sba 987 supporting statement

Supporting Statement for Paperwork Reduction Act Submission
OMB Control Number 3245-0136
SBA Form 987, Disaster Survey Worksheet
A.

Justification

The purpose of this submission is to request OMB reauthorization of the SBA Form 987,
“Disaster Survey Worksheet.”
1.

Circumstances that make the collection of information necessary. The Small
Business Administration is authorized to make loans to victims of declared
disasters for the purpose of restoring their damaged property to, as near as
possible, pre-disaster conditions. This authority is found in 15 USC 636 as
amended, implemented by 13 CFR Part 123 (copies attached). SBA’s Office of
Disaster Assistance (ODA) has not changed any information gathering items on
this form. ODA has revised some of the terminology to reflect field
transformation changes. Area Offices now collecting survey information are
referred to as Field Operation Centers (FOC).

2.

How, by whom, and for what purpose information will be used. 13 CFR 123.3
establishes the minimum criteria necessary for the Agency to declare a physical
disaster. SBA Form 987 is used by SBA’s Office of Disaster Assistance (ODA)
staff to record information regarding disaster damage. The information is
gathered by questioning affected individuals about the extent of their damage and
potential insurance recovery. State and local officials are also questioned to
obtain information helpful for the decision process. With this information, ODA
determines if sufficient damage has occurred to warrant a disaster declaration by
the Administrator of SBA.

3.

Technological collection techniques. Although the SBA 987 is in an electronic
format, it is not filled out by the public. ODA representatives collect the
information from public and State government officials in person after a disaster
has occurred. The information is used to complete the form. ODA representatives
who use electronic mobile devices collect information contained on the SBA 987.
The data is temporarily stored on the remote devices and then transferred to a core
database at a secure location through secure connections within the Disaster Credit
Management System (DCMS). DCMS is a web-based system that supports all
ODA loan-processing activities, including the disaster management, loss
verification, legal, document management, and portfolio maintenance tasks.

4.

Efforts to identify duplication. When other Federal Agencies are involved, joint
surveys are conducted whenever possible. Information is not available before the
disaster occurs. No other form used by the SBA collects this information.

5.

about

Impact on small businesses or other small entities. Where possible, a
visual-only inspection is made without the need to question the affected party.
When this is not possible, questions are limited to very general information
damage sustained and insurance coverage in effect.

6.

Consequence if collection is conducted less frequently or is not conducted. If this
information were not collected, ODA could not process disaster declaration
requests because there would be no basis upon which to determine if sufficient
damage has occurred to warrant a disaster declaration by the Administrator of
SBA. Since this information is collected only after a written request for a disaster
declaration is made by the Governor or Governor’s authorized representative of
the affected state, it cannot be collected less frequently.

7.

Existence of special circumstances. There are no special circumstances.

8.

Solicitation of public comment. ODA solicited comments in Federal Register
Vol. 71, No. 180, page 54704-dated September 18, 2006 (copy attached). The
comment period closed November 17, 2006, and no comments were received.

9.

Payments or gifts to respondents. There are no payments or gifts to respondents.

10.

Assurance of confidentiality. The information is not specifically linked to any
person or entity neither is it retrieved by a personal identifier. Therefore, there is
no need for assurances of confidentiality. The information is however, subject to
the Freedom of Information Act (5 U.S.C. §552).

11.

Questions of a sensitive nature. No sensitive questions are asked.

12.

Estimates of the hourly burden. We estimate that an average of 40 individuals
and businesses (respondents) are queried regarding damage to their property per
survey. It takes an estimated 5 minutes per response, which is based on the actual
experience of employees in the field who ask these questions.
The hour burden is based on survey activity for the 3 most recent fiscal years (FY
04, 05, and 06). Requests for Presidential and SBA Administrative declarations
(both declined and approved) are calculated as these are the declaration types that
require surveys. In the breakdown below, declines are listed separately because
we track them separately; however, they are essentially either Presidential or
Administrative declaration requests that were declined rather than approved,
based on the criteria not being met.

FY
04
05
06

Presidential &
Presidential SBA Administrative Administrative
Declarations
Declarations
Declines
41
30
2
21
35
1
25
39
2

Total
Surveys
73
57
66

Total surveys past 3 FYs = 196 divided by 3 = 66 average surveys per year
66 surveys x 40 respondents per survey = 2640 responses
2640 responses x .083 (5 minutes) per response = 219 hours
There are minimal financial costs to respondents. The cost estimate for a
respondent is based on a GS-5, Step 1 ($14.18 per hour), which is the level of
expertise (minimal) that is required to respond to simple questions. The annual
cost is calculated below:
219 hours x $14.18 per hour = $3,105 annual cost to respondents
13.

Estimate of total annual cost burden. There are no additional costs beyond that
identified in Item 12 above.

14.

Estimated annualized cost to the Federal Government. We estimate that it takes
approximately 10 hours to do the average survey. This information is based on
actual experience. Agency burden hours are calculated below:
66 surveys x 10 hours per survey = 660 Agency burden hours
The annual cost estimate for the Agency is based on the salary of a GS-11, Step 1,
($26.00 per hour), which is the typical grade for an employee performing these
surveys. The cost is calculated as follows:
660 total hours x $26.00 per hour = $17,160 Cost to the Government

15.

Explanation of program changes or adjustments in Items 13 and 14 on OMB
Form 83-I. The estimated cost to the respondent of $3,105 is an increase of $60
from the last submission. The estimated cost to the Government of $17,160 is a
increase of $232 from the last submission. This increase was caused by a change
in the basic salary of these grade levels, which has increased since the last
submission. The agency burden hours of 660 decreased by 90 hours from the
previous submission due to less disaster declaration requests.

16.

Collection of information whose results will be published. No publication is
anticipated.

17.

Expiration date for collection of information. ODA will display the expiration
date.

18.

Exceptions to certification statement in Block 19 on OMB Form 83-I. There are
no exceptions to the certification statement.

B. Collections of Information Employing Statistical Methods
N/A