supporting_statement

The Supporting Statement for OMB 0596-0080

Volunteer Application for Natural Resource Agencies

May 2007

The Supporting Statement for OMB 0596-0080

Volunteer Application for Natural Resource Agencies

May 2007

A. Justification

1. Explain the circumstances that make the col­lection of information necessary. 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.

Laws, Statutes and Regulations

• Public Law 92-300: Volunteers in the National Forest Act of 1972

• 16 USC 558 a-d – Volunteers in the National Forests Program

• 16 USC 583j-4 – Forest Foundation Volunteers

• 16 USC 1246 – Administration and development of national trails system

• 16 USC 1250 – Volunteer trails assistance

• 31 USC 3325 – Authorizes payment of vouchers

Participating Agencies

• USDA Forest Service (FS)

• Department of the Interior: National Park Service (NPS), Fish and Wildlife Service (FWS), Bureau of Land Management (BLM), Bureau of Reclamation (BR), and U.S. Geological Survey (USGS)

• Department of Defense – U.S. Army Corps of Engineers

Federal land management agencies have authorization to use volunteers and volunteer organizations to plan, develop, maintain, and manage, where appropriate, trails throughout the Nation. Agencies may recruit, train, and accept the services of volunteers to aid in interpretive functions, visitor services, conservation measures and development, or other activities in areas. While using volunteers is encouraged, such use must be efficient, effective, and cost-beneficial.

To create a pool of volunteers and allow for security and other screening checks, it is necessary to know the names, addresses, and certain information about individuals who are interested in serving the public as volunteers. Additionally, in order to reimburse volunteers for incurred expenses (transportation, uniforms, lodging, and subsistence) relating to volunteer activities, specific information (including social security number) is necessary.

Except as specifically designated below, a volunteer is not considered a Federal employee and is not subject to provisions of law relating to Federal employment, including those relating to hours of work, rates of compensation, leave, unemployment compensation, and Federal employee benefits. A volunteer is a Federal employee in the following circumstances:

• For the purpose of tort claim provisions¹

• Relating to compensation to Federal employees for work injuries²

• For the purposes of claims relating to damage to, or loss of, personal property of a volunteer during volunteer service

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.

1. What information will be collected - reported or recorded? (If there are pieces of information that are especially burdensome in the collection, a specific explanation should be provided.)

Table 1: Itemized Listing of Forms and Information Collected

Form Number and Name	Information Collected
	Volunteer’s Name	Contact and Emergency Notification Information	Consent of Parent/Guardian	Social Security Number	Expenses (for reimbursement)	Hours volunteered	Areas of Interest	Physical Limitations	Qualifications/Experience	Gender and Age (optional)	Ethnicity (optional)	Medical Insurance Information	Visa Information
All Participating Agencies
OF-301: Volunteer Application for Natural Resource Agencies	X	X					X	X	X
OF-NEW: Agreement for Volunteer Services	X	X	X	X						X	X
Forms Specific to the Forest Service
FS-1800-25: Volunteer Timesheet	X					X
FS-1800-24: Volunteers Annual Report	X					X				X	X
FS-6500-229: Request for Reimbursement Worksheet	X	X		X	X
FS-1800-6: Agreement for Sponsored International Voluntary Services	X	X	X				X		X			X	X
FS-1800-7: Agreement for Individual Volunteer Services	X	X	X
FS-1800-7 (PNW-94): Agreement for Individual Volunteer Services3	X	X	X							X	X
FS-1800-8: Agreement for Sponsored Volunteer Services	X	X	X				X
Forms Specific to U.S. Fish and Wildlife Service
SF-1164: Claim for Miscellaneous Expenses	X	X		X	X
Forms Specific to U.S. Geological Survey
Form 9-2080: USGS Individual Volunteer Agreement	X	X	X
Forms Specific to National Park Service
Form 10-67: Volunteer Claim for Reimbursement	X	X		X	X

2. From whom will the information be collected? If there are different respondent categories (e.g., loan applicant versus a bank versus an appraiser), each should be described along with the type of collection activity that applies.

The information collected from potential and selected volunteers of all ages. Those under 18 years of age must have written consent from parent or guardian.

3. What will this information be used for - provide ALL uses?

Participating natural resource agencies will use this information to manage agency volunteer programs. Specifically:

• Applications used to select and assign volunteers to appropriate activities.

• Agreements set forth the details of volunteer assignments and outline the responsibilities of participating individuals and agencies.

• Claims and reimbursement forms provide information necessary to reimburse volunteers for miscellaneous expenses.

• Timesheets allow for the collection of information regarding hours worked on specific areas and projects by specific volunteers.

• Reports are used to collect information on volunteers for use in preparing annual reports.

4. How will the information be collected (e.g., forms, non-forms, electronically, face-to-face, over the phone, over the Internet)? Does the respondent have multiple options for providing the information? If so, what are they?

The information is collected using forms listed on Table 1 above. Most of the forms may be completed electronically or by hand. All forms must be submitted in hardcopy with original signature as indicated.

5. How frequently will the information be collected?

Information on applications, agreements, and reports collected from each applicant or participant for each volunteer assignment. Most volunteers participate in one volunteer activity per year.

Information on timesheets and expense vouchers collected as needed from each applicant for each volunteer assignment in which they participate (usually more than one time during a volunteer assignment).

6. Will the information be shared with any other organizations inside or outside USDA or the government?

General non-identifying information shared in reports of participating agencies volunteer programs. This information provided to Congress and the public in reports. No information regarding individuals shared.

7. If this is an ongoing collection, how have the collection requirements changed over time?

Efforts made to standardize forms and requirements, though participating agencies’ differences preclude complete standardization. This package covers both types of forms. There is some overlap, due to the necessity of including agency specific forms while awaiting GSA approval for standardized forms. Participating agencies may have different fiscal requirements (reporting and contractual) that preclude standardization.

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.

Most of the forms that are included in this package will be available as e-forms. Due to the requirement for original signatures, these forms must be printed, signed, and submitted in hardcopy.

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.

The standardized volunteer application (OF-301) is available for use by all natural resource agencies. In addition, where necessary, agencies have included agency-specific forms for agreements, reimbursement of expenses, parental/guardian approval, medical insurance information, and similar items. Though more than one form may collect the same type of information, the participating agencies have different missions, mandates, and regulations that necessitate use of different forms. Since the agency specific forms are not available to individuals volunteering for other agencies, there is no confusion as to which forms to fill out for each agency.

Upon OMB approval, forms OF-301 and OF-New to be submitted for posting on the GSA forms web page, as well as the national forms web site. OF-301 streamlines cumbersome systems for referral between agencies. OF-New will provide a generic volunteer agreement format for all participating agencies. Agencies may opt not to use OF-New due to specific fiscal and legal requirements.

5. If the collection of information im­pacts small businesses or other small entities, describe any methods used to mini­mize burden.

This information collection has no impact on small businesses. Any impact on other small entities would be restricted to sponsored volunteer groups and the burden on these groups minimized as the information collected is the minimal necessary for program participation.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is con­ducted less fre­quent­ly, as well as any technical or legal obstacles to reducing burden.

If the information is not collected, participating natural resource agencies will be unable to recruit and/or screen volunteer applicants or administer/run volunteer programs. Less frequent collection of the information will preclude participating agencies from maintaining accurate lists of potential volunteers, who are crucial to assisting these agencies in fulfilling their missions.

6. Explain any special circumstances that would cause an information collecti­on to be con­ducted in a manner:

• Requiring respondents to report informa­tion to the agency more often than quarterly;

• Requiring respondents to prepare a writ­ten response to a collection of infor­ma­tion in fewer than 30 days after receipt of it;

• Requiring respondents to submit more than an original and two copies of any docu­ment;

• Requiring respondents to retain re­cords, other than health, medical, governm­ent contract, grant-in-aid, or tax records for more than three years;

• 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;

• Requiring the use of a statis­tical data classi­fication that has not been re­vie­wed and approved by OMB;

• 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; or

• 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 special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.6.

6. If applicable, provide a copy and iden­tify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), 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.

The Federal Register 60-day Notice for this information collection was published on March 28, 2007 (FR Vol. 72, 14515). One comment was received, from b.sachau on March 28, 2007:

“OMB 0596-0080 – extend time to comment [.] [T]he form should contain a line where the alleged “volunteer” clearly indicates whether he has this year or last year taken anything of value, including money, gifts, etc[.] from anyone in connection with this “volunteering”. [T]here is much corruption going around. [W]e need to make sure the volunteers arent [sic] stealing the place blind.”

The Forest Service did not respond to this comment. Period for accepting comments was not extended and no additional comments from this individual were received prior to the comment period closing on May 29, 2007.

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 record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years even if the col­lection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

Of the eight volunteers proponents attempted to contact, four provided comments. The comments are summarized below.

• Linda R., Springfield, VA: She found it easy to volunteer and the forms were not difficult. She became aware of volunteer opportunities through organizational affiliation and previous employment, and did not have to go through a selection process. Only suggestion for improvement in program is that sponsors should provide volunteers with information on all commuting options, including agency shuttle services.

• Steve K., Springfield, VA: He indicated that the process and forms were easy. Has enjoyed his volunteer experiences. He did not have to go through a selection process.

• John M., Missoula, MT: Application process is not difficult or time consuming. He did not have to go through a selection process, as he knew where his skills were needed due to previous employment. He stated that the public did not seem to know about volunteer opportunities, that members of the public had to have some prior knowledge of an agency to be aware of volunteer opportunities. He mentioned that most universities with natural resource programs require students to intern in their field of study and that many fulfill this requirement by volunteering with natural resource agencies.

• Roland E., Vancouver, WA: He has been a volunteer since retiring from Federal service in the 1990s. He has had no difficulty in signing-up, though indicated that being a long-time Federal employee probably facilitates the process. The forms present no problem. He has no particular problem with the application/selection process other than in some cases feels Federal agencies consider volunteers a “free lunch”…he considers himself relatively low maintenance, so this is not an issue for him, but that it might be an issue for others. He stated that volunteers need to be fed, nurtured, and rewarded to a greater extent than permanent full-time employees and this may make the application and selection process more attractive.

Participating Agencies and Contact Information

The following individuals represent the agencies currently participating (or who have participated in the past) as proponents of this information collection. These agencies are members of the Natural Resource Volunteers Committee and were contacted to obtain their views on availability of data; frequency of collection; the clarity of instructions and record keeping; disclosure or reporting format; and data elements to be recorded, disclosed, or reported.

Several of the participating agencies use Optional Form 301 (Volunteer Application). A new optional form is part of this information collection renewal and is entitled Volunteer Agreement. This is part of an effort by participating agencies to adopt standardized forms, though participating agencies prefer that use of such forms be optional to allow for agencies’ different legal and programmatic requirements.

Agency	Contact Information
USDA - FS	Bridget Harris, 703-605-4847, [email protected]
National Park Service	Joy Pietschmann, 202-513-7141, [email protected]
National Resources Conservation Service	Michele Eginoire, (515) 289-0325, [email protected]
Army Corps of Engineers	Debra Stokes, (202) 761-1736, [email protected]
Fish and Wildlife Service	Deborah Moore, (703) 358-2386, [email protected]
Bureau of Reclamation	Sheila Venson, (303) 445-2662, [email protected]
US Geological Survey	Sue Padgett, (703) 648-7450, [email protected]
USDA - CREES	Vacant - (202) 720-3566
Bureau of Land Management	Mary Tisdale, (202)-452-3065, [email protected] Carolyn Cohen, (202) 785-6583, [email protected]

6. Explain any decision to provide any payment or gift to respondents, other than re-enumeration of contractors or grantees.

When applicable, and allowed by agency regulations, volunteers receive per diem and reimbursement for incidental expenses. Agencies may have regulations that allow granting of monetary or non-monetary awards for volunteer service.

6. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Privacy Act System of Records OPM/GOVT-1 covers the collection of this information. This system of records was last published in the Federal Register on June 19, 2006, pages 35342-35347, Vol. 71. In addition, Privacy Act System of Records USDA/OP-1 covers Department of Agriculture records (Forest Service, et al); this system of records was last published in the Federal Register on January 28, 1998, page 4213, Vol. 63.

6. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or 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 of a sensitive nature. Some of the forms have questions regarding gender, ethnicity, and disability. These questions are to determine demographics of participants for reporting purposes (gender and ethnicity) or to determine basic physical ability for volunteer activities.

6. Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form.

a) Description of the collection activity

b) Corresponding form number (if applicable)

c) Number of respondents

d) Number of responses annually per respondent,

e) Total annual responses (columns c x d)

f) Estimated hours per response

g) Total annual burden hours (columns e x f)

Table 2 – Burden Hour Calculations

(a) Description of the Collection Activity			(b) Form Number	(c) Number of Respondents	(d) Number of responses annually per Respondent	(e) Total annual responses (c x d)	(f) Estimate of Burden Hours per response	(g) Total Annual Burden Hours (e x f)
ALL Volunteer Application for Natural Resource Agencies			OF-301	400,000	1	400,000	15 minutes (.25 hrs)	100,000
Select 1	ALL Agreement for Volunteer Services	Select 1	OF-NEW		1	400,000	15 minutes (.25 hrs)	100,000
	FS - Agreement for Individual Volunteer Services		FS-1800-7
	FS - Agreement for Sponsored Volunteer Services		FS-1800-8 & FS-1800-8 (PNW-94)
	FS - Agreement for Sponsored International Voluntary Services		FS-1800-6
	USGS - Individual Volunteer Agreement		Form 9-2080
FS - Volunteer Timesheet			FS-1800-25		1	400,000	15 minutes (.25 hrs)	100,000
FS - Volunteers Annual Report			FS-1800-24		1	400,000	15 minutes (.25 hrs)	100,000
Select 1	FS - Volunteers Request for Reimbursement Worksheet	Select 1	FS-6500-229		1	400,000	15 minutes (.25 hrs)	100,000
	FWS - Claim for Misc. Expenses		SF-1164
	NPS - Volunteer Claim for Reimbursement		Form 10-67
	Totals		---	400,000	---	2,000,000	---	500,000 burden hours

Record keeping burden should be addressed separately and should include columns for:

a) Description of record keeping activity: None

b) Number of record keepers: None

c) Annual hours per record keeper: None

d) Total annual record keeping hours (columns b x c): Zero

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

Table 3

(a) Description of the Collection Activity	(b) Estimated Total Annual Burden on Respondents (Hours)	(c) Estimated Average Income per Hour	(d) Estimated Cost to Respondents
Completion of forms	500,000 hours	$17.27*	$8,635,000

*Based on average weekly salary from Department of Labor, Bureau of Labor Statistics for 2007 (http://www.bls.gov/news.release/archives/realer_06152007.pdf)

6. Provide estimates of the total annual cost burden to respondents or record keepers resulting from the collection of information, (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) a total capital and start-up cost component annualized over its expected useful life, and (b) a total operation and maintenance and purchase of services component.

There are no capital operation and maintenance costs.

6. Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

The response to this question covers the actual costs the agency will incur as a result of implementing the information collection. The estimate should cover the entire life cycle of the collection and include costs, if applicable, for:

• Employee labor and materials for developing, printing, storing forms

• Employee labor and materials for developing computer systems, screens, or reports to support the collection

• Employee travel costs

• Cost of contractor services or other reimbursements to individuals or organizations assisting in the collection of information

• Employee labor and materials for collecting the information

• Employee labor and materials for analyzing, evaluating, summarizing, and/or reporting on the collected information

Administrative cost to the Federal Government estimated to be $8,820,000^ for

• Preparation of work plans

• Employee labor (collection, review, and processing of applications and other forms associated with this information collection)

• Reimbursement of volunteers expenses and per diem (when applicable)

This is based on an average of 15 minutes per activity, done by a GS-7/step 1 employee (cost to government approximately $17.64/per hour) multiplied by 2,000,000 tasks (forms).

6. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of OMB form 83-I.

The estimated burden hours and number of responses have increased dramatically. In 2004, the burden hours were 14,525 and number of responses 58,100. This information collection requests estimates 500,000 burden hours and 2,000,000 responses. This is an increase of 485,475 burden hours and 1,941,900 responses (400,000 respondents).

There are a number of reasons for this dramatic increase.

• Awareness of volunteer opportunities with natural resource agencies has increased. Three factors have contributed to the increase in volunteers:

• Agency retiree organizations

• University internship requirements for natural resource degrees and the decrease in available temporary positions (due to budget cuts)

• The Volunteer Internet site http://www.volunteer.gov/gov/index.cfm

• Agencies are continuing to improve procedures for determining total number of volunteers, though additional improvements to capture and track total number of volunteers annually are needed.

• Forms for tracking time, documenting agreements, and reimbursing volunteers for incidental expenses are now included in the total response count. Previously these forms were omitted from total response count. Many participating agencies were under the mistaken impression that once a volunteer signed-up said volunteer was a pseudo-Federal employee and therefore Paperwork Reduction Act regulations did not apply. This issue has been clarified for all participating agencies.

6. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

Other than inclusion in general agency reports, there were no reported plans for publishing or tabulation of volunteer information.

6. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

The OMB expiration date will be displayed on all forms listed in this information collection request.

6. Explain each exception to the certification statement identified in item 19, "Certification Requirement for Paperwork Reduction Act."

There are no exceptions to the certification statement identified on Form FS-1300-25, Part V "Certification Requirement for Paperwork Reduction Act."

B. Collections of Information Employing Statistical Methods

This information collection does not employ statistical methods.

1 Title 28

2 For the purposes of subchapter I of chapter 81 of title 5, within the meaning of the term ‘employee’ as defined in section 8101 of title 5?

3 Used by USDA Forest Service, Pacific Northwest Region

 http://www.opm.gov/oca/07tables/index.asp (2007)

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