Supporting Statement for a
Paperwork Reduction Act Submission to OMB The Federal Trade Commission (FTC) proposes to conduct surveys on consumers' use of and familiarity with the rating or labeling systems of the following entertainment industries: (1) motion picture; (2) recording; and (3) video and personal computer games. Together with information from the industry survey approved by OMB on December 21, 1999 under OMB Control No. 3084-0118, the consumer surveys will be used in an FTC report to the President regarding the advertising and marketing of violent entertainment materials to children. A. JUSTIFICATION
On June 1, 1999, the President requested that the FTC and
the Department of Justice conduct a study to determine whether and how members of the
entertainment industry are marketing violent material to children. The White House asked
that the study examine: To prepare this study, the FTC will request information from parents and children about their familiarity with, use of, and evaluation of the voluntary rating or labeling systems used by members of each industry. While FTC staff is gathering general information available in this area, consumer surveys will provide detailed and comprehensive data for the three industries involved. To the FTC's knowledge, such data is not currently available from any other source.
Though use of electronic media to conduct the surveys is theoretically possible, it would be impractical. Many households surveyed may lack a computer or certain individuals surveyed may lack ready facility for its use. In any event, the proposed telephone surveys will be very brief; additional time saved responding through electronic media would be minimal, if any.
There is no information available elsewhere that can be used to explore and compare consumers' familiarity with, use of, and evaluation of these industries' labeling or rating systems. Efforts to identify duplicate sources of information included a review of studies, data, hearing transcripts, news articles, and information found through contacts with industry trade associations, consumer groups, governmental agencies, and academic researchers.
Not applicable. The questions are being asked only of individual consumers.
If this information is not collected, the FTC will lack information to address important issues in the report to the President. The survey scope and burden has been reduced as much as possible without sacrificing the statistical value of the information to be collected.
The collection of information in the proposed survey is consistent with all applicable guidelines contained in 5 C.F.R. § 1320.5(d)(2).
As required by 5 C.F.R. § 1320.8(d), the FTC published a notice seeking public comment on the proposed collections of information. See 64 Fed. Reg. 46,392 (August 25, 1999). A copy of the FTC's publication is attached as Appendix B. The FTC received one comment regarding its proposed consumer research from the Interactive Digital Software Association (IDSA). The IDSA recommended that the Commission put out for public comment any survey instrument used to assess consumer attitudes toward and awareness of the IDSA's Entertainment Software Rating Board program, and that any such research only survey those who actually buy or play video games. Consistent with the requirements of the Paperwork Reduction Act, the survey instruments used to study consumer attitudes toward and awareness of the various IDSA rating or labeling systems will be made available to interested parties upon request to Commission staff. Moreover, respondents for the children survey will be those children whose parents say their children play video and/or personal computer games. The same approach will be taken for surveying children about their experiences regarding motion pictures and music recordings.
Not applicable.
Responses to the consumer surveys will not include any identifying information. The Commission will not receive any information about the identity of individual respondents.
The FTC will contract with a survey firm to: (1) identify and survey 750 parents with children aged 11 to 16; and (2) survey 400 children aged 11 to 16. For the parent telephone survey, the contractor will first identify respondents using screening questions. Allowing for non-response, the screener questions will be asked of approximately 5,000 respondents, as screening that number will provide a large enough random sample for this survey. After a parent completes the telephone survey, the contractor will ask the parent whether a child in the household aged 11 to 16 may participate in the survey. The FTC staff estimates that the screening for the survey will consume no more than one minute of each respondent's time. In addition, the FTC will pretest the parent survey on approximately 50 respondents to ensure that all questions are easily understood. This pretest will take approximately 15 minutes per person. Answering the parent survey will take approximately 15 minutes per respondent. Answering the children survey also will impose an individual burden of approximately 15 minutes. Thus, total hours burden attributable to the consumer research will approximate 383 hours, determined as follows:
The cost per respondent should be negligible. Participation is voluntary, and will not require any labor expenditures by respondents. There are no capital, start-up, operation, maintenance, or other similar costs to the respondents.
The total cost to the Federal Government for the information collection will be approximately $131,500. To obtain a contractor to design the information request, identify the consumers, conduct the surveys, and analyze the data will cost $125,000. In addition, the Commission staff time necessary to identify a contractor and to assist the contractor in completing its duties is estimated to require approximately 150 attorney hours and cost approximately $6,500. The cost of Commission staff time is necessarily an estimate because several factors in this calculation may vary, including the number of staff involved and the actual amount of time required. Clerical and other support services and costs of conducting the study are included in this estimate.
Not applicable. This is a new information collection.
The results of the surveys will be used to prepare a public report to the President. The collection of the information will begin after the completion of the OMB review process. The projected duration of the information collection is approximately ten weeks. The estimated date for the completion of the report is mid-to-late 2000.
The FTC will display the expiration date alongside the assigned OMB control number on the front page of its written document request.
Not applicable. B. COLLECTION OF INFORMATION EMPLOYING CASE STUDY METHODOLOGY
The potential respondent universe is detailed and explained under item #12 of Part A. above (discussing collection of information burden). In consultation with the contractor that will conduct the aforementioned surveys, staff has determined that a screening sample of 5,000 respondents will be needed to ensure a parent survey of 750 respondents.
As discussed more fully in Part A above, the FTC will contract with a survey firm to survey 750 parents with children aged 11 to 16, along with 400 children that age (children of the adult respondents, to the extent possible). The contractor will conduct a telephone survey of a random sample of adult respondents drawn from all 50 states and the District of Columbia. Random-digit dialing, including an initial call plus a minimum of three callbacks, shall be employed. The FTC's questionnaires will relate to parents' and children's attitudes regarding and awareness of self-regulatory rating systems applicable to music, movies, and video and personal computer games. The questionnaires will consist of a mixture of open-ended and closed-ended questions. The contractor will screen the potential respondents to restrict the adult respondents to parents of one or more children age 11-16 years who listen to music, watch movies, and/or play video or personal computer games.
Staff anticipates that the incidence rate of persons satisfying the screening criteria will be high. Moreover, in drafting the survey questionnaires staff has taken the length of the survey instrument into account so that fewer respondents drop out before completing the questionnaire. The contractor also plans to call children during hours when the children are more likely to be reached, minimizing unsuccessful attempts to reach respondents. Staff conservatively estimates that the sample sizes of parents and children surveyed will produce statistically reliable data, subject to sampling error of approximately +/- 3.5% and +/- 5.0%, respectively, based on a confidence level of 95%.
Staff will pretest the parent survey by sampling 50 respondents to ensure that all questions are easily understood. This pretest is also discussed in Part A above, and is part of the collection of information for which staff seeks OMB approval.
The study design has been reviewed internally by Mary Engle, Assistant Director for Enforcement, Bureau of Consumer Protection (202/326-3161), and input on statistical issues has been provided by Michael Mazis, a consultant with the Bureau's Division of Advertising Practices. The contractor (Roper Starch Worldwide, 610-921-3333) is experienced in conducting statistically rigorous telephone surveys. 1. See the attached Letter from the President to the Attorney General and Chair of the Federal Trade Commission, dated June 1, 1999, and the White House Press Release President Clinton and Vice President Gore: Addressing the Marketing of Violence to Children, dated June 1, 1999. (Appendix A) |
||||||||||||||||||||||||