Icr 2577-0062

Paperwork Reduction Act Submission

Please read the instruction before completing this form. For additional forms or assistance in completing this forms, contact your agency’s Paperwork Reduction Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 Seventeenth St., NW, Washington, DC 20503.

1. Agency/Sub-agency Originating Request: U.S. Department of Housing and Urban Development Office of Public and Indian Housing		2. OMB Control Number: a. 2577-0062	b.   None      
3. Type of information collection: (check one) New Collection Revision of a currently approved collection Extension of a currently approved collection Reinstatement, without change, of previously approved collection for which approval has expired Reinstatement, with change, of previously approved collection for which approval has expired Existing collection in use without an OMB control number For b-f, note item A2 of Supporting Statement instructions.	4. Type of review requested: (check one) Regular Emergency - Approval requested by       Delegated 5. Small entities: Will this information collection have a significant economic impact on a substantial number of small entities? Yes No 6. Requested expiration date: a. Three years from approval date b. Other (specify)      

7. Title:

Energy Conservation for PHA-owned or Leased Projects - Audits, Utility Allowances

8. Agency form number(s): (if applicable)

HUD-50078

9. Keywords:

Housing, Public Housing, Management, Utility Allowances, Resident(s)

10. Abstract:

PHAs establish allowances for PHA-furnished utilities and for resident-purchased utilities. PHAs document, and provide for resident inspection, the basis upon which allowances and scheduled surcharges (and revisions thereof) are established. PHAs complete energy audits, benefit/cost analyses for individual meters vs. master-metering. Additionally, PHAs review annual and updated tenant utility allowances, as necessary.

11. Affected public: (mark primary with “P” and all others that apply with “X”) a.  Individuals or households e.   Farms b.   Business or other for-profit f.   Federal Government c. Not-for-profit institutions g. P State, Local or Tribal Government		12. Obligation to respond: (mark primary with “P” and all others that apply with “X”) a.   Voluntary b. P Required to obtain or retain benefits c.   Mandatory
13. Annual reporting and recordkeeping hour burden: a. Number of respondents 3090 b. Total annual responses 3090 Percentage of these responses collected electronically 0% c. Total annual hours requested 9330 d. Current OMB inventory 13269 e. Difference (+,-) 3939 f. Explanation of difference: 1. Program change: -3939 2. Adjustment:      		14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) Do not include costs based on the hours in item 13. a. Total annualized capital/startup costs       b. Total annual costs (O&M)       c. Total annualized cost requested       d. Current OMB inventory       e. Difference       f. Explanation of difference: 1. Program change:       2. Adjustment:      
15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”) a.   Application for benefits e. X Program planning or management b. X Program evaluation f.   Research c.   General purpose statistics g. X Regulatory or compliance d. P Audit		16. Frequency of recordkeeping or reporting: (check all that apply) a. Recordkeeping b. Third party disclosure c. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biannually 8. Other (describe)      
17. Statistical methods: Does this information collection employ statistical methods? Yes No	18. Agency contact: (person who can best answer questions regarding the content of this submission) Name: Nicole Faison Phone: 202-708-0744 x4267

19. Certification for Paperwork Reduction Act Submissions

On behalf of the U.S. Department of Housing and Urban Development, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9.

Note: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320/8(b)(3). appear at the end of the instructions. The certification is to be made with reference to those regulatory provisions as set forth in the instructions.

The following is a summary of the topics, regarding the proposed collections of information, that the certification covers:

1. It is necessary for the proper performance of agency functions;

2. It avoids unnecessary duplication;

3. It reduces burden on small entities;

4. It uses plain, coherent, and unambiguous terminology that is understandable to respondents;

5. Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

6. It indicates the retention periods for recordkeeping requirements;

7. It informs respondents of the information called for under 5 CFR 1320.8(b)(3):

1. Why the information is being collected;

2. Use of the information;

3. Burden estimate;

4. Nature of response (voluntary, required for a benefit, or mandatory);

5. Nature and extent of confidentiality; and

6. Need to display currently valid OMB control number;

8. It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to collected (see note in item 19 of the instructions);

9. It uses effective and efficient statistical survey methodology; and

10. It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.

     

Signature of Program Official: X      

Date:

Supporting Statement for Paperwork Reduction Act Submissions

A. Justification

1. This information collection is necessary to comply with the requirements of 24 CFR Part 965, Subpart C, which implements HUD policies in support of national energy conservation goals by requiring Public Housing Agencies (PHAs) to conduct energy audits and undertake certain cost-effective energy conservation measures. All PHAs shall complete an energy audit for each PHA-owned project under management, not less than once every five years. Solicitations for energy performance contracting shall be submitted to the HUD Field Office for review and approval prior to contract award. A benefit/cost analysis shall be made to determine whether a change from a master-metering system to individual meters will be cost effective.

Additionally, 24 CFR Part 965, Subpart E, requires PHAs to establish, review and revise utility allowances for PHA-furnished utilities for all check-metered utilities and allowances for resident-purchased utilities for all utilities purchased directly by residents from the utilities suppliers. The PHA shall maintain a record that documents the basis on which allowances and scheduled surcharges, and revisions thereof, are established and revised. Such record shall be available for inspection by residents.

The PHA shall review, at least annually, the basis on which utility allowances have been established and, if reasonably required.

Authority: 42 U.S.C. 1437, 1437a, 1437d, 1437g, and 3535(d).

2. PHAs establish utility allowances, conduct energy audits, solicit for energy performance contracts, and conduct a benefit/cost analysis for master-metering system versus check-metered utilities as required by statute and HUD regulations. The optional form HUD-50078 is a tool available to PHAs to assist them with energy audits. The data collected is a compilation of facility and utility usage data for each PHA-owned project. With the exception of form HUD-50078, which may be transmitted electronically, faxed, or mailed to a designated location, all other required documents are submitted to appropriate HUD field offices. Additionally, PHAs are required to maintain records for establishing annual utility allowances for resident inspection/review.

3. This collection of information does not require the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology. Consideration of using information technology to reduce burden has been discussed. At this time no automation plans have been developed, except for the collection of data related to HUD benchmarking (form HUD-50078), which is a voluntary submission. The fact that establishment of utility allowances, energy performance contracts, and benefit/cost analysis would be different for each PHA needs further analysis and costing.

4. HUD regulations permit PHAs to use or modify similar information for establishing utility allowances, if available. Energy audits, energy performance contracts and benefit/cost analysis are conducted and solicited for each PHA. The information provided by each PHA will be different for each PHA.

5. If a small PHA cannot develop the required utility allowance information, HUD regulation allows them to use information from other sources.

6. The Federal Government provides most PHAs with subsidies for operating costs of public housing developments. Included in the operating costs is the cost of utilities. If utility allowances are more than reasonable, the PHA may be receiving more subsidies than it should. The residents may, by litigation, receive court-imposed amounts from the PHA which could cause added Federal subsidies.

7. There are no special circumstances that would cause this information collection be conducted more than quarterly; written response fewer than 30 days after receipt of it; submit more than an original and two copies of any document; retain records, use of statistical data classification that has not been reviewed and approved by OMB, etc.

8. HUD published a Federal Notice of Proposed Information Collection dated September 11, 2006, allowing the public a 60-day comment period. The comment period ends November 13, 2006. HUD received no comments on this information collection.

9. No payment or gift is provided to respondents.

10. There are no assurance of confidentially provided to respondents.

11. There are no questions of a sensitive nature.

11. The reporting and recordkeeping requirement are estimated as follows:

Regulation Reference	No. of Respondents	X	Frequency of Response	Total Responses	X	Estimated Hours	=	Total Annual Burden Hours
965.302 - Energy Audits	680		1	680		3.5		2380
965.308 - Energy Performance Contracts	15		1	15		24		360
965.402 - Benefit/Cost Analysis	15		1	15		2		30
965.502 - Establish utility allowances	500		1	500		8		4000
965.506 - Establishment of Surcharges For Excess Consumption	200		1	200		1		200
965.507 – Review and revise utility allowances	680		1	680		2		1360
965.508 Individual Relief Criteria	1000		1	1000		1		1000
TOTALS	3,090			3,090				9,330

11. No other costs are associated with this collection.

14. The cost to the Federal Government is not determinable since it will be part of the general cost to operate the PHA.

15. This is an extension of an existing information collection. Decrease in burden hours is because the majority of PHAs have already established utility allowances for PHA-furnished utilities and resident-purchased utilities. Energy audits are performed only every 5 years and benefit/cost analyses are optional for PHAs with more than one project of similar design and utilities services. Additionally, utility allowances are reviewed annually when significant change in reasonable consumption occurs and changes in utility rates. Therefore, PHAs revise utility allowances between annual reviews, only if there is a rate change that is greater than 10 percent or more from rates which the allowances were based.

16. The information collection results will not be published.

17. A separate Federal Register Notice will be published to announce the OMB approval number and expiration.

18. There are no exceptions to the certification statement identified in item 19, OMB 83-I

B. Collections of Information Employing Statistical Methods

This collection of information will not employ statistical methods.

OMB 83-I 10/95