Supp. Stat. PRA Apr--Jun 07 A. Flynt

June 21,2007

Supporting Statement for
Paperwork Reduction Act Submissions
OMB Control Number: 1660 - 0037
Title: Application Form for Single Residential Lot or Structure
Amendments to National Flood Insurance Program Maps
Form Number(s): FEMA Forms 81-92 and 81-92A
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.

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 Department of Homeland Security's Federal Emergency Management Agency
(FEMA) administers the National Flood Insurance Program (NFIP) and maintains the
maps that depict flood hazard information. The NFIP regulations Section 44 CFR 65 and
70 (copy attached) outline the data that must be submitted by an owner or lessee of
property who believes hisher property has been incorrectly included in a Special Flood
Hazard Area (SFHA). In order to remove an area from a SFHA, the owner or lessee of
the property must submit scientific or technical data demonstrating that the area is
"reasonably safe from flooding" and not in the SFHA.

The forms supplement the general information requirements in the NFIP regulations and
establish an organized, systematic approach to collect data needed to request removal
from a SFHA in a manner that will:
Ensure all data required to process such a request is received with the initial
submittal;
Ensure processing consistency between all processing partners;
Ensure that submitted data are presented in a manner that will increase processing
efficiency;
Reduce the amount of time required to process requests; and
Reduce processing costs.
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:
how the information will be shared, if applicable, and for what programmatic
purpose.
FEMA collects scientific and technical data submissions to determine whether a specific,
single-lot property is located within or outside of a SFHA. FEMA provides the appellant
with a written determination as to hidher decision. If the property is determined not to be
within a SFHA, the appropriate map is modified by a Letter of Map Amendment
(LOMA). The owner or lessee of a property uses a LOMA to show that a property is not
flood prone, making it possible for the lending institution to waive the flood insurance
requirement. If insurance is camed for the property, the new determination should result
in significantly lower rates.
FEMA processed requests from approximately 26,400 respondents to this collection in
FY 2006. Processing of theses requests helps to improve the accuracy of FEMA map
products, and therefore, the effectiveness of the National Flood Insurance Program.
FEMA Form 81-92, Application Form for Single Residential Lot or Structure
Amendments to National Flood Insurance Proaam Maps, is a simplified version of the
MT-1 FEMA Form 81-87, Property Information. This simplified form allows the owner
or lessee of a single lot or structure to more easily understand and prepare the data
required to determine if the single lot or structure is located in the SFHA. The form
describes the location of the property, what is being requested, and what data are required
to support the request.
In addition to this form, a Spanish-language version of the form, FEMA Form 8 1-92A,
Formulario Para Solicitar Modificaciones a Mapas del Programa Nacional de Sewras
Contra Inundaciones Para un Lote o Estructura Residencial Individual, has been prepared
and will be produced. The form, intended to assist requesters who understand Spanish
better than English, is simply Spanish translation of the revised FEMA Form 81-92,
described above.

In addition to these forms, requests must include the following:
A copy of the Plat Map for the property (with recordation data and stamp of the
Recorder's Office) OR
A copy of the property deed (with recordation data and stamp of the Recorder's
Office), accompanied by a tax assessor's map or other certified map showing the
surveyed location of the property relative to the local streets and watercourses
Copy of the effective FIRM panel and/or Flood Boundary and Floodway Map
(FBFM) (if applicable) on which the property location has been accurately
plotted.

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 forms (8 1-92 and 8 1-92A) are available on the Internet and can be downloaded from
the website. The forms can be found at the following website address:
http://www.fema.~ov/plaidprevent~flddl
mt-ez.shtm. The forms are provided in
Adobe@ Acrobat@ PDF format and as Microsoft Word WinZip archives. Users are able
to download the files and print completed forms manually and mail them to FEMA. The
forms are also available in FEMA's electronic forms system, DocNet located at
http://docnet.ferna.~ov.
The software for DocNet must be downloaded before accessing
the system. Currently, there is no method for submitting completed forms online.
Depending on the availability of finding fiom the federal government and the priority
given to this collection, FEMA may develop the capability for users to return completed
forms electronically over the Internet.
Effective Flood Insurance Rate Maps (FIRM), Flood Boundary and Floodway Maps
(FBFM), and Flood Insurance Study (FIS) reports that cover the area in which a
particular property is located can be obtained fiom the Map Service Center (MSC) on the
FEMA website at htt~://store.msc.fenla.pov.Those that do not have internet access can
contact the Map Service Center at 800-358-9616.
Requestors can check on the status of their Letter of Map Amendment (LOMA) request
by visiting FEMA's Mapping Information Platform website at htt~s:/hazards.fema.aov.
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 duplicative efforts. Detailed information on specific property locations
within communities, nationwide, is not collected or maintained except at the community
level because of the prohibitive costs associated with such an effort. While community
officials may maintain such information, as required by 44 CFR §59.22(a), this data is
not readily accessible by FEMA and thus must be provided for verification purposes. If
available, however, property owners or lessees may use this data in preparing their
submissions.
Usually, the submissions take the form of providing copies of existing information such
as recorded deeds and plat maps from which FEMA can determine the location of the
property relative to the mapped flood boundaries as depicted by the SFHA. Topographic
or elevation data, when it is available, is also used in its available format.

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 of information will have the same impact on small businesses or other
small entities as all other respondents.
6. Describe the consequence to FederaVFEMA 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 the collection of information were not conducted, it would deprive individuals of the
right to provide scientific or technical data to correct flood insurance maps that may be in
error. The impact of this deprivation is difficult to assess, but it would, in all probability,
adversely affect community participation in the NFIP, which is voluntary. If this
information were not collected, the majority of respondents to this collection would
continue to pay higher flood insurance premiums than would be necessary if they were to
get a determination showing that their property was no longer in a Special Flood Hazard
Area. If this were the case, local pressures would likely mount and cause a significant
number of communities to reevaluate their decisions to continue their participation in the
NFIP. Without this collection of information there would also be increased costs for
mapping, since these requests would require physical revisions to the Flood Insurance
Rate Maps.
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 special circumstances for this collection that would require 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.
Under no circumstances are respondents required to prepare a written response to the
collection of information in fewer than 30 days after receipt of it.

(c) Requiring respondents to submit more than an original and two copies of
any documen t.
Respondents are only required to submit one copy of all documents.

(d) Requiring respondents to retain records, other than health, medical,
government contract, grant-in-aid, or tax records for more than three years.
Respondents are not required to retain any records pertaining to this collection.

(e) I n 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 is not used in statistical surveys not designed to produce valid and reliable
results that can be generalized to the universe of study.
(f) Requiring the use of a statistical data classification that has not been
reviewed and approved by OMB.

This collection does not require the use of a 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.
This collection does not include any pledges of confidentiality.

(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.
This collection does not require respondents to submit confidential information.
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
instituted procedures to protect t h e information's confidentiality t o
the extent permitted by law.
5

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 OkIB. 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 sixty-day Federal Register Notice was published for comments on April 20,
2007, volume 72, number 76, pages 19942-19943. Comments were received on
June 22,2007 from a Mr. George F. Meyers, Co-Chair for the Association of
State Flood Plain Managers, Inc.of Madison, Wisconsin.
DHSIFEMA's Mitigation Division, Risk Analysis Branch is responding to
Mr. Meyers and the Floodplain Regulations Coninlittee conlinents on FEMA
Forms 8 1-92, Application Form for Single Residential Lot or Structure
Amendments to National Flood Insurance Program Maps; and Form 81-92A the
Spanish version.. Their comments focused on such things as the use of fill and its
definition, elevation of the lowest floor of a structure, page numbering, basis of
determination, state requirements on the use of licensed land surveyors and
registered professional engineers, and lowest lot elevation.
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.
In preparation of the forms and instructions, FEMA's Contractor, the National Service
Provider was consulted regarding changes to the forms and instructions. No major
changes to the forms and instructions are being implemented.
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.
By the nature of the information collection activity, itself, consultation with those from
whom information is to be obtained is continuous. These consultations are conducted on
a daily basis by FEMA's Contractor, the National Service Provider. When requests are
received from respondents (homeowners, surveyors, and engineers), comments are often
included regarding the forms and instructions. The majority of the comments involve the
clarity of instructions. In addition, FEMA's website
(http://www.fema.gov/plan/prevent/fhm/tsd einap.shtm) includes an email address, in
which respondents can provide comments regarding the forms and clarity of instructions.

9. Explain any decision to provide any payment or gift to respondents, other than

remuneration of contractors or grantees.
There will be no payments or gifts provided to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis
for the assurance in statute, regulation, or agency policy.
This collection does not involve privacy act information.
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 of a sensitive nature required for this collection of information.

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, o r 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.
Based on historical records, it is anticipated that FEMA will receive at least 26,400
responses to this collection per year. The estimated number of burden hours per response
to submit all forms in this applicationlcertification package has been determined to be 2.4
hours. Frequency of response for the FEMA Forms will be annual. Burden hours per
respondent vary as displayed in the chart under 12c.
The total number of respondents is presented as an estimate of the respondents
completing either FEMA Form 8 1-92 or FEMA Form 81-92A in a given year. FEMA
Form 8 1-92A is a Spanish version of FEMA Form 81-92 and, as such, only one of the
two forms would be required for any one application. In order to determine the
approximate breakdown of respondents listed below for each form, it was assumed that
12.5% of respondents, the percentage of U.S. citizens that consider themselves to be in
whole or in part Hispanic or Latino as per the 2000 Census, would use FEMA Form 8192A. This number might be further refined once updated Census data becomes available.
Based on this percentage, it is estimated that of the 26,400 annual responses received,
3,300 could require use of FEMA Form 8 1-92A (Spanish Version).
Homeowners are the primary public affected by this forms collection. This is because
homeowners are those who initiate completion and submission of the forms collection.
However, due to certification and other technical requirements, completion of the forms
collection requires participation by a second category of "affected public." This category
includes business or other for-profit organizations. The estimates provided are based on
the assumption that the burden involved with completing this forms collection will
typically be split evenly between these two categories of "affected public."

!

The number of respondents varies from year to year as the Federal government has no
control over the number of individuals who, acting on their own initiative, seek to have
determinations made for their properties. There are wide differences in the complexity
and size of individual data submissions.
Table 1. Annual Hour Burden
Data Colledlon
Activltyllnstrument

No. of
Respondents

Frequency
of
Responses

Burden
Response
Per

Annual
Responses

(A)

(B)

(C)

(D) = (AXE)

Hour

Total
Annual
Hour
Burden
(E) = (CxD)

Form 81-92:
I

1

1

Homeowners
Engineers, Surveyors
Form 81-92A
(Spanish Version):
Homeowners
Engineers, Surveyors

TOTAL

I

1

1.2

11,550

1

1.2

I

I
1,650
1,650

26,400

I
1
1

I

I

I

11,550

11,550
11,550

I
1.2
1.2

1

13,860
13,860

I
1,650

I

1,650

1,980
1,980

26,400

3 1,680

FEMA Form 81-92 is estimated to be 27,720 total annual burden hours and FEMA Form
81-92A is estimated to be 3,960 total annual burden hours. The burden hours per
response is estimated to be 2.4. This includes 1.2 burden hours per response for
homeowners which includes gathering other existing data such as a copy of the Plat Map
for the property, a copy of the deed for the property accompanied by a copy of the tax
assessor's map (or other suitable map) for the property, and a photocopy of the effective
FIRM panel (including title block) that shows the area in which the property is located,
and 1.2 burden hours per response for engineers and surveyors which includes surveying
the subject properties before completing the elevation section of the form. Once the
forms are completed, they are certified by the surveyor/engineer and signed by the
homeowner.
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.
This collection covers one form; however there is an English (81-92) and Spanish (8 192A) version of the 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 13.

I

Table 2. Annual Cost to Respondents for Hour Burden.
I

Data Collection
Activityllnstrument

Form 81-92,81-92A
Form 81-92,81-92A
Form 81-92,81-92A
TOTAL

I

I

Respondent's
Occupational
Category

Homeowner
Surveyor
Engineer

($1

(F)

from Table1

$14.15
$22.05
$31.82

15,840
11,088*
4,752*

Median Wage

I

I

Total Annual
Hour Burden
(hour)

(El,

Total Annual
Cost Burden

($1

-.

(G)

= (FxE)

$224,136
$244,490
$151,209
$619,835
*These figures represent the percentage of Total Annual Hour Burden split between Surveyors and Engineers The
total of each percentage equals the Total Annual Hour Burden listed in Table 1 (15,840). Please see narrative below for
further explanation.

The burden assumed by the homeowner to complete this form collection is based on
average annual pay figures for the United States in 2005. According to the United States
Department of Labor, Bureau of Labor Statistics, the average annual salary in the United
States in 2005 was $37,870. The median hourly wage rate was $14.15. This figure was
used to determine the annual cost to homeowners. The total annual hour burden for
homeowners (15,840) was multiplied by the median hour rate for homeowners ($14.15)
to arrive at a total annual cost of $224,136 for homeowners.
The burden assumed by the business or other for-profit organizations to complete this
form collections is baskd on the average annual
figures for these professions
(surveyors and engineers), according to the United States Department of Labor, Bureau
of Labor Statistics. The median hourly wage rate for a surveyor in 2005 was $22.05, and
for an engineer was $3 1.82. Historical data indicates that approximately seventy percent
(70%) of the elevation section of the forms are completed by surveyors and
approximately thirty percent (30%) are completed by engineers. Therefore, the
percentage of total annual hour burden for surveyors (1 1,088) and engineers (4,752) was
multiplied by the median hour rate for surveyors ($22.05) and engineers ($3 1.82) to
arrive at a total annual cost of $244,490 for surveyors and $15 1,209 for engineers.

pay

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 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:
The cost estimates should be split into two components:
a. Operation and Maintenance and purchase of services component. These
estimates should take into account cost associated with generating,
maintaining, and disclosing o r 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@), and the time period over which costs will be incurred.

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 start-up, capital, operational, or maintenance costs for this collection.

Annual Cost Burden to Respondents or Record-keepers
Data
Collection
Actlvityllnstr
ument

*Annual Capital
Sm-up

(Investmentsin
overheact, equipment
and other one-time
expenditures)

.Annual Operations
and Mdntenanw Cost
(such as recordkewhJ.
echnlcaUpmfesslmal
services, ect.)

Annual NonLabor Cost
(e,ndlblms
on
training, travel and
other resources)

Total Annual
Cost to
Respondents
I

N/ A

Total

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.
Annual Cost to the Federal Government
Contract Costs

Cost ($1
$93,500

Staff Salaries (1 GS12 ($29.81/per hour) x 312 hours)

$9,300

Item

1
I

Facilities
Computer Hardware and Software
Equipment Maintenance
Travel
Printing
Postage
Other
Total

$7,000
$11,700
$121,500

The contractor costs are estimated to.be $93,500. This cost includes call center staff
responding to an average of 16,000 calls per year that pertain to this collection. Most of
these calls are from respondents who require assistance with completing the forms and
interpretation of the instructions. Based on historical call center data, calls pertaining to
the forms lasts an average of 6 minutes. Based on an average loaded rate of $55.00 per
hour, the contractor costs for responding to these calls is $88,000. The contract costs

associated with completing and submitting required documents for this collection is
estimated to be $5,500. This includes 100 hours and is based on an average loaded rate
of $55.00 per hour.
Staff salary cost is estimated to be $9,300. This cost includes one GS12 government
employee, with an hourly rate of $29.81, dedicating fifteen percent of their time to the
coordination, completion, and final submission of this collection.
The cost for printing 30,000 copies of the forms and instructions is estimated to be
$7,000.
The postage cost for mailing 30,000 forms and instructions is estimated to be $1 1,700
based on a postage cost of 0.39 cents per mailing.

15. Explain the reasons for any program changes or adjustments reported in Items
13 or 14 of the OMB Form 83-1 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.
The annualized cost to respondents decreased from $686,162 to $619,835, representing a
decrease of $66,327. This decrease is due to adjustments in the median hourly rates for
homeowners and engineers and surveyors, and incorrect burden hours used in the
previous collection to calculate the costs for engineers and surveyors.

1 Data Collection Activltyllnstrument
1 None

I Total

I

1

Program Changes
(hours)

-$66,327 1

During September of 2005, the nation was impacted by Humcane Katrina. The Terms of
Clearance for this collection required an evaluation of the impact, if any, to this forms
collection. There have been no regulatory or statutory changes that have affected this
collection and consequently no changes in burden hours or annual responses.

As a lesson learned, FEMA now includes the NFP and Levees Fact Sheet with all final
determinations issued for properties in areas protected by levees. This Fact Sheet
contains additional information concerning risks associated with levees, flood insurance
and mitigation of flood risks in areas protected by levees.
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.

The results of information collections will be made in accordance with NFIP regulations
44 CFR Parts 65 and 70 and will not be published for statistical use.
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.

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 83-1 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.