responsive documents - crew: epa: regarding proposed foia tracking system: 9/26/2011 - epa documents

8/4/2019 Responsive Documents - CREW: EPA: Regarding Proposed FOIA Tracking System: 9/26/2011 - EPA Documents

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Agenda Background

Program overview Governance Data flows Features and functions Open Govt

Results of Technical An Feasibility Screens of possible FOIA

New Issues FOIA dashboard

Next Steps


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eRulemaking Program: Vision: Citizens can easily access anefficient, and open federal rulemaking Goals:

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Scope: Federal-wide program (EPA is th Projects: Regulations. gov: Public interface tonon-rulemakings (e.g., environmental imguidance, in formation collections, privacy

FDMS.gov: Government-wide systemAgencies to centrally manage the rule Regulations.gov/Exchange: new futools for Regulations.gov

Funding Cross-agency workgroup estimates P Agencies pay usage fees to EPA thro


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Governance: Multiple levels of crocollaboration

Executive CommitteeCo-chaired by EPA and 0MB38 agency representatives

Advisory BoardChaired by eRulemaking PMO40 agencies participate

BudgetWorkgroup


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Architecture: Data Flows, Partners,

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Regulations.qov Features Usage:

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Benefits One-stop Access Transparency Trusted Source Public Participation Cost Savings

Features Search all rulemakings Download & printdocuments Comment by Web form Full text search Bookmarking & emailalerts RSS, Site Maps

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Technical Analysis4 Results

Extending Federal Docket(FDMS) is technically feasiaccomplished via two diffe

Technical infrastructure Sufficient capacity using ex

network, security, bandwidsupport federal-wide FOIA Approach

Create new public web por Create new secure Agencyscreens, user roles, workflto meet FOIA needs


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The target audience is thegeneral public, so the sitemust be approachable. Userstend to read personal storiesmore frequently than anyother text on a site.2. The first thing users look for

when they enter a site iswhat they can do or click.Top tasks make the site moreactionable. User testingwould help to validate theseitems as the top tasks.3. A purpose statement tellsusers what FOIA is in 25words or less. It is followedby a call to action.4. Below the fold, the footercontains the site map directlyin it for quick and easynavigation. This is similar tothe format ofwhitehouse.gov.

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1. The FOIA branding ties into the long-term goal of makingthis site government-wide. I would recommend a moremodern, simple logo to reflect that the website has beenrefreshed and is now easier to use.2. The agency name appears just above the FOIA logo, and auser can change agencies by clicking the arrow.3. The social bookmarking feature used on Regu(ations.gov

can also be used here to allow a user to email, print orbookmark any page.


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1. This wizard-style form walksusers through the requestprocess step by step, withoutoverwhelming them.2. Agency defaults to the agencyssite the user is on. A drop-downmenu makes it easy to change.

By selecting the agency on thispage, the next page can populatethe different regions for thatagency.3. The form instructions say thatpeople requesting informationabout themselves must signunder penalty of perjury. Ifsomeone responds Yes to this

question, we can insert anelectronic signature checkbox onthe next page with the wordingunder penalty of perjury.

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1. Use simple terms that the generalpublic will be able to easilyunderstand. Write the contentbetween a 4h and 8h gradereading level.2. Provide additional information onthe main task the user will do onthis site, make a FOIA request.3. Related links are expected to beon the right. This follows theformat of the About page onRegulations.gov.

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FAQs

1. Group frequently asked Ern-erptocnon A;cncy Vquestions into generalinformation plus top tasks. FOIAFreedom of Information Act

2. Expand!collapse answers so thatusers can read answ ers withoutnavigating away from the screen. Frequently Asked Questions (FAQHectic FAOa

3. Include conta ct information here General informa tionas well. What is FOIA?What is the Privacy Act?What records are exempt from FOIA?What are reading rooms?Where are the policy) guidance documents?

Making a FOIA requestHow do I make a FOlk request?What is the response time2Am I eligible for expedited pracesing?Whatfees are associated with a FOIA request?Am I eligible for a fee waiver?

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Envrronmer.tel Prvt ectrvn Anncy V

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Hand Delivery National Freedom of InformationU S Envircnmental Protection A1301 Constitution Avenue. NW.Washington, D C 20004

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lectronic FOIA Relizing FDMS FrailysisIay 6, 2010

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Document Change HistoryVersion Date Author Description of CV 1.0 May 6, 2010 Em ily Miller Init ial Draft


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Office of In formation Collection Electro

Table of Contents

1. Introduction2.1 Purpose2.2 Assumptions2.3 Proposed Phases2.4 Document Organization

2. Implementation Options2.5 Option 1: Leveraging Ex isting Framework2.6 Option 2: Leveraging Tools and Infrastructure with New Components

3. Suitability Analysis2.7 Infrastructure2.8 Functionality

4. Role Descriptions5. Processes6. RecommendationAppendix A: AcronymsAppendix B: FOIA RequirementsAppendix C: As-Is FOIA Process Maps


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Office of Information Collection Electron

1. IntroductionThis document analyzes the feasibility of incorporating the current EPA FInformation Act (FOIA) response procedures into the existing Federal DocSystem (FDMS) infrastructure in order to leverage the existing public-facinwell as reduce costs. In addition, this analysis will also present the resultsnew functionality available to the FOIA programs from the eRulemaking inas additional capabilities, as requested by the FOIA response team. Exisbetween the programs include public intake, public search and browse, Aprocessing, content storage and display, and inter- and intra-Agency user

PurposeThis document will describe the results an analysis which includes a respfol low ing questions:

1. Based on the requirements, where/how can FDMS be leveraged?2. What are the gaps for functionality that cannot be met through FDMSsolutions?

3. How can the tool potentially interact with other existing EPA FOIA sy4. What are the summarized options, with cost and recommended apprAssumptionsThe following assumptions were made when compiling this document.

1. Privacy Act requests are currently out of scope for this analysis2. This analysis was completed in support of EPA FOIA responses fihowever when possible, it includes more standardized language3. We assumed that not all manual processes will be incorporated in

platform; however, several additional requirements have been capplanning.

Proposed PhasesPhase 1: Create a public-facing website for receiving and tracking FOIAcapability to collect, manage and respond to requests with workflow, inclucollection from current system; store, categorize and retrieve (search) FOoptional user profile data; browse reading rooms.Phase 2: Connect to applicable NARA and DOJ systems to pass data reg


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Office of Information Collection Electro

Section 2: Intersection AnalysisDiscusses the as-is processes apotentially intersect within the FD M S frameworkSection 3: OptionsDescribes the various options for inco rpora tingSection 4: RolesDescribes the po tential new roles that co uld be aSection 5: Process MapsDetails the steps involved for the futureSection 6: RecommendationSummarizes the recommended op tiAppendix A: AcronymsAppendix B: FOIA Program RequirementsAppendix C: As-Is FO IA Process Maps


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Office of In formation Collection Elect

2. Implementation OptionsThis section presents two options for go ing forward with inc lus ion of FOIFederal Docke t Management System framew ork. Options includeinfrastructure/technology framework changes, screen changes/additionsscanning options, and other relevant areas to consider when selecting aOption 1: Leveraging Existing FrameworkOption 1 seeks to leverage most of the ex isting software and phys ica l arminimizing changes or creating new screens or in tegrating new too ls). Tthis option include: Use of existing database schema, Content Server, Webto

Conversion Server Use of Goog les Web Tool Kit for the pub lic-facing websit Modification of almost every screen within the FDMS agemeet the needs for FOIA requests New groups and access con trol lists (ACL5) on the Conte

The pros and cons for this approach are listed below:Table 1. Option I ProsLeverage Website Regulations.gov ut ilizes the Google Web Toolkitmodern model for the new FOIA public-facing wCPU Licensing Existing licensing agreement for Documentum wrequire the purchase of new licenses to supportHardware Reuses all existing hardwareExisting Software Reduces costs incu rred for additiona l FOIA toolFOIA Xpress

Table 2. Option I ConsCategory DescriptionWDK Framework The WDK framework currently utilized for the exeRulemaking agency system is outdated and sla

replacement within the next 3 years; therefore, fwould be requiredScreen Reuse Existing processes are very specific to Regulatiotherefore a blend is not truly reusing the screensall be altered with new layers of code to follow thprocess flowProcess Flow Blend Blend ing of the Regulations.gov process flow an

Category Description


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Office of Information Collection Electronic FOIA Response Analysis

Option 2: Leveraging Tools and Infrastructure with New ComponentsOption 2 leverages the existing infrastructure where possible, however, it infuses newtechnologies to increase cost savings and minimize redundancy. The highlights for thisoption include:

Use of existing database, Content Server, Webtop, PDF ConversionServer Use of Googles Web Tool Kit for the public-facing website Creation of new screens using Adobe Flex technology New groups and access control lists (ACLs) on the Content Server

The pros and cons for this approach are listed below:

CPU Licensing Existing licensing agreement for Documentum would notrequire the purchase of new licenses to support FOIAUpdated Framework Option 2 does not utilize the outdated WDK framework but

rather a new, proven and flexible technology in Adobe FlexHardware Reuses all existing hardwareCode Change The Program code (FOIA vs. Regulations) is separated andEfficiency therefore easier to upgrade and easier to apply changes to asyou would not be identifying within complex screen layers,which changes apply to which program. This includes logical

separation of backend objects and storage.Existing Software Reduces costs incurred for additional FOIA toolsets such asFOIA XpressFDMS Foundational The modernized FOIA approach to Data Objects and UI

Change frameworks could serve as the foundation going forward forthe necessary FDMS migration away from WDK

Table 4. Option 2 ConsCategory DescriptionProcesses Existing processes are very specific to Regulations.gov,

therefore a reuse of the screens would be too complex therefore this option does no t reuse screen code.

Both options will require Annual Report support and the framework for both will includethe ability to create FOIA specific reports. These reports will need to be created basedon the new elements added to the system. In a future phase, if the requirements forreporting equal the need for a Business Intelligence tool, the team could leverage opensource tools or leverage the EPA Enterprise-wide tools in Oracle Business Intelligenceand SAP Business Objects.

Leverage WebsiteTable 3. Option 2 Pros

Category DescriptionRegulations.gov utilizes the Google Web Toolkit and is a goodmodel for the new FOIA public-facinq website

Booz Allen Hamilton 4 5/6/2010


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Office of In formation Collection Electronic FOIA Response Analysis

3. Suitability AnalysisThis section will describe how the current FDMS architecture is laid out and could beleveraged to include the requirements as defined by the EPA FOIA team. This willinclude an architecture diagram with intersections identified for FOIA. It will also includean analysis of what level of effort it would take to meet each of the documentedrequirements.InfrastructureThis section describes the intersections between FOIA requirements and the existinginfrastructure supporting FDMS and Regulations.gov.Capability Availability to include FOIANetwork Ample capacity existscapacityServer capacity Ample capacity existsSecurity Identification, Firewall, Intrusion Detection, and Monitoring are in placeDatabase License has been purchased and capacity existsContent System and licensing is in placeManagementStack Java applications are in a clustered environment which strongly supports

the addition of the FOIA workloadIndexing Powerful Indexing software is in place (Endeca, FAST)Searching Powerful Searching software is in place (Endeca, FAST)Recovery and Storage Area Networks (SANs), systematic backups and a COOP site areBackup all in place for useDeveloper A license for the development of the Rich Internet Application tool for theToolkit Option 2 framework would need to be procured (low cost)LDAP Firewall, Intrusion Detection, SSL all can be reused eliminating the need tobegin the lengthy firewall process at EPAVPN The program owns the VPN that is in place and it can be uti lized for FOIAScanning Staff and servers are in place using both Kofax and Captiva and utilizingthe support of scanner to scanner infrastructure for submission or the useof human/manual scanning team

FunctionalityCapability REGS FDMS Leveragability of CommodityDocketitolder- X A 1 he hUlA requirement 1N012 requires the ability to createbased Process a folder in order to store the request, responsedocumentation and other communication details together.



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The docket-based process within FDMS supports thiscapability; however, this can be leveraged by utilizing thedesign of the process and creating a new FOIA setup(Option 2), or it can be leveraged as it exists within FDMS(Option 1). Therefore either approach supports thisconcept/requirement.

Public-facing X Regulations.gov has a modernized, public-facing interfaceUser Interface which can be leveraged for FOIA with minimal changes to

each page. Changes would include search instructions,navigational elements, metadata, search index, andrequest submission instructions. This site wasconstructed using Google Web Toolkit and would no trequire a change in technology to meet the FOIA intakerequirements.

Routing X X Routing frameworks exist bu t would be altered to meet theFOIA process flows.Permission Sets X X New groups and Access Control Lists will need to becreated for either optionBusiness x The business processing u ti li zed for FDMS would need toProcessing be simplif ied for FOIAs in an effort to maintain good

performance and reduce complexity and costs, whilemeeting FOIAs requirements.

Version Control x Version control was no t listed as a requirement, howeverthe functionality could be turned on if desired. This featurewould add to the storage requirements.Metadata X X There is some commonality across the existing metadata

fields captured such as ID, Title, Keywords and Abstract,however, more fields will need to be created in order tomeet the requirements.

Email X X Notifications exist at both the internal (Agencies) andNotifications external (Public) levels.Certification and X X The FOIA C&A will become a modification to the existingAccreditation FDMS C&A rather than supporting two separate efforts.(C&A)Help Desk X X Single help desk could support user calls with minimaltraining and a potential staff augmentation based on

analysis of cal l volumeServer/Network X X Leveraging components and staff for existing services toAdministration support the server and network administration

Replacing Existing FOIA ToolsThe current toolset provides the basic capabilities to manage and respond to FOIArequests. Utilizing the FDMS framework and infrastructure will add the followingcapabilities to the FOIA program:

Ability to expand Reading Room capabilities to provide links across Regions andOffices which reduces duplication, expands the ability to retrieve related



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responses easily and will not require the user to know where to look for theresponses (the current setup requires clicking through each separate readingroom) Ability to send a request to another Office or Region through a workflowmechanism in order to properly track dates for acceptance, assignment,completion, etc. Ability to create a user profile (if desired) to reduce the burden on the user,provide status on all open requests, and store past responses Ability to create a folder containing all associated documents including emailsand approvals for a request Ability to reduce the manual steps involved with the Annual Report by collectingelectronic metadata Ability to expand the FOIA response service offering to any Federal Agency Ability to send electronic data to Regional feeder systems supporting theresponses to FOIA requests



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4. Role DescriptionsThe following Roles are described in order to ensure that the needs of the system canbe met and are comprehensive. In addition, these roles are used in the To-Be ProcessMaps and are described here for clarification. One staff member could potentially holdtwo roles.

Table 5. Roles and ResponsibilitiesRole Description

Thi s new role will manage the communication point for allrequests. Although the Location Response Team will havethe ability to communicate with the user for informationgathering, all assignments will come from this role and allfinal request responses will be delivered through this role.

System Administrator The standard System Administrator role will be theSuperuser within the system.FOIA Administrator This user would have the ability to set up new users,delegate work, and reassign work.Location Response Team The LRT responds to the assigned items that came fromthe Switchboard Operator. In addition, this role determines

extensions, holds and performs other response-relatedfunctions.

Location Response Team This potential role could serve as the work assignmentLead contact for the location if a need is determined. They couldensure that responses are assigned and responded to in atimely fashion and gather metrics as well.

FOIA Requestor This role is no t currently captured through IdentityManagement but could be offered to users as an option toextend additional capabilities.

Scanner This capability would need to be determined but it is apotential integration point with the EPA Docket Center.Finance Center The finance center contact could have the capability toenter payment information in to the system.OGC Contact The OGC contact could enter appeal information in to thesystem.

Switchboard Operator



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U.S. Environmental Protection AgencyFOIA.gov Feasibility Analysis Report

Version 3.4February 9, 2011

Prepared by:PROJ ECTper ormanceCORPORATION1760 Old Meadow Road McLean, VA 22102

Phone: 703-748-7000 Fax: 703-748-7001

FOIA.gov Feasibility Analysis ReportVersion 3.3

January 28, 2011


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Table of ContentsEXECUTIVE SUMMARY 41.0 INTRODUCTION 5

1.1 Feasibility Analysis Purpose 51.2 Feasibility Analysis Step-by-Step Process 5

2.0 FOIA TRACKING AND PROCESSING IMPROVEMENT OBJECTIVES 62.1 Current FOIA Process 62.2 Goals and Priorities 7

3.0 DEFINITION OF ALTERNATIVES 83.1 Alternative #1: FQIA Status Quo 83.2 Alternative #2: FOIA.gov Module of eRulemaking 9

4.0 ESTIMATE COSTS FOR EACH ALTERNATIVE 114.1 Life Cycle Cost Analysis by Element 11

5.0 ESTIMATE QUANTITATIVE BENEFITS FOR EACH ALTERNATIVE 145.1 Quantitative Benefit 1: Reduction in Staff Time and Administrative Costs due to

Improved Records Management Capabilities 146.0 DOCUMENTALLASSUMPTIONS 167.0 ADJUST COSTS BASED ON RISK ASSESSMENT 178.0 NET PRESENT VALUE CALCULATIONS 209.0 EVALUATE ALTERNATIVES 21

9.1 NetPresent Value 219.2 Return on Investment 219.3 Payback Period 21

10.0 RECOMMENDATION 22

Table of TablesTable 1: Summary of Alternatives 4Table 2: Annual Costs for Alternative #1 FOIA Status Quo 13Table 3: Annual Costs for Alternative #2 FOIA.gov Module of eRulemaking 13Table 4: Reduction in Staff Time and Administrative Costs due to Improved RecordsManagement Capabilities 15Table 5: Risk Impact 17Table 6: Risk Percentages by Alternative 17Table 7: Total Risk Adjustment by Risk Category 19Table 8: Cumulative Costs and Benefits of Each Alternative 20Table 9: Summary of Alternatives 21


January 28, 2011


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Record of Changes/Version History. DateofChange/Version Number Description Author(s)Change

Version 1.0 11/23/2010 Initial Draft Project Performance CorporationVersion 2.0 12/10/2010 Revised Draft Project Performance CorporationVersion 3.0 12/14/2010 Final Version Project Performance CorporationVersion 3.1 01/14/2011 Revised Final Environmental Protection Agency

. Revised Final withVersion 3.2 01/21/2011 . . Environmental Protection Agencyadjusted_lifecycleVersion 3.3 01/27/2011 Revised Final with Project Performance CorporationVersion 3.4 02/09/2011 Final Edits Project Performance Corporation

iii


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F0IA.gov Feasibility Analysis ReportVersion 3.3

January 28, 2011


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1.0 INTRODUCTION1.1 Feasibility Analysis PurposeSection 300 of the Office of Management and Budgets (0MB) Circular Number A-il establishes thepolicy for planning, budgeting, acquisition, and management of federal capital assets. it also instructsmajor information technology (IT) investment business owners on how to justify their budgets anddefine requirements.OEls OIC is conducting a feasibility analysis to assess whether a proposed, centralized GOTS FOIAmodule is sound and cost-effective. Th e overall objective of this feasibility analysis is to evaluate thetechnical and cost feasibility of implementing a government-wide FOIA.gov module in eRulemaking.The analysis includes estimates of costs and benefits for each alternative, adjusting for risk and timing,in addition to discussing the advantages and disadvantages of each proposed alternative.

1.2 Feasibility Analysis Step-by-Step ProcessThis document details the viable alternatives for receiving, tracking, monitoring, and storing FOIArequests. Th e Feasibility Analysis process is divided into the following steps:

1. Determine and define objectives and requirements.2. Identify alternatives.3. Conduct interviews with stakeholders and review background documentation.4. Estimate costs and benefits for each alternative.5. Adjust costs based on risk assessment.6. Calculate ROl for each alternative.7. Evaluate alternatives and provide recommendation.

This document is accompanied by a cost model detailing the cost-benefit analysis. Sections 2 through10 of this document walk through this step-by-step process and conclude with a recommendation andrationale.

Page 5 of 22


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2.2 Goals and PrioritiesFederal agencies can benefit by having a comprehensive, centralized FOIA solution to managetracking, monitoring, and storing FOIA requests. High-level requirements include the following:

Streamline and automate business processes. Deploy user-friendly technology. Increase transparency and accessibility of information to the public. Increase user satisfaction. Enhance the quality of reports. Meet security and conformance standards.

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January 28, 2011

3.0 DEFINITION OF ALTERNATIVES


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Based on current and future-state business process requirements, data, and stakeholder input, twoalternatives have been identified for this Feasibility Analysis:

1. FOIA Status Quo2. FOIA.gov Module built on the eRulemaking platform

Details of each alternative are listed below. All alternatives strive to align not only with the OlC teamsrequirements, but also the overall Agency strategic goals and targets.3.1 Alternative #1: FOIA Status QuoAlternative #1, the FOIA Status Quo, represents using agency FOIA processes as administered today.According to the March 2010 United States DOJ Chief FOIA Officer Reports, thirteen agencies use aCOTS product, FOlAXpress, to track and manage FOIA requests. EPAs BY 2012 CPIC Lite ProposalForm states that FOlAXpress provides services to FOIA users and administrators through Web-basedintranet access. FOlAXpress has the capability to track correspondence and generate a variety ofactivity reports. The remaining agencies typically use one of several COTS tools, internally developedapplications, Microsoft Office Suite, or paper-based methods to track and process FOIA requests.According to the United States DOJs Office of Information Policys FOIA Post, Summary of AnnualFOIA Reports for Fiscal Year 2009, the total federal FOIA spending for 2009, including the actualprocessing, information gathering, and response development to the FOIA request, was approximately$382 million. Agencies without support of an application, like FOlAXpress, have limited reportingcapabilities and must often rely completely on manual processes to create reports. While the currentFOIA processes have some limitations, they continue to meet the most basic FOIA requirements.

PROS CONS Meets federal FOIA tracking and Lacks central repository for housingreporting requirements responsive records

Established workflows at all 94 FOIA- High cost to maintain 94 separatereceiving agencies systems

Will not require additional training Reliance on manual efforts Autonomy in managing agencys Public must go to 94 agencies to fileprocessing system requests

Agencies own their data Cannot electronically share requestsbetween agencies

chief FOIA Officer Reports. United States Department of Justice. March 2010. 6 FOlAXpress BY 2012 CPIC Lite Proposal Form. oEt/OIC/CSD. August 26, 2010.Summary of Annual FOIA Reports for Fiscal Year 2009. United States Department of Justice Office of Information Policy

FOIA Post. June 4, 2010. < http://www.justice.gov/oip/foiapost/2olofoiapostl8.htm>.Page 8 of 22


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FQIA.gov Feasibility Analysis ReportVersion 3.3

January 28, 2011

minimal customization to meet agency needs. As customization increases, so does the cost and risk of


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the solution implementation. Screens will be customized to the FOIA processes and the frameworkwill be updated using Adobe Flex.However, if leveraging a GOTS solution immensely changes the organizations workflow processes,there is a much greater risk of low user acceptance without proper training and helpdesk support foreach of the 94 agencies receiving FOIA requests. User acceptance of a GOTS solution, such as an FOIAmodule of eRulemaking, depends largely on the solution meeting the users business processes.

PROS Meets federal FOIA tracking and

reporting requirements Central, standardized repository for

FOIA information that is easilyaccessible by both federal employeesand the public

Cost savings if customization is limited eRulemaking has already funded a

major portion of development andidentified lessons learned

Scalable, flexible, and will provide arobust platform to meet newrequirements as they evolve

Allows agencies to consult or referrequests electronically to otheragencies

CONS Adaptation of an FOIA.gov module

could change the current workflowand work habits of many FOIAemployees

Requires training Agencies lose autonomy May require technical infrastructure

changes

Public can submit requests to multipleagencies at once

Supports the guidelines outlined inPresident Obamas Freedom ofInformation Act memorandum

Obama, Barack. Freedom of Information Act Memorandum for the Heads of Executive Departments and Agencies.Accessed December 14, 2010. < http://www.whitehouse.gov/the press office/FreedomoflnformationAct/>

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Table 2: Annual Costs for Alternative #1 FOIA Status Quo

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Alternative 1: FOIA Status Quo*Cost Element FY2011 FY2012 FY2013 FY2014 FY2015 Total

Planning 0.000 0.000 0.000 0.000 0.000 0.000Development 4.327 4.457 4.591 4.729 4.870 22.974

FOlAXpress 1.391 1.433 1.476 1.520 1.566Additional Support 2.936 3.024 3.115 3.209 3.305

O&M 10.111 10.414 10.726 11.048 11.379 53.678FOlAXpress 4.238 4.365 4.496 4.631 4.770

Additional Support 5.873 6.049 6.230 6.417 6.610Government FTE5 3.408 3.510 3.615 3.723 3.835 18.091

Program Support 6,815 7.019 7.230 7.447 7.670Total 17.845 18.381 18.932 19.500 20.085 94.743

Table 3: Annual Costs for Alternative #2 FOIA.gov Module of eRulemaking

Alternative #2: FOIA.govModule of eRulemaking*II[lijth1 I I I I ji. ItT1I

Planning 0.288 0.297 0.000 0.000 0.000 0.585

Development 1.297 1.335 0.764 0.393 0.203 3.992Systems and Application 1.152 1.187 0.611 0.315 0.162Development

Software Acquisition 0.001 0.000 0.000 0.000 0.000Testing 0.144 0.148 0.153 0.079 0.041

O&M 0.000 0.948 0.971 1.000 0.706 3.624Hosting 0.000 0.171 0.176 0.182 0.187

Administration Costs 0.000 0.148 0,153 0.157 0.162Storage 0.000 0.035 0.030 0.031 0.032

User Support 0.000 0.297 0.306 0.315 0.162Training 0.000 0.297 0.306 0.315 0.162

Government FTE Costs 0.435 0.448 0.231 0.238 0.245 1.596Program Support 0.435 0.448 0.23 1 0.238 0.245

Total 2.020 . 3.028 1.965 1.631 1.153 9.797

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Table 4: Reduction in Staff Time and Administrative Costs due to Improved RecordsManagement Capabilities

Alternative #1: FOIA Status Quo Alternative #2: FOIA.gov Module ofeRulemakingYear % Reduction Value Added Year % Reduction Value Added

FY2OII 0% 0.000 FY2OII 0% $0000FY2012 0% 0.000 FY2012 25% $2893FY2013 0% 0.000 FY2013 50 % $5786FY2014 0% 0.000 FY2014 75% $8679FY2015 0% 0.000 FY2015 100% $11572Total sooooo Total $28.9289

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January 28, 2011

6.0 DOCUMENT ALL ASSUMPTIONS


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The following substantive assumptions were used when estimating the costs for each alternative: Th e start year is FY 2011. Th e discount rate is seven percent. A standard three percent inflation rate will be applied to all labor and hardware costs in FY

2012 and beyond. Contracted system analysts, programmers, and senior system engineers are estimated at

approximately $150/hour. EPAs loaded annual salary in FY 2011 is approximately $145,000. Each FOIA report is approximately 10 pages in length and stored as a color PDF copy. On average, it takes 2.5 hours to complete an FOIA request. Current FOIA processes are in full effect with only minor enhancements, as needed. No

additional planning or design is required at this time. The proposed FOIA.gov solution will meet all OIC business and technical requirements in

addition to meeting the current process requirements. The process of developing, vetting and issuing a solicitation, performing vendor selection,

and awarding a contract will take two months for this alternative. Project management for an FOIA.gov module of eRulemaking will be supported by internal

EPA FTEs. An FOIA.gov module of eRulemaking is live by FY 2012, but i t wil l still need enhancementsthroughout the project life cycle. An FOIA.gov module of eRulemaking requires minimal customization to meet FOIA

functionality needs. Adobe Flex would be used to create screens for an FOIA.gov module of eRulemaking. Only open and backlogged FOIA requests/cases will need to be migrated from their

respective agencies or departments to the FOIA.gov module of eRulemaking. Additionalhistorical data migration and conversion will be decided based on the discretion andfunding of the applicable agencies and departments.

An FOIA.gov module of eRulemaking would be hosted at the NCC. All hardware costs(servers) are inherent in the WCF charge.

Contractors will perform training and helpdesk support for the FOIA.gov solution. System security work for an FOIA.gov module of eRulemaking will be completed by the

eRulemaking Project Management Office. The cost estimate does not include the DOJ FOIA dashboard at this time; however, this

document does include internal and external facing automated reports. Data entry (to preserve the integrity of historical data) is not included in the cost estimate

at this time and is assumed to be completed by the applicable agencies.Page 16 of 22


January 28 , 20117.0 ADJUST COSTS BASED ON RISK ASSESSMENTA risk-adjusted return on investment should be compared for each alternative in order to determine


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which one is the best solution. This puts the alternatives on equal footing from a cost perspective, as itwill account for the increased complexity of a particular alternative that may not be representedaccurately without the risk adjustment. For the purposes of this analysis, risk is defined at a high leveland is determined by those factors that would have the most significant impact on the alternativesfrom a cost perspective, should they be realized.Risks were quantified based on the probability of occurrence multiplied by the cost if the risk occurs.In order to make a conservative estimate, if the risk were to occur, we assumed a doubling of the costs(having to entirely rework). This technique was chosen based on the type of projects that are beingcompared. This does not underestimate or overestimate quantified risks as the probability of totalrework is lower than the probability of partial rework. For example, a five percent probability ofoccurrence of total rework of a $100,000 cost ($5,000) is no different than a 20 percent probability ofhaving to rework only a portion of the cost (20 percent of $25,000 = $5,000 cost if the risk occurs).Table 5 below highlights the percentages associated with the probability of each of the risks identifiedin this analysis:

Table 5: Risk ImpactRisk Probability Value

No t Likely 10%Low Probability 25%Likely 50%Highly Likely 75%Near Certainty 90%Not Applicable 0%

In addition, Table 6 below highlights the total risk adjustment for each alternative with a summary byrisk area and probability of occurrence. Definitions of each risk area can be found on the followingpage.

Table 6: Risk Percentages by Alternative. Rkk Probbilitv of Occurrence

Business Impact 25% 10%Resource Availability 10% 25%Management andOversight 10% 10%Technical Issues 25% 10%Security 10% 10%

Alternative 2:Alternative 1:FOIA.gov Moduleife Cycle Risk Area FOIA Status Quo eRulemaking

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January 28, 2011

SecurityIn todays world, IT Security and security of data is critical to any government system. FOIA responsesare not confidential and open to the public. The report authors assumed that the FOIA.gov solution


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meets agency security needs, as security requirements would be handled by the eRulemaking ProjectManagement Office.Table 7 below highlights the costs (in millions) estimated if these risks were to occur.

Table 7: Total Risk Adjustment by Risk CategoryTotal Risk Adjustment by Risk CateRorv (Cost if Risk Occurs)

Business Impact 23.69 0.98Resource Availability 1.81 0.40Management and Oversight 7.67 0.82Technical Issues 13.42 0.36Security 5.37 0.36Total 51.9473 2.9235

Alternative #2 :Alternative #1: FOIALife Cycle Risk Area FOIA.gov Module ofStatus Quo eRulemaking

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8.0 NET PRESENT VALUE CALCULATIONS


January 28, 2011

After costs and benefits for each alternative have been identified and adjusted for risks, they need todollars. This analysis allows for costs, benefits, and risks to be adjusted


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be compared in present valuefor the period of time when they occur. A cost or benefit in year one has a different present value thanan equal cost or benefit in an out year. For purposes of this analysis, seven percent discount rateswere applied to all out year costs (risk adjusted) and quantifiable benefits, per the 0MB Circular A-94requirement. Table 8 below summarizes the data for each alternative.

Table 8: Cumulative Costs and Benefits of Each Alternative

FY2O11 17.845 27.630 0.000 1.000 27.630 0.000 -27,630FY2012 18.381 28.459 0.000 0.935 26.597 0.000 -26.597FY2013 18.932 29.312 0,000 0.873 25.603 0.000 -25.603FY2014 19.500 30.192 0.000 0.816 24.645 0.000 -24.645FYZO15 20.085 31.098 0.000 0.763 23.724 0.000 -23.724Total 94.743 146.690 0.000 128.199 0.000 -128.199

F U. 2.(FY2012 rFY2013 1.965 2.587 5.786 0.873 2.260 5.054 2.794FY2014 1.631 2.193 8.679 0.816 1.790 7.084 5.295FY2015 1.153 1.561 11.572 0.763 1.191 8.828 7.637Total 9.797 12.720 28.929 11.365 23.669 12.304

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January 28, 2011

9.0 EVALUATE ALTERNATIVESAfter costs and benefits for each alternative have been identified and adjusted for risk, they need to


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be compared in present value dollars. This analysis allows for costs, benefits, and risks to be adjustedfor the period of time when they occur based on a life cycle of five years. A cost or benefit in year onehas a different present value than an equal cost or benefit in an out year. For the purposes of thisanalysis, a seven percent discount rate was applied to all out year costs (risk-adjusted) andquantifiable benefits.Three quantitative methods (i.e., computing NPV, ROl, and payback period) of evaluation were used inthis analysis to help validate the FOIA.gov teams path forward with the potential investment. Eachalternative was thoroughly assessed and analyzed to ensure that all feasible options were examinedprior to determining future FOIA receipt, tracking, monitoring, and storage strategies. In addition tothe quantitative analysis, detailed qualitative analysis can be found in Section 3 of this document.Th e following table presents the findings of the quantitative analysis. Alternative #2 includes the costof concurrently running an agencys current system for the full fiscal year during which FOIA.gov isscheduled to be deployed. Explanations and supporting details of each evaluator are presented aswell.

Table 9: Summary of Alternatives

9.1 Net Present ValueNPV measures the net value of an investment in present terms. Th e NPV analysis identifiedAlternative #2 , an FOIA.gov module of eRulemaking, was the best alternative with a NPV of$12,304,257. Th e NPV takes into account all risk-adjusted costs and benefits and adjusts for time.9.2 Return on InvestmentROI is the ratio of investment gains relative to investment costs and is used to measure the efficiencyof an investment. An ROl greater than 1.0 indicates an investment with positive returns. The ROlanalysis highlighted Alternative #2 as the most valuable alternative with an ROl of 2.08.9.3 Payback PeriodPayback period measures the time required for investment gains to exceed investment costs. Thepayback period for each alternative is evaluated as a total risk-adjusted cost for the alternative dividedby the average annual benefit provided by the alternative. An investment will result in payback whenthe life cycle ROl exceeds 1.0.

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January 28, 2011

10.0 RECOMMENDATIONThe qualitative and quantitative analysis in this report shows that it is in the best interest of the 94


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FOIA-receiving agencies to implement an FOIA.gov module in eRulernaking to meet FOIA receipt,tracking, monitoring, and storage requirements. The FOIA.gov module has the highest NPV, highestROl, and the shortest payback period in addition to the most qualitative advantages. Based onquantitative and qualitative analysis, an FOIA.gov module of eRulemaking is technically and financiallyfeasible and is recommended for future FOIA receipt, tracking, monitoring, and storage functionality.

Page 22 of 22

(2 Follow up to our recent discussions on the costs savings & benefits of a\ govt-wide FOIA moduleJohn Moses to: Melanie.A.Pustay 06/24/2011 05:45 PM


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Melanie,As promised, attached is compilation cost savings that we discussed when we last met and came up withon the phone (e.g., automatically accepting FOIA requests via a common request form). Ive alsoincluded a few more estimates of cost savings from business process efficiencies which would accruefrom deploying a govt-wide FOIA module (publicly accessible via FOIA.gov) . As you can see, Ill nexttackle estimating the number of duplicative and redundant FOIA web sites and online means to acceptFOIA requests.I think youll be pretty happy seeing the additional cost savings and agency efficiencies that we were ableto identify from just a few meetings.

FOIA module cost savings - in addition to Cost Benefit Study June 2011 .xlsxIll be on leave next week but can be reached via email (blackberry) or cell phone if youd like to discussbefore I return on July 5th.Thanks.John Moses, DirectorCollection Strategies DivisionOffice of Information CollectionOffice of Environmental Informationphone: (202) 566-1352; FAX: 202-566-1611; cell: 202-302-9530.Mailing address:U.S. Environmental Protection Agency (mailcode 2822T)1200 Pennsylvania Ave., NWWashington, DC 20460

,AJLrq-/ /1 (1A) bU1!- sIOd,lQ C1

Summary of Total Costs Avoided / Saved from a govt-wide FOIA module

1) Cost AvoidanceA) Build and operate govt-wide FOIA module vs operating individual FOIA tracking systems

(derived from Cost & FeasibilityAnalysis of Govt-wide FOIA portal, February 9, 2011)


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Five year savings $128,000,000

2) Cost SavingsA) Consolidation of websites

1) Annual savings accrued (FdA module - duplicative web sites) TBD2) Annual savings accrued (FOIA module - redundant FOIA web form) TBD

B) Business Process Efficiencies1) Annual savings accrued (FOIA module - automatic request form) $14,423,077

Five year savings $72,115,385

2) Annual savings accrued (FOIA module - self-serve FOIA inquiries) $351,563Five year savings $1,757,815

C) Records Storage Costs (TBD) TBD

Total Cost Savings(AnnualTotal Cost Savings (Five Year)Grand Total Cost Avoidance & Savings (Annual) NAGrand Total Cost Avoidance & Savings (Five Year) $201,873,200

J0 /-4, j t I t-

Consolidation ofWebsites1) Savings accrued via shutting down duplicative and redundant web sites

leave 1 web site per Department/independent Agency


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Number of duplicative web sites (govt wide) 72 **analysis isincompleteAverage cost to maintain each web site (dollars) $10,000 (see last tabfor data)Total Costs Saved 720,000

2) Savings accrued via shutting down redundant online web forms to accept FOIA requestsno online web forms remain since FOIA module accepts FOIA requests

Number of redundant online FOIA web forms (govt wide ) TBD

Average cost to maintain each web form and email box ( $10,000Total Costs Saved #VALUEl

tcQ,

Business Process Efficiencies1) Savings accrued via common FOIA module request form (9nbox)

online comment form completed by pub lic; automatically deposited into Agency


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Number of FOIA submissions per year (govt wide) 600,000

Average amount of time to manually upload (minutes) 20eg open and read document in an email inbox , scan or upload file into anelectronic tracking/repository tool, type in metadata into electronic tracking/repository tool

Total minutes to upload 12,000,000

Total Hou rs (divide Total Minutes by 60 ) 200,000Total FTE (divide Total Hours by 2080) 96.1538462

Total Cost Sav ing s (multiply Total FTE by $150,000) $14,423,077

2) Savings accrued via online ability for public to inquiry about status of FOIA requests

# of phone inquiries per week (EPA) 45# of phone inquires per week (govt-wide; EPA *50) 2,250Annu al 4* of phone inquiries (multiply by 26 ) 58,500

Average amount of time to respond (minutes) 5Total minutes to respond 292,500

Total Hours (divide Total Minutes by 60 ) 4,875

Total FTE (divide Total Hours by 2080) 2.34375

To tal Cost Saving s (multiply To tal FTE by $150,000) $351,563

Parent AgencyAdministrative Conference ofthe Un ited States

Rulemaking7 Age ncy -

supportedRe gs.go vYes

PartnerAgency -

by Supportedby FD MS

.#webTota I#of1 tS .C afl

FOIA.. FOIAbbeAgency sites reducedYes

Advisory Co unc il onHi storical Preservation Yes


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Ad visory Commission onIntergovernmental RelationsAfrican DevelopmentFoundation

Agency for InternationalDevelopment

Agriculture DepartmentAgricultural Marketing ServiceAn ima l and Plant HealthInspection Service

Commodity Credit CorporationEconomic Research ServiceFarm Service AgencyFederal Crop InsuranceCorporationFood Safety and InspectionServiceFoo d and Nutrition Se rviceForeign Agricultural ServiceForest Service

Grain Inspection, Packers andStockyards Administration

National Agricultural Lib raryNational Agricultural StatisticsServiceNatural ResourcesConservation ServiceRu ral Business-CooperativeServiceRural Housing ServiceRur al Utilities Service

Yes

Yes Yes

Yes Yes YesYes Yes Yes

Yes YesYes YesYes YesYes YesYes Yes


Yes Yes

Yes Yes


American Battle MonumentsCommission Yes Ye s

Broadcasting Board of

Parent Agency Sub-AgencyArchitectural andTransportation Barriers

Rulemaking.Agency

2orted byPartnerAgency -Supportedby FDMS

Yes Yes

Yes Yes

Total,# of sites canFOIA FO ikeb . beAgency sites reduced


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Governors

Central Intelligence Ag ency *(see ODNI) Yes

Chem ical Safety and HazardInvestigation Board

Census BureauEconomic Analy sis BureauEconomic DevelopmentAdministrationEconomics and StatisticsAdministrationForeign-Trade Zones Board

Industry and Security BureauInternational TradeAdministrationMinority BusinessDevelopment AgencyNational Institute of Standardsand Technology

National Oceanic andAtmospheric AdministrationNational Telecommunicationsand InformationAdministration

Patent and Trademark Office

U.S. Commission on CivilRightsCommodity Futures TradingCommissionConstruction IndustryCollective Ba rgainingConsumer Product SafetyCommission

8 7Commerce DepartmentYes Yes

Yes Yes YesYes YesYes YesYes Yes

Yes YesYes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes

Yes Yes Yes

Rulema king PartnerAgency - Agency - of sites cansupported by Supported FOIA FOIA web be.Regsgov by FDMS Agency sites rducd

Corporation for National andCommunity Service Yes Yes

Cost Accounting Standards

Parent Age Icy ;.;.


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Bo ard YesCourt Services and OffenderSupervisionAgencyforthe Yes Yes

Defense Department Yes Yes Yes 25 24Air Forc e Department Yes YesEngineers Corps Yes YesNavy Department Yes Yes

Defense Nuclear FacilitiesSafety Board Yes Yes

Delaware Rive r BasinCommission Yes

Education Department Yes Yes Yes

Energy Department Yes Yes YesEn ergy Effic iency andRenewable Energ y Office Yes Yes

Environmental ProtectionAgency Yes Yes Yes 17 16

Equal EmploymentOpportunity Commission Yes Yes Yes

Executive Office of thePresident Yes Yes

Environmental Quality, Council Yes Yes YesManagement and Budget Yes Yes YesFederal Procurement Poli cyOffice (under 0MB) Yes YesOffice of Science andTechnologyUS Trade Representative Yes Yes

Farm Credit AdministrationFarm Credit SystemInsurance Corporation

: 4web.TotIof sites canFOIA FQIAWeb.b:Agency sitesarentAgrcy:

Rulemaking PartnerAgency- Agency

: supported by Supported* Sub-Agency Regs.gov by FDMS

Yes

Yes

Yes

Yes


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Federal CommunicationsCommunicationsFederal Deposit InsuranceCorporation

Federal Election Commission

Federal Energy RegulatoryCommissionFederal Financial InstitutionsExamination CouncilFederal Housing FinanceBoardFederal MaritimeCommissionFederal Mediation andConciliation ServiceFederal Reserve System

Federal Retirement ThriftInvestment Board

Federal Trade CommissionGovernment AccountabilityOfficeGeneral ServicesAdministration

Yes

Yes

Yes

Yes Yes

Yes Yes

Yes Yes

Yes

YesYes

Yes Yes

Yes Yes

Yes

Yes Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

Yes

YesYes

Yes

Yes

Yes

Government Ethics Office

Government Printing Office Yes Yes

#webTotal of, sitescan

FQ1A : FOIAweb;.Agency sites ..11aI.Paret : Sub-AgencyHarry S. Truman ScholarshipFoundation

Health and Human Services

RulemakingAgencysupported by

: Regs.govYes

PartnerAgency -Supportedby FDMS

Yes Yes Yes


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Homeland Security,Department of

Centers for Medicare &Medicaid ServicesChildren and FamiliesAdministration

Food and Drug AdministrationHealth Resources and ServicesAdministrationIndian Health ServiceInspector General Office,Health and Human ServicesDepartmentPublic Health ServiceRefugee Resettlement OfficeSubstance Abuse and MentalHealth Services Administration

Coast GuardFederal EmergencyManagement AgencyFederal Law EnforcementTraining CenterImmigration and NaturalizationServicesTransportation SecurityAdministration

Community Planning andDevelopment, Office ofAssistant SecretaryFederal Housing EnterpriseOversight Office

Inter-American Foundation Yes

DepartmentYes YesYes YesYes Yes

Yes YesYes Yes

Yes YesYes Yes

Yes Yes

Yes Yes

Yes YesYes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes Yes

Yes

Yes

9 8

Housing and UrbanDevelopment Department

Interior Department Yes Yes Yes 7 6

Rulemaking Partner #web-- Agency- Total#of sites cansupported by Supported FOIA FOlAweb be

,ancy Regs gov by FDMS Agency sttes reducedIndian Affairs Bureau Yes YesIndian Arts and Crafts Board Yes YesIndian Trust Transition Office Yes Yes

Parent Agency


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Land Management Bureau Yes YesMinerals Management Service Yes YesMines Bureau Yes YesNational Park Service Yes YesSurface Mining Reclamationand Enforcement Office Yes Yes

Joint Board for Enrollment ofActuaries YesJustice Department Yes Yes Yes 8 7

Alcohol, Tobacco, Firearms andExplosives, Bureau of Yes YesDrug EnforcementAdministration Yes Yes

Federal Bureau of Investigation Yes YesForeign Claims SettlementCommission Yes YesParole Commission Yes YesPrisons Bureau Yes Yes

Labor Department Yes Yes YesDisability Employment PolicyOffice Yes YesEmployment StandardsAdministration Yes YesEmployment and TrainingAdministration Yes YesLabor Statistics Bureau Yes YesLabor-Management StandardsOffice Yes YesMine Safety and HealthAdministration Yes YesOccupational Safety and HealthAdministration Yes YesPension and Welfare BenefitsAdministration Yes YesWage and Hour Division Yes Yes

Library of Congress Yes

#wbTotal #f sites can

FIA FOIA web beAgency sites , reduced4

Rulemaking PartnerAgency - Agency -[ supported by SupportedParent I SuAgncy Regs gov by FDMS

Copyright Office, Library ofCongress Yes

Local Television LoanGuarantee Board Yes


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Merit Systems ProtectionBoardMinority BusinessDevelopment AgencyMorris K. Udall Scholarshipand Excellence in National

National Aeronautics andSpace Administration

National Archives andRecords Administration

National Credit UnionAdministrationNational Crime Preventionand Privacy Compact CouncilNational Foundation on theArts and the HumanitiesNational Institute forLiteracyNational Labor RelationsBoardNational Railroad PassengerCorp (Amtrak)

National Science Foundation

Nuclear RegulatoryCommission

Office of the DirectorNational Intelligence

Yes Yes

Yes

Yes

Yes Yes Yes

Yes Yes Yes

Yes Yes

Yes

Yes

Yes

Yes Yes Yes

Yes Yes Yes

Yes Yes Yes

Yes Yes

Peace Corps

To ta l # of sitesnFOIA FO lA tb eAgency sites reduced

Ru lemaking Partner. ; 1gency- Agency-supported by SupportedParent Agency Sub-Agency Regs gov by FDMSOverseas Private InvestmentCorporation Yes

Yes

Yes

Yes


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Pension Benefit GuarantyCorporationPersonnel ManagementOffic ePostal Ra te CommissionPostal Se rvice

Presidio Trust

Railroad Retirement BoardSecurities and ExchangeCommission

Selective Service System

Sma ll BusinessAdministrationSmithsonian Institution

Social SecurityAdministration

Special Counsel OfficeState Department

Tennessee Valley Authority

Federal AviationAdministrationFederal Highw ayAdministrationFederal Motor Carrier SafetyAdministration

Yes Yes

Yes Yes

Yes

YesYes

Yes

YesYes

Yes Yes

Yes

Yes Yes

Yes

Yes Yes

Yes

Yes Yes

Yes Yes

Yes Yes

Yes

Yes

YesYes

Yes

YesYes

Yes

Yes

Yes

Yes

YesTransportation Department

Yes Yes