Supporting Statement 02-26-07 L. Johnson

Supporting Statement for Paperwork Reduction Act
Submissions
OMB Control Number: 1660-0002
Title: Disaster Assistance Registration
Form Number(s): FEMA Forms 90-69 (English), 90-69A (Spanish),
ApplicationIRegistration for Disaster Assistance, FEMA Forms 90-69B
(English), 90-69C (Spanish), Declaration and Release and the new
Receipt for Government Property permit
General Instructions
A Supporting Statement, including the text of the notice to the public required by 5 CFR
1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register,
must accompany each request for approval of a collection of information. The
Supporting Statement must be prepared in the format described below, and must contain
the information specified in Section A below. If an item is not applicable, provide a brief
explanation. When Item 17 or the OMB Form 83-1 is checked "Yes", Section B of the
Supporting Statement must be completed. OMB reserves the right to require the
submission of additional information with respect to any request for approval.
To complete the supporting statement, type in your responses in the white space below
each question. Your responses should be full and complete and provide sufficient
information to help the OMB desk officer to understand what you are planning to do and
why and how the AgencyIFederal Government will benefit from and use the information
you will be obtaining or soliciting.

Specific Instructions
A. Justification
1. Explain the circumstances that make the collection of information necessary
(give details as to why this information is being collected). Identify any legal or
administrative requirements that necessitate the collection. Attach a copy of the
appropriate section of each statute and regulation mandating or authorizing the
collection of information. Provide a detailed description of the nature and source of
the information to be collected.
The Robert T. Stafford Disaster Relief and Emergency Assistance Act, Public Law 93288, as amended is the legal basis for FEMA to provide financial needs and services to

individuals who apply for disaster assistance benefits in the event of a major disaster. 44
CFR, Subpart D, Federal Assistance to Individuals and Households Section 206.1 10
implement the policy and procedures set forth in section 408 of the Robert T. Stafford
Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5174, as amended by the
Disaster Mitigation Act of 2000. This program provides financial assistance and, if
necessary, direct assistance to eligible individuals and households who, as a direct result
of a major disaster or emergency, have uninsured or under-insured, necessary expenses
and serious needs and are unable to meet such expenses or needs through other means.
44 CFR Part 206.1 17 authorize FEMA to provide direct assistance to applicants who is
eligible for housing assistance. In order to receive direct assistance for housing (e.g., a
mobile home or travel trailer) from FEMA, the applicant must be acknowledge and
accept the conditions for using government property. In addition, the applicant must
acknowledge that he or she has been informed of the conditions for continued direct
housing assistance. To accomplish these notifications, FEMA will use the applicant's
household composition data in NEMIS to prepare a Receipt for Government Property.
In addition, FEMA complies with the provisions of Title IV of the Personal
Responsibility and Work Opportunity Reconciliation Act of 1996, 8 U.S.C. $5 1601 et
seq. (Under Section 432. of Title IVYthe Attorney General of the United States, after
consultation with the Secretary of Health and Human Services, shall promulgate
regulations requiring verification that a person applying for a Federal public benefit is a
qualified alien and is eligible to receive such benefit.), with respect to determinations of
eligibility or disaster assistance for applicants who are not U.S. citizens.
2. Indicate how, by whom, and for what purpose the information is to be used.
Except for a new collection, indicate the actual use the agency has made of the
information received from the current collection. Provide a detailed description of:
a) how the information will be shared, if applicable, and for what programmatic
purpose.
After a major disaster or emergency is declared by the President, a Tele-Registration 800
number is published for individuals, to call so that they may apply for emergency
assistance. FEMA service representatives will interview applicants over the telephone
using a Intranet script, and record applicants information directly to the electronic copy
of FEMA Forms 90-69 (Engish) and 90-69A (Spanish) Application/ Registration For
Disaster Assistance in the National Emergency Management Information System
(NEMIS) computer system. In rare circumstances, when the system is not accessible, or
when phone lines are down, FEMA representatives will record information using the
paper versions of FEMA Forms 90-69 (Englkh) and 90-69A (Spanish)
ApplicatiodUegistration For Disaster Assistance. The paper versions of these forms are
entered into NEMIS by FEMA representatives.
In addition to registering over the telephone, applicants may apply for assistance online
and check the status of their application submitted to FEMA, using an Internet version of
FEMA Forms 90-69 (English) and 90-69A(Spanish) Application Registration for

Disaster Assistance and the "Guide to Disaster Assistance". The information collected
via the Internet will be electronically transferred to NEMIS so that information can be
stored, and processed according to the legal and administrative policies referenced above.
In order to be eligible to receive FEMA Disaster Assistance, a member of the household
must be a citizen, non-citizen national or qualified alien of the United States. F E W
Forms 90-69B (English) and 90-69C (Spanish), Declaration and Release form is used
to certify respondents information and eligibility, after the application process. FEMA
Forms 90-69B and 90-69C further informs the respondent of the Privacy Act and
Paperwork Burden Disclosure Notice. Once applicants have completed the Declaration
and Release form FEMA will notify contract firms for inspection of damaged properties.
Once property inspections are performed, the data is used to determine applicant
eligibility for financial assistance. Applicants that are eligible for payment are forward
into the NEMIS financial system for transmission to the U.S. Treasury. Applicants who
are not eligible are also entered in the NEMIS computer system. Depending on the nature
of the disaster/emergency and subsequent losses, individuals may be referred to other
agencies and organizations authorized to provide disaster relief assistance, such as the
Small Business Administration, the American Red Cross, the Internal Revenue Service,
etc.
Applicants who qualify for direct assistance for immediate housing (e.g., a mobile home
or travel trailer) must acknowledge and accept conditions for using government property.
A Receipt for Government Property (Temporary Housing Unit) permit was
developed for applicants to acknowledge the conditions for continued direct housing
assistance. Once an applicant is determined eligible for direct assistance, FEMA will use
the applicant's information collected on FEMA Form 90-69 to prepare the Receipt for
Government Property (Temporary Housing Unit) which will permit applicants to dwell in
temporary housing units. The Receipt for Government Property (Temporary Housing
Unit) permits is filed, with the applicants FEMA Form 90-69.

3. Describe whether, and to what extent, the collection of information involves
the use of automated, electronic, mechanical, or other technological collection
techniques or other forms of information technology, e.g., permitting electronic
submission of responses, and the basis for the decision for adopting this means of
collection. Also describe any consideration of using information technology to
reduce burden.
The registration process is done over the Internet, FEMAYs800 toll free number, or
through the submission of a paper form which later entered into the system to be
processed. All three of these registrations end up in the National Emergency Management
Information System (NEMIS) to be processed in the same manner. NEMIS is an
integrated database system used to provide FEMA, States, and other federal agencies
with automation and record storage capabilities to perform disaster and non-disaster
operations. NEMIS enables rapid and coordinated transition for monitoring an incident,
managing declarations, setting up Disaster Field Offices, and providing assistance to

communities and individuals affected by the disaster. The rational for this system is to
reduce the burden for applicants applying for assistance and to manage disaster
information more efficiently and economically.
Historical Background

During the 2004 Hurricane Season 1 million registrations were taken in 30 days
During the 2005 Hurricane Season 2 million registrations were taken in 35 days
(with record high days where over 100,000 registrations were taken in 1 day).
2005 Registrations and Agents

mm Call Center Agents
TeleRegs
-Teleregs

+ Internet
30000

25000

3
is000

6

B
f

10000 2

5000

0

Planning

FEMA's planning for future Hurricane Seasons included the review of network capacity
for the continuation of record high days. As such, FEMA's IT Directorate has provided
additional server capacity to the network to support higher application levels for both the
800# and Internet electronic application processes. Steps have also be taken to make
systems and websites more intuitive and user friendly, also meeting the requirement for
508 compliance for those with special needs. Finally, a Spanish Internet application
process has been added to FEMA.gov to assist those that prefer to register online in
Spanish.

4. Describe efforts to identify duplication. Show specifically why any similar
information already available cannot be used or modified for use for the purposes
described in Item 2 above.
There is no similar information available that can be used for the purposes of this
information collection.

5. If the collection of information impacts small businesses or other small
entities (Item 5 of OMB Form 83-I), describe any methods used to minimize.
The NEMIS system is designed in such a way that small business owners are referred
immediately to the Small Business Administration (SBA) for disaster assistance. Many
of the questions in the NEMIS computer systems is not necessary for businesses. Once
NEMIS identify a business registration, these applicants are referred to SBA. Therefore
the burden for businesses is minimal.

6. Describe the consequence to FederaVFEMA program o r policy activities if
the collection of information is not conducted, or is conducted less frequently, as
well as any technical or legal obstacles to reducing burden.
Information will be collected only when the President has declared a major disaster or
emergency that has affected individuals and families. To fulfill the mandates of the
Robert T. Stafford Disaster Relief and Emergency Assistance Act, as amended and
provide all victims with disaster assistance for which they are eligible, registration
information must be collected. Without this collection, disaster victims would have to
make inquiries to government agencies/departments, active in the disasters, to determine
program availability appropriate to their needs. Additionally, applicants for Housing
Assistance, Other Needs Assistance, and SBA loans would have to file separate
registrations or intake documents with individual agencies/departments, greatly
increasing paperwork burdens.
7. Explain any special circumstances that would cause an information
collection to be conducted in a manner:
(a) Requiring respondents to report information to the agency more
often than quarterly.
There are no requirements for respondents to report information to the agency more often
than quarterly.
(b) Requiring respondents to prepare a written response to a
collection of information in fewer than 30 days after receipt of it.
There are no requirements for respondents to prepare a written response to a collection of
information in fewer than 30 days after receipt of it.
(c) Requiring respondents to submit more than a n original and two
copies of any document.
There are no requirements for respondents to submit more than an original and two
copies of any documents.

(d) Requiring respondents to retain records, other than health,
medical, government contract, grant-in-aid, or tax records for more than three
years.
There are no requirements to respondents to retain records for more than three years.
(e) In connection with a statistical survey, that is not designed to
produce valid and reliable results that can be generalized to the universe of study.
There is no statistical survey, involved with this collection of information.
(f) Requiring the use of a statistical data classification that has not

been reviewed and approved by OMB.
There are no requirements to use statistical data classification that has not been reviewed
and approved by OMB.
(g) That includes 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.
There is no pledge of confidentiality that is not supported by authority established in
statute or regulation for this information collection.
(h) Requiring respondents to 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.
There are no requirements for respondents to submit proprietary trade secret, or other
confidential information for this collection.

8. Federal Register Notice:
a. Provide a copy and identify the date and page number of publication in
the Federal Register of the agency's notice soliciting comments on the information
collection prior to submission to OMB. Summarize public comments received in
response to that notice and describe actions taken by the agency in response to these
comments. Specifically address comments received on cost and hour burden.
A 60 day Federal Register Notice was published for this collection on December 4,2006,
volume 71, number 232, pages 70416 - 704 17. There were no comments received for
this collection of information.

b. Describe efforts to consult with persons outside the agency to obtain their
views on the availability of data, frequency of collection, the clarity of instructions
and recordkeeping, disclosure, o r reporting format (if any), and on the data
elements to be recorded, disclosed, o r reported.

FEMA frequently work with persons outside of the agency, who serve in a partnership
role to facilitate our assistance or to provide other forms of assistance to disaster victims.
Following are some key outside organizations and their role in this process:
The U.S. Treasury uses address information from the registration to send financial
assistance awarded to applicants. Inspection Contract Firms use data to schedule and
perform inspections. They also gather the signed 90-69 B/C Declaration and Release
forms. State's Other Needs Assistance Program Offices - Based on income, insurance
and need, applicants' information is shared with State Other Needs Assistance Program
Offices in Joint disasters where the state has opted to direct their own Other Needs
Assistance Program.
Small Business Administration - Based on income, insurance, and need, applicants'
information is shared with the Small Business Administration for consideration of loans.
c. Describe consultations with representatives of those from whom information
is to be obtained o r those who must compile records. Consultation should occur at
least once every three years, even if the collection of information activities is the
same as in prior periods. There may be circumstances that may preclude
consultation in a specific situation. These circumstances should be explained.

Under Executive order 12862, Federal Agencies are to develop a customer service
orientation 'for use in the implementation of their programs. In accordance with Executive
Order 12862, FEMA review customer service performance and provide customer service
feedback through the Disaster Assistance Customer Satisfaction Survey. The data
collection for this survey is approved under OMB No. 1660- 0036, F E W Public
Assistance Program Evaluation and Customer Satisfaction Surveys and Individual
Assistance Customer Satisfaction Surveys.

9. Explain any decision to provide any payment o r gift to respondents, other
than remuneration of contractors o r grantees.
There is no payment or gift to respondents for this data collection.
10. Describe any assurance of confidentiality provided to respondents and the
basis for the assurance in statute, regulation, o r agency policy.
The individual will be advised of the Privacy Act prior to providing any personal
information. During the registration process the registrar or the individual reads the
Privacy Act regarding authority to collect information, primary purposes, and routine
uses of the information. The individual is advised that the information may be given to

various federal and State agencies, insurers or lenders, as well as specific organizations
and agencies from which the individual is directly seeking assistance. A compilation of
the individual's responses in the form of the 90-69/A, ApplicatiordRegistration for
Disaster Assistance, is mailed to each individual; however, the Privacy Act Statement is
not included mailed.
At the time of inspection, the 90-69B/C, Declaration and Release, which includes the
Privacy Act Statement and Paperwork Burden Disclosure Notice, is presented to the
individual for signature. The individual is further advised that helshe must provide
private information, such as family financial status, to determine possible eligibility for
assistance. Finally, the individual is advised that the information may be shared with
state and local government agencies to promote hazard mitigation measures designed to
reduce repetitive loss from disasters and to prevent the duplication of benefits between
federal and state agencies.
11. Provide additional justification for any questions of a sensitive nature, such
as sexual behavior and attitudes, religious beliefs, and other matters that are
commonly considered private. This justification should include the reasons why the
agency considers the questions necessary, the specific uses to be made of the
information, the explanation to be given to persons from whom the information is
requested, and any steps to be taken to obtain their consent.

Respondents are not required to provide additional justification for questions of a
sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters
that are commonly considered private.

12. Provide estimates of the hour burden of the collection of information. The
statement should:
a. Indicate the number of respondents, frequency of response, annual
hour burden, and an explanation of how the burden was estimated. Unless directed
to do so, agencies should not conduct special surveys to obtain information on which
to base hour burden estimates. Consultation with a sample (fewer than 10) of
potential respondents is desired. If the hour burden on respondents is expected to
vary widely because of differences in activity, size, or complexity, show the range of
estimated hour burden, and explain the reasons for the variance. Generally,
estimates should not include burden hours for customary and usual business
practices.
Annual Burden Hours

Tele-Registration Application
Registration for Disaster Assistance
1,151,255

1

18 min

1,151,255

345,377

Internet Application Registration for
Disaster Assistance (English and
Spanish)
Paper version of FEMA Form 90-69
and 90-69A (English and Spanish)
FEMA Form 90-69B and 90-69C,
Declaration and Release (English
and Spanish)
Receipt for Government Property
(Temporary Housing Unit) (English
TOTAL

5 15,487

1

18 min

5 15,487

154,646

51,549
1,718f 91

1

18 rnin.

5 1,549

15,465

64 %

1

2 min.

1,099,706

36,657

1,718291
2,835,180 555,009

It has been estimated that a total of 1,718,291 applicants will apply for Disaster
Assistance.
The number of respondents using the FEMA 1-800 number for completing FEMA
Forms 90-69 and 90-69 A (English and Spanish) is historically estimated to be 67%
(1,15 1,255) of the total numbers of applications for disaster assistance registration. It has
been estimated that it takes approximately 18 minutes for applicants to complete a
registration through calling the FEMA 1-800 number.
The number of respondents using the internet for completing FEMA Form 90-69 and
90-69 (English and Spanish) is historically estimated to be 30% (515,487) of the total
numbers of applications for disaster assistance registration. It has been estimated that it
takes approximately 18 minutes for applicants to complete a registration through the
FEMA Internet website.
The number of respondents using FEMA Form 90-69A paper (English and Spanish) is
historically estimated to be 3% (5 1,549) of the total numbers of applications for disaster
assistance registration. It has been estimated that it takes approximately 18 minutes for
applicants to complete a registration with a FEMA representative using a paper form.
It has been estimated that historically approximately 64% (1,099,706) of applicants will
complete FEMA Form 90-69 B and C (English and Spanish) once they have registered
for disaster assistance. This numbers of applications will results in property inspections.
It has been estimated that it takes approximately 2 minutes for applicants to review and
sign the FEMA Form 90-69 B or C for Declaration and Release.
The number of respondents for Receipt for Government Property (English and Spanish)
is estimated to be 1% (1 7,183) of the total numbers of applications for disaster assistance
registration. Historically, approximately 1% of the total numbers of applications for
disaster assistance results in the awarding of direct assistance (e.g., mobile home or travel
trailer). It has been estimated that it takes approximately 10 minutes for applicants to
review and sign the Receipt for Government Property permit.

b. If this request for approval covers more than one form, provide separate
hour burden estimates for each form and aggregate the hour burdens in Item 13 of
OMB Form 83-1.
c. Provide estimates of annualized cost to respondents for the hour burdens
for collections of information, identifying and using appropriate wage rate
categories. The cost of contracting out or paying outside parties for information
collection activities should not be included here. Instead this cost should be
included in Item 14.

]~ndividuals
and ~ouseholdsl 555,009
I

Total

1
I

$18.90

1
I

$5.67

1

10.489.670.

1

I

10,489,670

It is estimated that the annualized hour burden cost to respondents for the hour burdens
will be approximately $10,489,670. for completing the Disaster Assistance Registration
applications for this collection of information. Respondents are individuals and families
who have applied for assistance as a result of a declaration of a major disaster or
emergency.

13. Provide an estimate of the total annual cost burden to respondents or
recordkeepers resulting from the collection of information. The cost of purchasing
o r contracting out information collection sewices should be a part of this cost
burden estimate. Do not include the cost of any hour burden shown in Items 12 and
14. The cost estimates should be split into two components:
There are no recordkeeping requirements to respondents for this collection of
information.
a. Operation and Maintenance and purchase of sewices component.
These estimates should take into account cost associated with generating,
maintaining, and disclosing or providing information. Include descriptions of
methods used to estimate major cost factors including system and technology
acquisition, expected useful life of capital equipment, the discount rate(s), and the
time period over which costs will be incurred.
There are no operation and maintenance and purchase of services component to
respondents for this collection of information.
b. Capital and Start-up-Cost should include, among other items,

preparations for collecting information such as purchasing computers and software,
monitoring sampling, drilling and testing equipment, and record storage facilities.
There are no capital and start-up-cost to respondents for this collection of information.
14. Provide estimates of annualized cost to the Federal Government. Also, provide
a description of the method used to estimate cost, which should include
quantification of hours, operational expenses (such as equipment, overhead,
printing and support staff), and any other expense that would have been incurred
without this collection of information. You may also aggregate cost estimates for
Items 12,13, and 14 in a single table.
ANNUALIZED COST TO THE FEDERAL GOVERNMENT

Item
Contractor Cost (343 remote contract personnel performing Tele-Registration at $14

Cost

3,438,490
h
a
per hour to support t
Staff Salaries (190 GS-5 @ $14 per hour supporting the projected 1.2M annual TeleRegistrations)
1,934,150
Facilities (leasing a temporary Disaster Assistance Tele-Registration Center)
2,000,000
Computer Hardware and Software (estimated annual cost for 190 FEMA
workstations used to take registrations @, 166.3 1 each)
3 1,599
Equipment Maintenance (estimated to be 10% of the Computer Hardware and
Software cost (3 1,599)
3,159
Travel (10 FEMA staff @ $5,000 per employee to travel to remote sites to provide startup assistance to contract supervisory personnel managing the Teleregistration call center)
50,000
Printing (approximately 1,200,000Disaster Assistant Guides and 1,200,000 FEMA Form 90-96 ) 6,000,000
Postage (cost of mailing 1.2M FEMA Form 90-69 and applicant Disaster Assistant guides
1,800,000
to individuals based on annual registration projections)
Other (Security badges and headsets for 343 employees @ $10 each)
3,430
Total
$15,257,669

P

I

1

(

I

This above table outlines estimated expenses to support the projected 1.2M average
annual applications for Federal assistance. Contractor cost covers remote call center surge
staff (343) hired on a temporary basis to handle overflow registrations that FEMA can not
support. Staff salaries is projected expense for 190 FEMA staff assigned to take the initial
part of the 1.2M registration load. Facilities expense is estimated to be $2M for a
temporary call center facility leased for one year. Computer Hardware and Software
expense supports the 190 FEMA personnel with workstations to perform registration
intake. Equipment maintenance covers repair and replacement for the 190 workstations at
10% of the equipment cost. Travel is projected for 10 FEMA staff to provide orientation
for remote call center management staff at the start-up of remote facilities. Printing cost
is estimated for Disaster Assistance Guides and completed 90-69 forms that are mailed to
applicants. Postage covers the mailing of the printed documents. Other expense covers
the cost for FEMA and remote call center staff security badges.

15. Explain the reasons for any program changes or adjustments reported in
Items 13 or 14 of the OMB Form 83-1. Changes in hour burden, i.e., program
changes or adjustments made to annual reporting and recordkeeping hour and cost
burden. A program change is the result of deliberate Federal government action.
All new collections and any subsequent revisions of existing collections (e.g., the
addition or deletion of questions) are recorded as program changes. An adjustment
is a change that is not the result of a deliberate Federal government action. These
changes that result from new estimates o r actions not controllable by the Federal
government are recorded as adjustments.

The Disaster Assistance Registration process has been optimized to flow in a logical and
efficient manner for applicants and staff gaining efficiencies in the registration process.
Streamlining and optimization of the process has resulted in a decrease in the average
time for processing Disaster Assistant Applications while the number of responses has
increased. The burden hour for this data collection have increased from 163,113 burden
hours to 557,009 hours (+391,896) and from 482,584 responses to 1,718,291
(+1,235,707)) responses. The following data collection activities have caused an increase
in burden hour estimates.
During the last OMB submission the Tele-Registration intake burden hours and the
FEMA Form 90-69 and 90-69A burden hours were combined. The previous burden hour
was estimated to be 5% (7824) for FEMA Form 90-69 and 90-69A and 95% (200,200)
for Tele-Registration, which was estimated to have a total burden of 163,113 hours.
The current estimate for Tele-Registration is 1,151,255 responses and 345,377 burden
hours. Therefore an adjustment of +145,177 burden hours has been estimated for this
information.
The current estimates for FEMA Form 90-69 and 60-69A have estimated to be 5 1,549
responses and 15,465 burden hours. Therefore an adjustment of +720,000 responses and
+208,024 burden hours have been revised in for this information.
The Internet Application Registration burden estimates have been included in this
Information Collection Request (ICR). Applicants register for disaster assistance on-line
using the internet. An adjustment increase of +5 15,487 responses and +l54,646 total
burden hours has been estimated for use the internet application for Disaster Assistance
Registration.

Depending on the nature of the disasterlemergency and subsequent losses, individuals
may be referred to other agencies and organizations authorized to provide disaster relief
assistance. FEMA Form 90-69B and 90-69C responses was previously estimated to
be308,854 (64% of 482,584) which had an burden hour estimated of 10,295 hours. Due
to the increase in the number of response for this submission, The number of response is
estimated to be 1,099,706 responses (64% of 1,718,291) and 36,657 burden hours.
Therefore this data have a difference of +26,362 hours and +790,852 responses.
The Receipt for Government Property (English and Spanish) is new information that is
captured as a program change for this data collection. The number of responses for this
new information is estimated to be 1% (1 7,183) of the total numbers of applications for
disaster assistance registration. The burden hour for this data collection is estimated to be
+2,864 hours. In order to receive direct assistance for housing (e.g., a mobile home or
travel trailer) from FEMA, the applicant must be acknowledge and accept the conditions
for using government property authorized under 44 CFR 206.1 17..

16. For collections of information whose results will be published, outline plans
for tabulation and publication. Address any complex analytical techniques that will
be used. Provide the time schedule for the entire project, including beginning and
ending dates of the collection of information, completion of report, publication
dates, and other actions.
There is no collection of information whose results will be published for tabulation and
publication.

17. If seeking approval to not display the expiration date for OMB approval of
the information collection, explain reasons that display would be inappropriate.
A valid OMB control number, expiration date and burden disclosure notice will be
displayed in all collection's material.
18. Explain each exception to the certification statement identified in Item 19
"Certification for Paperwork Reduction Act Submissions," of OMB Form 83-1.
There is no certification exception for this collection of information.

B. Collections of Information Employing Statistical Methods.
There are no statistical methods involved with this collection of information.

1. Describe (including numerical estimate) the potential respondent universe
and any sampling o r other respondent selection method to be used. Data on the
number of entities (e.g., establishments, State and local government units,
households, o r persons) in the universe covered by the collection and in the
corresponding sample are to be provided in tabular form for the universe as a whole

and for each of the strata in the proposed sample. Indicate expected response rates
for the collection as a whole. If the collection has been conducted previously,
include the actual response rate achieved during the last collection.

The collection of information does not employ statistical methods.

2. Describe the procedures for the collection of information including:
Statistical methodology for stratification and sample selection,
Estimation procedure,
Degree of accuracy needed for the purpose described in the justification,
Unusual problems requiring specialized sampling procedures, and
Any use of periodic (less frequent than annual) data collection cycles to
reduce burden.
3. Describe methods to maximize response rates and to deal with issues of nonresponse. The accuracy and reliability of information collected must be shown to be
adequate for intended uses. For collections based on sampling, a special
justification must be provided for any collection that will not yield "reliable" data
that can be generalized to the universe studied.
4. Describe any tests of procedures or methods to be undertaken. Testing is
encouraged as an effective means of refining collections of information to minimize
burden and improve utility. Tests must be approved if they call for answers to
identical questions from 10 o r more respondents. A proposed test or set of tests may
be submitted for approval separately o r in combination with the main collection of
information.

5. Provide the name and telephone number of individuals consulted on
statistical aspects of the design and the name of the agency unit, contractor(s),
grantee(s), or other person(s) who will actually collect and/or analyze the
information for the agency.