Supporting Statement 1660-0033

March 28, 2007

Supporting Statement for
Paperwork Reduction Act Submissions
OMB Control Number: 1660-0033
Title: Residential Basement Flood Proofing Certification
Form Number: FEMA form 81-78
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-I 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.

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 National Flood Insurance Program(NFIP)administered by the Federal Emergency
Management Agency (FEMA), regulation 44 CFR 60.3, Floodplain management criteria for
flood-prone areas, ensures that communities participating in the NFIP, in Special Flood
Hazard Areas (SFHAs), have basement construction at the lowest floor elevation or above
the 100 year flood elevation, or Base Flood Elevation. This requirement is to reduce the
risks of flood hazards to new buildings in SFHAs and reduce insurance rates. However, 44
CFR 60.6,c, regulation allow communities to apply for an exception to permit and certify
the construction of flood proof residential basements in SFHAs. This certification must
ensure that the community has demonstrated that the areas of special flood hazard, in which
residential basements will be permitted, are subject to shallow and low velocity flooding and
adequate flood warning time to notify residents of impending floods. This allows the
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community to ensure that local floodplain management ordinances are met as well as a
certificate that allow homeowners to receive a "discounted" flood insurance rate applicable
to flood proof basements.
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.
FEMA form 81-78 is only used in communities that have been granted an exception by
FEMA to allow the construction of flood proof residential basements in SFHAs.
Homeowners must have a registered professional engineer or architect complete FEMA
form 81-78 for development or inspection of a properly designed and constructed
basement, and certify that the basement design and methods of construction are in
accordance with floodplain management ordinances. In any case homeowners are
responsible for the fees involved with these services. The local community may require that
FEMA form 81-78 be used in the permitting process for new residential basement
construction in SFHAs. Homeowners provide FEMA form 81-78 to their insurance agent to
receive discounted flood insurance rates under the NFIP. The homeowner, the insurance
agent, and the community official would all retain a copy of this form for recordkeeping
purposes.
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.
FEMA Form 81-78 is submitted in conjunction with an application for National Flood
Insurance Program insurance. There are no provisions for this form to be submitted
electronically; however, it is available for downloading from the FEMA website at
http://www.fema.gov/pdf/nfip/manual200505/08cert.pdf
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 are no duplications of FEMA Form 81-78.
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.
This collection does not impact any small businesses or other small entities.

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6. Describe the consequence to Federal/FEMA program or 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.
If this information is not collected, there would be difficulty in assuring that proper
construction and flood proofing techniques are being utilized, and in providing lower flood
insurance rates to homeowners.
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.
This information only needs to be collected when property owners in SFHAs build a
flood proof basement in a community which has received a basement exception.
(b) Requiring respondents to prepare a written response to a
collection of information in fewer than 30 days after receipt of it.
There is no request for a written response in fewer than 30 days.
(c) Requiring respondents to submit more than an original and two
copies of any document.
There is no request to submit additional copies of documents.
(d) Requiring respondents to retain records, other than health,
medical, government contract, grant-in-aid, or tax records for more
than three years.
This collection does not have recordkeeping requirements.

(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.
This collection does not employ statistical methodology.
(f) Requiring the use of a statistical data classification that has not
been reviewed and approved by OMB.
The information collection will not use any statistical data classification not reviewed and
approved by OMB.

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(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.
No assurance of confidentiality has been provided to respondents.
(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.
Respondents will not be asked to submit proprietary trade secrets.

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 comments on January 23, 2007
Volume 72, Number 14, pp. 2894. There were no comments received for this collection.
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, or reporting format (if any), and on the data
elements to be recorded, disclosed, or reported.
NFIP program personnel frequently discuss the certificate at meetings with involved
users; e.g., insurance agents, company officials, surveyors, local officials, and others.
FEMA worked very closely with the surveyors, engineers, architects, local community
officials, and International Code Council during the development process.
c. Describe consultations with representatives of those from whom information
is to be obtained or 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.
FEMA has a team of engineers who have certified a large proportion of all flood proof
basements built in communities with exceptions. The engineers consult with local

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community engineers and architects with respect to the amount of time necessary to
certify flood proof basement construction and the cost to homeowners for certification.
9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
No payment or gift was given to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis
for the assurance in statute, regulation, or agency policy.
Respondents were not provided with any assurance of confidentiality.
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.
There are no questions that are of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information. The
statement should:
a.

Data Collection
Activity/Instrument
FEMA form 81-78
TOTAL

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.
No. of
Respondents

Frequency
of
Responses

Hour
Burden Per
Response

Annual
Responses

(A)
150
150

(B)
1
1

(C)
3.25
3.25

(D) = (AxB)
150
150

Total
Annual
Hour
Burden
(E) = (CxD)
487.5
487.5

FEMA Form 81-78 is submitted by the homeowner in conjunction with his or her
application for National Flood Insurance Program insurance. The homeowner provides
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his or her name and property address for the form. It is required that a registered
professional engineer or architect complete Sections II and III of the form. The
homeowner employs the services of the engineer or architect in completing the technical
sections of the form.
It is estimated that the average time required for completing and submitting this form is
3.25 hours. This time is allocated to the engineer or architect in obtaining the information
required and completing the sections of the form that require professional expertise and
certification.
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-I.
This request for approval does not cover more than one form.
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.

Table 2. Annual Cost to Respondents for Hour Burden.
Data Collection
Activity/Instrument

Respondent’s
Occupational
Category

Median
Wage
($)

Average Cost
Per
Respondent

Total Annual
Hour Burden
(hour)

Total Annual
Cost Burden
($)

(F)

(FxC)

(E)

(G) = (FxE)

$28.94

$94.06

487.5

$14,108.25

$28.94

$94.06

487.5

$14,108.25

from Table 1

FEMA Form 81-78
Architect &
Engineers
TOTAL

13. Provide an estimate of the total annual cost burden to respondents or
recordkeepers resulting from the collection of information. The cost of purchasing
or contracting out information collection services 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:
a. Operation and Maintenance and purchase of services component.
The average cost paid to the architect or engineer employed by a homeowner to complete
this form is $325. For 150 respondents, the total annual cost burden is $48,750, i.e., 150
forms x $325 per form.
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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/or Start-Up Cost.
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
Contract Costs [Specify what is for and what is included, i.e. S/W development,
survey, etc.] Contractor staff costs to process, manage, and review the forms
Staff Salaries [State number of employees involved, GS-level, Time spent w/
this collection] 1 GS 14: 20 hours @ $45.00 an hour annually
Facilities
Computer Hardware and Software
Equipment Maintenance
Travel
Printing 6,000 copies (as inventory requires)
Postage
Other
Total

Cost ($)
312.50
900.00
600.00
0.00
0.00
0.00
200.00
235.00
0.00
$2247.50

The estimated annual cost to the Federal government, performed by the contractor, to
process, manage and review this information is approximately $ 312.50 (150 forms / 12
per hour = 12.5 hours x $25.00/hour = $312.50). This amount includes the review,
validation, and data entry of the information necessary to rate the flood insurance policy.
The approximate cost is determined as follows:
• Total number of certificates processed = 150
• Production rate per hour = 12
• Underwriting Specialist Rate per hour = $25.00
In addition, a GS-14 Federal employee may spend approximately 1% or 20 hours
annually to review the form and to answer questions pertaining to the form. The
approximate cost of $900 is determined as follows: One Insurance Examiner GS-14 level
may spend a total of 20 hours annually. The average rate per hour is $45.00. The total
annual cost for the GS-14 is $900.
The Federal government may spend $200 annually to print (as inventory levels require)
approximately 6,000 copies of the Residential Basement Floodproofing Certificate. In
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addition, the Federal Government may spend approximately $235 annually for postage to
mail approximately 600 of these forms. The cost of storing these forms is approximately
$50 per month, or $600 annually. The total annualized cost to the Federal Government is
$2247.50.
15. Explain the reasons for any program changes or adjustments reported in Items
13 or 14 of the OMB Form 83-I in a narrative form. Present the itemized changes in
hour burden and cost burden according to program changes or adjustments in
Table 5. Denote a program increase as a positive number, and a program decrease
as a negative number.
Definitions
Program changes should not be confused with adjustments.
i) Program change
A "Program increase" is an additional burden resulting from an action or directive of a branch
of the Federal government (e.g., an increase in sample size or coverage, amount of information,
reporting frequency, or expanded use of an existing form). This also includes previously in-use
and unapproved information collections discovered during the ICB process, or during the fiscal
year, which will be in use during the next fiscal year.
A "Program decrease", is a reduction in burden because of: (1) the discontinuation of an
information collection; or (2) a change in an existing information collection by a Federal agency
(e.g., the use of sampling (or smaller samples), a decrease in the amount of information requested
(fewer questions), or a decrease in reporting frequency).

ii) An "Adjustment" denotes a change in burden hours due to factors over which the
government has no control, such as population growth, or in factors which do not affect
what information the government collects or how (e.g., changes in the methods used to
estimate burden or correction of errors in burden estimates).
Itemized Changes in Hour Burden and Cost Burden.

Data Collection Activity/Instrument

Changes in Hour Burden
Program
Changes
(hours)

Residential Basement Floodproofing Certificate
Total
Data Collection Activity/Instrument

Changes in Cost Burden
Program
Changes ($)

Residential Basement Floodproofing Certificate
Total

Adjustments (hours)

487.5 hrs -163 hrs
+324.5hrs
Adjustments
($)

0+$48,750.50=$48,750.50
+$48,750.50

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The previous burden hours for this collection were 163 hrs. There has been an increase
in burden hours to 487.5 hours which equals an increase in hours of 324.5 hours. The
previous cost in burden for this collection was none. This collection now has $48,750.50
in cost burden. The adjustment in burden hours and cost burden is due to an increase in
the number of FEMA forms 81-78 submitted along with applications form National
Flood Insurance Program policies. This adjustment is also due to the cost burden not
being captured in the previous submission of this collection.
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.
This collection of information will not have any published results.
17. If seeking approval to not display the expiration date for OMB approval of
the information collection, explain reasons that display would be inappropriate.
This collection is not seeking approval to not display the expiration date for an OMB
approval. 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-I.
This collection does not seek exception to the certification statement referenced above.

B. Collections of Information Employing Statistical Methods.
When Item 17 on the Form OMB 83-I is checked “Yes”, the following documentation
should be included in the Supporting Statement to the extent it applies to the methods
proposed:
THERE IS NO STATISTICAL METHODOLOGY INVOLVED IN THIS
COLLECTION.

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