1660-0016 Supporting Statement

August 16th, 2007

Supporting Statement for
Paperwork Reduction Act Submissions
OMB Control Number: 1660 - 0016
Title: Revision to National Flood Insurance Program Maps: Application Forms
for LOMRs and CLOMRs
Form Number(s): FEMA Form 81-89 Series, which includes Forms 81-89, 8189A, 81-89B, 81-89C, 81-89D, and 81-89E.

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.
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, Federal Emergency Management Agency
(FEMA) administers the National Flood Insurance Program (NFIP) and maintains
the maps that depict flood hazard information. In 44 CFR Part 65, FEMA
specifically requests that communities submit technical information concerning flood
hazards and plans to avoid potential flood hazards. In order to revise the Base (lpercent annual chance) Flood Elevations (BFEs), Special Flood Hazard Areas
(SFHAs), and/or floodways presented on the NFIP maps, a community must submit
scientific or technical data demonstrating the need for a revision. The NFIP
regulations cited in 44 CFR Part 65 outline the data that must be submitted for these
requests. This collection serves to provide a standard format for the general

1

information requirements outlined in the NFIP regulations and helps establish an
organized package of the data needed to revise NFIP maps. This collection helps to:
•
•
•
•
•

Ensure all data required to process these requests is received with the initial
submittal;
Ensure processing consistency among all requests;
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.
The information collected on FEMA Forms 81-89, 81-89A, 81-89B, 81-89C, 81-89D,
and 81-89E is used to determine if such data will result in a modification of a BFE,
SFHA, and/or floodway. Once the information is collected, it is submitted to FEMA for
review and is subsequently included on the NFIP maps. These maps are used by
communities for compliance with floodplain management regulations, by lenders in
determining application of the mandatory flood insurance purchase requirement, and by
insurance agents in determining actuarial flood insurance rates.
This collection uses a series of six forms, described below:
a. FEMA Form 81-89, Overview and Concurrence Form provides the basic
information regarding the revision request and requires the signatures of the
requester, community official and engineer. This form is required for all
revision requests. This form describes the location and nature of the requested
NFIP map change, and the data required to support the request.
b. FEMA Form 81-89A, Riverine Hydrology & Hydraulics Form provides the
basic information on the scope and methodology of hydrologic and/or hydraulic
analyses that are prepared in support of the revision request. This form should be
used for revision requests that involve new or revised hydrologic and/or
hydraulic analyses of rivers, streams, ponds, or small lakes.
c. FEMA Form 8l-89B. Riverine Structures Form provides the basic information
regarding hydraulic structures constructed in the stream channel or floodplain.
This form should be used for revision requests that involve new or proposed
channelization, bridges/culverts, dams, and/or levees/floodwalls.
d. FEMA Form 81-89C, Coastal Analvsis Form provides the basic information
on the scope and methodology of coastal analyses that are prepared in support
2

of the revision request. This form should be used for any revision requests
that involve new or revised coastal analyses.

e. FEMA Form 81-89D, Coastal Structures Form provides the basic information
regarding hydraulic structures constructed along the coast. This form should
be used for revision requests that involve new or proposed levees/dikes,
breakwaters, bulkheads, seawalls, and lor revetments located along the coast.
f. FEMA Form 81-89E. Alluvial Fan Flooding Form provides the basic
information for analyses of alluvial fans. This form should be used for
revision requests involving alluvia fans.
In addition to these forms, requests must include but not limited to the following data:
•

•
•

•

An annotated Flood Insurance Rate Map (FIRM) and/or Flood Boundary
and Floodway Map (FBFM) (if applicable) at the scale of the effective
FIRM and/or FBFM showing the revised base floodplain and floodway
boundaries delineated on the submitted work map and how they tie into
the base floodplain and floodway boundaries shown on the effective
FIRM and/or FBFM at the downstream and upstream ends of the revised
reach.
A diskette containing input and output files for all submitted hydrologic
and/or hydraulic models
A topographic work map certified by professional engineer showing the
revised proposed base floodplain and floodway boundary delineations
and how they tie into the unrevised information.
Evidence of compliance of all applicable NFIP regulations as identified
in the submitted forms.

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 are made available on the Internet and can be downloaded from the website.
The forms can be found at the following website address:
http://www.fema.gov/plan/prevent/fhm/frm_form.shtm. The forms are available on the
internet for download in Microsoft Word and Adobe Acrobat format. Currently, the
collection cannot be submitted to FEMA electronically; users can only print completed
forms and mail them to FEMA. Depending on the availability of funding and the priority
given to this collection, FEMA may develop the capability for users to return the
information electronically.

3

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 from the Map Service Center (MSC) on
the FEMA website at http://store.msc.fema.gov. 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 Revision (LOMR), and
Conditional Letter of Map Revision (CLOMR) request by visiting FEMA's Status of
Map Change Requests database at http://www.fema.gov/plan/prevent/fhm/st_main.shtm.
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 and no other existing collection can be used or
modified to serve these purposes. While the information collected may have been
prepared by other Federal, State, or local agencies or by private firms/individuals, this
information is only available to FEMA as part of this collection. Usually, the
submissions take the form of providing copies of existing information such as
topographic data available from State and/or local government agencies. This data may
be used to refine the Special Flood Hazard Area boundary delineations.
Detailed information on specific 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 are 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.
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 is the same regardless of size of the business or entity responding to
the collection.
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 were not collected, the NFIP maps could not be revised to reflect
current existing flood hazards. Processing of these requests helps to improve the
accuracy of FEMA map products, and the effectiveness of the National Flood Insurance
Program.

4

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 the NFIP maps would not reflect actual risk
associated with flooding and the citizens may risk their life and property during a
disaster.
(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. Respondents
are required by 44 CFR §65.3 to report information within 6 months after the data
is available.
(c) Requiring respondents to submit more than an original and two
copies of any document.
Respondents are not required to submit more than one original document of this
collection.
(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 maintain these records for any period of time.
(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.

5

This collection is not connected with a statistical survey.
(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 a pledge 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.
Respondents are not required to submit proprietary or 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 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 Notice was published for comments on June 20, 2007, volume
72, number 118, pages 34029-34030. No comments received during the 60-day
comment period concerning information required by FEMA to revise NFIP
maps.

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.
FEMA conducts several workshops for community officials, engineers,
6

surveyors, and developers every year on the MT -2 process. While the
purpose this workshop is not to solicit feedback on the forms and
instructions, attendees use the opportunity to give comments and clarity of
instructions. In addition, FEMA's website
http://www.fema.gov/plan/prevent/fhm/tsd_emap.shtm includes an email
address, in which respondents can provide comments regarding the forms and
clarity of instructions. FEMA also provides a toll free number (877-3362627) to answer questions and provide opportunity for respondents to
comment on the forms.
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.
If a community official or other party seeks assistance from FEMA, on the FHBM or
FIRM, that an altered or relocated portion of a watercourse provides protection from, or
mitigates potential hazards of the base flood, FEMA may request specific documentation
from the community certifying and describing how the provisions of flood plain
management criteria will be met for the particular watercourse involved. This
documentation, which may be in the form of a written statement from the Community
Chief Executive Officer, an ordinance, or other legislative action. The statement shall
describe the nature of the maintenance activities to be performed, the frequency with
which they will be performed, and the title of the local community official who will be
responsible for assuring that the maintenance activities are accomplished.

9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
No gifts are provided to respondents.
10. Describe any assurance of confidentiality provided to respondents. Present the
basis for the assurance in statute, regulation, or agency policy.
This collection does not involve privacy act information. The information on the
form consists of documentation and interpretation of public documents. The
information of the collection is publicly available and therefore not confidential,
including community participation status in the National Flood Insurance Program
(NFIP). The NFIP data collection is provided on a voluntary basis.
FEMA does not mandate use of the forms. However, the forms provide assurance
that all pertinent data relating to an individual request are submitted in the collection.
7

11. Provide additional justification for any question 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.
This collection does not include questions of a sensitive nature.
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.
Based on historical records, it is anticipated that FEMA will receive at
least 10,080 responses for this collection. Respondents to this collection
are typically developers, community officials or private engineering firms.
Because of ongoing development in communities, a respondent may
submit multiple responses to request multiple changes to the NFIP maps.
The estimated number of burden hours per respondent to submit all forms
in this collection has been determined to be 14.5 hours.
Table 1. Annual Hour Burden
Data Collection
Activity/Instrument

Form 81-89, Overview
and Concurrence Form
Form 81-89A,
Riverine Hydrology &
Hydraulics Form
Form 81-89B, Riverine
Structures Form
Form 81-89C, Coastal
Analysis Form
Form 81-89D, Coastal
Structures Form

(B)

Hour
Burden Per
Response
(C)

1,680

Annual (1)

1,680

No. of
Respondents
(A)

Frequency of
Responses

Annual
Responses

Total Annual
Hour Burden

(D) = (AxB)

(E) = (CxD)

1.0

1,680

1,680

Annual (1)

3.5

1,680

5,880

1,680

Annual (1)

7.0

1,680

11,760

1,680

Annual (1)

1.0

1,680

1,680

1,680

Annual (1)

1.0

1,680

1,680

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Form 81-89E, Alluvial
Fan Flooding Form
TOTAL

1,680

Annual (1)

1,680*

* The number of respondents equals total number of collection package received.

1.0

1,680

1,680

14.5

10,080

24,360

Estimated number of collection package received

in a given year is 1,680.

The Overview and Concurrence Form is estimated to 1 hour per respondent. This form is
completed by developer’s representatives (typically, engineering firms or land
surveyors). The developer may review forms prepared by their representatives and sign
the form as a requester for the collection. The certifying official should be the Chief
Executive officer (CEO) for the community or an official legally designated by the CEO.
Engineer or Land Surveyor will certify their analysis and supporting data for the request.
The Riverine Hydrology & Hydraulics Form is estimated to take 3.5 hours per
respondent. This form is completed by engineers or land surveyor to do analyses of
rivers, streams, ponds, or small lakes. As identified in the form, community official may
be involved in providing public or individual notifications to impacted property owners
of increased hazards on their property, if applicable. A separate form is used for each
flooding source.
The Riverine Structures Form is estimated to take 7 hours per respondent. This form is
completed by engineers or land surveyors for revision request that involve new or
proposed channelization, bridges/culverts, dams and levees/floodwalls. A separate form
should be used for each flooding source
The Coastal Analysis Form is estimated to take 1 hour per respondent. This form is
completed by developers or their representatives. This information is intended to
document the steps taken by the requester in the process of preparing the revised models
or analyses and the resulting revised Flood Insurance Study (FIS) information. This form
is estimated to taken 1 hour to complete and certify.

9

The Coastal Structures Form is estimated to take 1 hour per respondent. This form is
completed and certified by engineers or land surveyors. While property owners or their
representatives signing this form is not required to have obtained the supporting data or
perform the analyses, they must have supervised and review the work
The Alluvial Fan Flooding Form is estimated to take 1 hour per respondent. A complete
engineer analyses must be submitted in support of each section of this form. In addition,
it may be necessary to complete other forms relating to specific flood control measures,
such as levees/floodwalls, channelization or dams.

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.
See table in 12(a)
c. Provide an estimate of annualized cost to respondents for the hour
burdens for collections of information, identifying and using appropriate
wage rate categories. The cost to the respondents 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.
Annual Cost to Respondents for Hour Burden
Data Collection
Activity/Instrument

Form 81-89, Overview
and Concurrence Form
Form 81-89A, Riverine
Hydrology & Hydraulics
Form
Form 81-89B, Riverine
Structures Form
Form 81-89C, Coastal
Analysis Form
Form 81-89D, Coastal
Structures Form
Form 81-89E, Alluvial
Fan Flooding Form

Median
Wage
($)

Total Annual
Hour Burden
(hour)

Total Annual
Cost Burden
($)

$14.15

420

$5,943

$50.00

420

$21,000

$31.82

840

$26,728

$50.00

1,260

$63,000

$31.82

4,620

$147,008

$31.82

11,760

$374,203

Engineers/ Land
Surveyors

$31.82

1,680

$53,458

Engineers/ Land
Surveyors

$31.82

1,680

$53,458

Engineers/ Land
Surveyors

$31.82

1,680

$53,458

24,360

$798,256

Respondent’s
Occupational Category

Developers or Individual
Property Owners
State/Local Community
Officials
Engineers/ Land
Surveyors
State/Local Community
Officials
Engineers/ Land
Surveyors
Engineers/ Land
Surveyors

TOTAL

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The total Annual Cost Burden for this collection is $798,256. Engineers and Surveyors
are the primary public affected by this forms collection. They are hired by the developers
or individual property owners to research, collect all necessary data, and analyze this
information for the collection. Developers or individual property owners (or their
representatives) are also involved for a brief review of the collection forms. In addition,
the State, Local, or Tribal government representatives review the completed collection
forms against their record and concur, if appropriate. The estimates provided are based on
the burden involved for reviewing and/or completing the collection forms.
The burden rate assumed for the developer or individual property owners (or their
representatives) to complete this form collection are 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 median hourly wage rate was $14.15.
This figure was used to determine the annual cost to the developer or individual
property owners (or their representatives). The developer or individual property
owners may be involved in reviewing and signing Form 81-89, “Overview and
Concurrence Form”. It is estimated that they will spend 420 hours (0.25 hours on
each collection x 1,680 collection per year). The total annual responses for the
developers or individual property owners (or their representatives) annual burden
hours (420) was multiplied by the median hour rate for developer ($14.15) to arrive
at a total cost of $5,943 for developers or individual property owners (or their
representatives).
The burden rate assumed for State, Local, or Tribal governments is based on a
"revealed preference" approach, as outlined in the October 4, 1999, OMB paper
"Estimating Paperwork Burden" (available at
http://www.whitehouse.gov/omb/fedreg/5cfr1320.html). The median hourly wage rate
for a community official in 2004 was assumed to be $50.00. The State/Local
Community Officials owners are typically involved in reviewing and certifying Form
81-89, “Overview and Concurrence Form”. In addition, as required in Form 81-89A,
“Riverine Hydrology & Hydraulics Form”, State/Local Community Officials may be
required to provide public or individual notifications to impacted property owners of
the increased hazards. It is estimated that they will spend 420 hours (0.25 hours on
each collection x 1,680 collection per year) for Form 81-89 and 1260 hours (0.75
hours on each collection x 1,680 collection per year) annually for Form 81-89A
notifications. The total annual responses for the State/Local Community Officials
equals annual burden hours (1,680) was multiplied by the median hour rate for
developer ($50.00) to arrive at a total cost of $84,000 for community officials.
The burden rate assumed for Engineers and Land Surveyors to complete this form
collection is based on the average annual pay figures for these professions, 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 $31.82.

11

All collections would require an engineer’s involvement, but may not require a
surveyor’s service. Therefore, for burden computation, we utilized the engineer’s
wage. It is estimated that they will spend 840 hours (0.5 hours on each collection x
1,680 collection per year) for Form 81-89 and 4,620 hours (2.75 hours on each
collection x 1,680 collection per year) annually for Form 81-89A notifications. For
the remainder of the forms, engineers will be only involved with these collections.
Therefore, engineers will spend (840+4,620+11,760+1,680+1,680+1,680=) 22,260
hours annually for this collection. At the median hourly rate of $31.82 for engineers,
this collection will cost $708,313.
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:
The cost to developers for engineers and/or land surveyors services is estimated to
range from $10,000 to $25,000, depending on the scope of the project. The engineers
and/or land surveyor service includes scoping, surveying cross-sections, developing
hydrologic and hydraulic analysis, and preparing work maps and reports documenting
the engineering analysis and results. The average cost to developers for engineers
and/or land surveyor services is estimated to be $17,500 however; it would likely vary
on a property by property basis. The annual cost to 1,680 respondents multiplied by an
average cost of $17,500 is estimated to be approximately $29.4 million.
Recordkeeping burden is minimal and considered usual business practice for
communities. This is the requirement for each community to keep on file all supporting
analyses and documentation used to support a determination that property (land or
structures) are "reasonably safe from flooding" [as referenced in §65.5(a)(4)(ii),
§65.:(a)(5), §65.6(a)(14)(ii), and §65.6(a)(15) - May 4,2001, Final Rule (Vol. 66, No.
87, pages 22442 - 22443].
a. Operation and Maintenance and purchase of services 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 is no cost to respondents for Operation and Maintenance.
b. Capital and Start-up-Cost should include, among other items,
preparations for collecting information such as purchasing computers and

12

software, monitoring sampling, drilling and testing equipment, and record
storage facilities.
There is no Capital and Start-up Cost for this collection.

Annual Cost Burden to Respondents or Record-keepers
Data
Collection
Activity/Instr
ument

*Annual Capital
Start-Up Cost
(investments in
overhead, equipment
and other one-time
expenditures)

*Annual Operations
and Maintenance Cost
(such as recordkeeping,
technical/professional
services, ect.)

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

Total Annual
Cost to
Respondents

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 [Description below.]

Item

Cost ($)
$18,500

Staff Salaries [1 GS12 employee spending approximately _5_% of time annually

$3,190

($63,809 per year) time to the review, coordination, and approval of the final submission for
MT-2 forms.]

Facilities [cost for renting, overhead, ect. for data collection activity]
Computer Hardware and Software [cost of equipment annual lifecycle]
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]
Travel
Printing [32,500 MT-2 annually]
Postage [mailing 500 MT-2 forms as requested]
Other
Total

$0
$0
$0
$0
$21,360
$200
$0
$43,250

The contractor costs are estimated to be $18,500. This cost includes call center staff
responding to an average of 3,200 calls per year that pertain to this collection. Most of

13

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 $50.00
per hour, the contractor costs for responding to these calls is $16,000. The contract
costs associated with completing and submitting required documents for this
collection is estimated to be $2,500. This includes 50 hours and is based on an average
loaded rate of $50.00 per hour.
Staff salary cost is estimated to be $3,190. This cost includes one GS 12 government
employee dedicating five percent of their time to the review, coordination, and
approval of the final submission for MT-2 forms.
The postage cost for mailing 500 MT -2 forms and an instruction, as requested, is
estimated to be $200 based on a postage cost of $0.39 per mailing.
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.
A "Program increase" is an additional burden resulting from an federal government regulatory action or
directive. (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).
"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
changes in the methods used to estimate burden or correction of errors in burden estimates.

Itemized Changes in Annual Burden Hours
Data collection
Program Change Program Adjustment
Activity/Instrument (hours currently Change (hours currently
on OMB
(New)
on OMB
Inventory)
Inventory)
FEMA Form 81-89
20,880
Series
Difference
Total(s)

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Adjustment
(New)

24,360
+3480
+3480

Explain: Annual burden hours due to additional responses.
Itemized Change in Annual Cost Burden
Data Collection
Program Change Program Old Cost
Activity/Instrument (Old Cost
Change
Burden
Burden
(New)
FEMA Form 81-89
0
0
$25,200.000
Series
Difference
Total(s)

Adjustment
(New)
$29,400,000
+$4,200,000
+$4,200,000

Explain: Annual burden hours due to additional responses.
The total number of respondents for this collection has changed to 1,680 and the total
annual number of responses 10,080. Although the mix of complexity of a
determination request has been stable over the years, there is no way of predicting with
absolute certainty the number of determinations that will be requested in a given year.
The total burden hours increased from 20,880 to 24,360 (+3480) hours. This increase is
due to increase in the number of respondents for this collection. This has caused a
program adjustment of +3480 hours.
The annualized cost to 1,680 respondents multiplied by an average cost of $17,500 is
estimated to be approximately $29.4 million annually. This cost is attributed to the cost
to developers for the services of a license surveyor or engineer to conduct the analyses
required for this information collection.
During September of 2005, the nation was impacted by Hurricane 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 is now re-evaluating accredited levees where new flood
hazards studies are underway. However, this has no impact on 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.
The results of information collections will be made in accordance with NFIP
regulations 44 CFR Parts 65 will not be published for statistical use.
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17. If seeking approval not to 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-I.
This collection does not seek exception to the certification statement referenced above.

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