Supporting Statement

August 17, 2007

Supporting Statement for
Paperwork Reduction Act Submissions
OMB Control Number: 1660 - 0030
Title: Request for the Site Inspection, Landowners Authorization/
Ingress/Egress Agreement
Form Number(s): FEMA Form 90-1 and FEMA Form 90-31
General Instructions
A Supporting Statement, including the text of the notice to the public required by 5 CFR
1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register,
must accompany each request for approval of a collection of information. The
Supporting Statement must be prepared in the format described below, and must contain
the information specified in Section A below. If an item is not applicable, provide a brief
explanation. When Item 17 or the OMB Form 83-I is checked “Yes”, Section B of the
Supporting Statement must be completed. OMB reserves the right to require the
submission of additional information with respect to any request for approval.

Specific Instructions
A. Justification
1. Explain the circumstances that make the collection of information necessary
(give details as to why this information is being collected). Identify any legal or
administrative requirements that necessitate the collection. Attach a copy of the
appropriate section of each statute and regulation mandating or authorizing the
collection of information. Provide a detailed description of the nature and source of
the information to be collected.
44 CFR Part 206.117 provides the requirements for disaster-related housing needs of
individuals and households who are eligible for temporary housing assistance. Section
408(a) of the Robert T. Stafford Disaster Relief and Emergency Assistance Act P.L.100707) authorizes the President to provided mobile homes and other readily fabricated
dwellings to eligible applicants who require temporary housing as a result of a major
disaster. Accordingly FEMA forms 90-1, Request for the Site Inspection and 90-31,
Landowner’s Authorization Ingress-Egress Agreement are designed to: (1) ensure sites
for the temporary housing units will accommodate the unit and comply with local, State
and Federal guidelines and regulations regarding the placement of the unit; (2) ensure the
landowner, if other than the applicant receiving the unit, will allow the unit to be placed
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on the property; and (3) ensure that routes of ingress and egress to and from the property
are maintained.
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 Form 90-1, Request for Site Inspection is used to ensure that the proposed
housing unit sites are evaluated to ensure site feasibility, including a determination
whether the site is located in a floodplain. FEMA Form 90-31, Landowners
Authorization/Ingress-Egress Agreement, is used to obtain approval from the property
owner if other than the applicant for (1) placement and (2) transportation of the housing
unit through adjacent properties in order to place and remove the housing units. The
implementation of this portion of the Temporary Housing Program (Disaster Housing
Program) is implemented when the local infrastructure of a local area under a disaster
declaration has no rental resources available. This would be in the form of hotels,
apartments and or rental homes. Personnel assigned to use these forms are members of
Individual Assistance Group located within the Joint Field Office (JFO) for the purpose
of housing disaster applicants.
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.
At present there are no circumstances that would call for the collections to be handled
through the use of automated, electronic, mechanical or using any other technology. The
forms are the most efficient way to ensure specific information is collected, recorded and
evaluated to reduce the Governments exposure to liability currently.
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.
Duplication of benefits may occur when an applicant has additional living expenses
insurance benefits to cover the cost of renting alternate housing. In these instances,
FEMA may provide a temporary housing unit if adequate alternate housing is not
available, or if doing so is the best interest of the household and the government.
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.

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This collection does not impact small businesses or other small entities.
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.
I f this collection of information is not conducted FEMA would not be able to provide or
authorize temporary housing assistance to eligible individuals and households displaced by a
disaster. Therefore; FEMA would be in violation of the Robert T. Stafford Disaster Relief
and Emergency Assistance Act (P.L. 93-288, as amended, Section 408, Federal Assistance
to Individuals and Households.
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.
Respondents are not required to report this 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.
Respondents are not required to prepare a written response to this 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 document.
Respondents are not required to submit more than an original and two copies of any
document.
(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 by mandate to retain records but are advised by
representatives to retain all documentation for 3 years after the date of filing their
individual applications. Inspectors are not required or authorized to retain records. All
pertinent information is the property of the US Government.
(e) In connection with a statistical survey, that is not designed to produce
valid and reliable results that can be generalized to the universe of study.
This collection does not involve a statistical survey.

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(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 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 that is not supported by
authority established in statute or regulation.
(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 proprietary trade secret, or other
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 Register Notice was published on May 8, 2007, volume 72, number 88,
page 26140-26141. There were no comments received for this information collection.
However; the 30-day federal register notice was amended to capture miscalculated
burden hour estimate published in the 60 day Federal Register Notice.
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 has not sought consultation with other government or private agencies regarding
the information specific to these documents in reference to availability of data, frequency
of collection, clarity of instructions, recordkeeping, disclosure or reporting format due to
the unique nature of the information collected and of the Temporary Housing Program.
No other entity employs or manages similar programs.

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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.
Any site upon which FEMA place housing units must comply with applicable State and
local codes and ordinances, as well as 44 CFR part 9, Floodplain Management and
protection of Wetlands, and 44 CFR Part 10, Environmental Consideration, and all other
applicable environmental laws and Executive Orders. FEMA will provide guidance and
interpretation to meet specific needs through over-site functions. As determined
necessary, monitoring and over-site functions will include on-site programs reviews by
FEMA.
9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
There are no payments or gifts to respondents for this information collection.
10. Describe any assurance of confidentiality provided to respondents and the basis
for the assurance in statute, regulation, or agency policy.
A Privacy Threshold Analysis (PTA) was prepared and submitted to DHS for review on
July 12, 2007, due to Privacy Act information related to individuals and landowners.
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 data collection.
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,

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estimates should not include burden hours for customary and usual business
practices.
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.
ANNUAL BURDEN HOURS
Data Collection
Activities /
Instruments
FEMA Form 90-1,
Request for the Site
Inspection
(Applicants and Site
Inspectors)
FEMA Form 90-31,
Landowner’s
Authorization IngressEgress Agreement
(Landowners and
Applicants)

TOTAL

Number of
Respondents

Frequency
of
Responses

Hour
Burden Per
Response
(hours)

Annual
Responses

Total Annual
Hour Burden
(hours)

(A)

(B)

(C)

(D = AxB)

(E = CxD)

117,071

1

10 minutes

117,071

19,512

117,071

1

10 minutes

117,071

19,512

1

20 minutes

234,142

39,024

117,071

Note: The 30-day federal register notice was corrected to capture miscalculated burden hours
published in the 60-day federal register notice.

FEMA has estimated that the burden hour to Landowners, site inspectors and applicants
to review and complete FEMA Form 90-31 is estimated to be 10 minutes. Landowners
and Site Inspectors must review and complete the landowner’s agreement with the
applicants for placement and/or the removal process for housing units and utility access
and installation. FEMA has estimated that the burden hour to complete FEMA form 90-1
is 10 minutes. The form is completed by FEMA site inspectors and disaster applicants for
site inspections of properties. FEMA site inspectors must complete and review site utility
information on the form with applicant. Although applicants burden for completing these
forms are minimal, FEMA site inspectors and landowners must ensure that the applicant
is present when completing the forms. Both forms are required to receive temporary
housing assistance.
c. Provide estimates of annualized cost to respondents for the hour burdens
for collections of information, identifying and using appropriate wage rate
categories. The cost of contracting out or paying outside parties for information
collection activities should not be included here. Instead this cost should be
included in Item 14.
Annual Cost to Respondents for Hour Burden
Respondent’s
Occupational
Category

Total Annual
Burden Hours

Mean Hour
Rate ($)

Average
Cost per
Respondent
($)

Total Annual Cost
Burden
($)

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Individuals and
Households
LandOwners

19,512
19,512
39,024

$18.84
$25.14
$37.68

$3.14
$4.19
$7.33

$367,606.08
$490,531.68
$858,137.76

Total
Note: The supporting statement was amended to capture miscalculated burden hour cost published in the 60-day
Federal Register Notice.

According to the U.S. Department of Labor, Bureau of Labor Statistics website
(www.bls.gov) the mean hour wage rate for Individuals and Households is estimated to
be $18,84 and for Landowners $25.14, therefore, the estimated burden hour cost to
respondents is = $858,137.76 annually. Site inspectors are FEMA employees therefore
their burden hour cost will be to the government.
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:
Respondents are advised by representatives to retain all documentation for 3 years after
the date of filing their applications. Inspectors are not required or authorized to retain
records. There is no additional cost burden to respondents for record keeping as a result
of this collection. Applicants are not required to pay for site inspections; this is done as
part of the Temporary Housing Program Site Inspection Process.
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.
FEMA has estimated the annualized cost to the government utilizing the US Office of
Personnel Management Salary Table under the following formula for the personnel
involved in the collection and processing of the 90-1 and 90-31. For Estimated annual
staff salaries 300 GS 11, Step 5 employees spending approximately 40 hours a week
doing site inspections and processing 117,071 at $25.51 per hour = $53,238.00 per
employee annually = $15,971,400.00. The cost of printing these forms is $600.00. The
total annualized cost to the government is $15,972.000.00.

ANNUALIZED COST TO THE FEDERAL GOVERNMENT
Item
Contract Costs [Specify what is for and what is included, i.e. S/W development,
survey, etc.]
Staff Salaries [State number of employees involved, GS-level, Time spent w/
this collection] Additional information contained in above statement

Cost ($)
0
$15,971,400.00

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

0
0
0
0
$600
0
0
$15,972,000.00

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.
Itemized Changes in Annual Burden Hours

Burden Hours
Data collection
Currently on the
Activity/Instrument OMB Inventory
FEMA Form 90-1
167
FEMA Form 90-31
200
Total(s)
367

Adjustment
Difference
(New)
19,512
+19,345
19,512
+19312
39,024
+38,657

The adjustment in burden hours for this collection has increased from 367 hours to
39,024 hours (+38,657). The number of responses for this collection has increased from
1,200 responses to 234,142 (+232,942). Although the hour per response for FEMA
Forms 90-1 and 90-31 has not changed, the burden increase was estimated based on the
results of the massive devastation from hurricanes Katrina and Rita, which caused
difficulties in acquiring suitable individual housing. These total hours do not indicate
normal burden hours associated with the Temporary housing program. These estimates
represent an extreme case Burden during a catastrophic disaster.
Itemized Change in Annual Cost Burden
Data Collection
Old
Activity/Instrument Adjustment
Adjustment
Cost Burden (New)
Difference
Individuals and
$367,606.08
+$367,606.08
0
Households
$490,531.68
+$490,531.68
Landowners
0
Total(s)

0

$858,137.76

+$858,137.76

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The burden hour cost to respondents was not captured during the last OMB submission.
The estimated burden hour cost to respondents, using wage rate categories is estimated to
be $858,137.76 annually.
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.
There are no outline plans for tabulation and publication of data for this information
collection.
17. If seeking approval to not display the expiration date for OMB approval of the
information collection, explain reasons that display would be inappropriate.
This collection does not seek approval to not display the expiration date for OMB
approval.
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 “Certification for Paperwork Reduction Act
Submissions”. This collection does not use efficient statistical survey methodology or
use of information technology. Statistical Survey methodology "is not applicable".

B. Collections of Information Employing Statistical Methods.
THERE IS NO STATISTICAL METHODOLOGY INVOLVED IN THIS
COLLECTION.

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