analysis, report writing, and petition for delisting ( if applicable) will be conducted. The critical test for any such process and associated criteria is to insure that it is rigorous, scientifically defensible, and allows for full review and comment from interested and affected stakeholders.

Two samples   all type 1 counties ( regardless of size) and all type 2 counties ( regardless of size) will be drawn. Both groups have well over 100,000 people ( population and fishermen), so rules of large samples apply. Surveying either population for each county type requires 384 interviews with a margin of error of +/ 5 percent. Therefore, 4 surveys ( type 1& 2, fishermen and population) would require 1,536 completed interviews ( 384 x 4 = 1,536). To achieve the 20 percent response rate, 7,680 surveys ( 1,536 / .2 = 7,680) will be mailed. 8 Category County Fish License Sales Population ( 2000 Census) Sales per 1,000 people 1 large Bay 21,088 110,157 191 1 large Genesee 36,726 436,141 84 1 large Midland 11,488 82,874 139 1 large Saginaw 19,360 210,039 92 1 mid Isabella 8,316 63,351 131 1 mid Tuscola 6,727 58,266 115 1 small Arenac 8,824 17,269 511 1 small Gladwin 8,818 26,023 339 2 large Lapeer 7,620 87,904 87 2 large Livingston 13,553 156,951 86 2 large Oakland 53,835 1,194,156 45 2 mid Gratiot 4,502 42,285 106 2 mid Mecosta 12,810 40,553 316 2 mid Montcalm 12,200 61,266 199 2 mid Sanilac 5,627 44,547 126 2 mid Shiawassee 6,149 71,687 86 2 small Clare 14,954 31,252 478 2 small Huron 11,648 36,079 323 2 small Iosco 21,752 27,339 796 2 small Ogemaw 7,111 21,645 329 2 small Osceola 5,091 23,197 219 2 small Roscommon 23,335 25,469 916 Total 321,534 2,868,450 112 When grouped, the totals look like this:

Category Population License sales 1 large 839,211 88,662 1 mid 121,617 15,043 1 small 43,292 17,642 Total, type 1 1,004,120 121,347 2 large 1,439,011 75,008 2 mid 260,338 41,288 2 small 164,981 83,891 Total, type 2 1,864,330 200,187 The distribution of both population and sales when grouped is good news on the survey side; all categories have at least 15,000 data points, which is plenty to draw a sample from.