Icr 2506-0153

ICR 2506-0153.doc

Brownfields Economic Development Initiative (BEDI) Grant Application

OMB: 2506-0153

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Paperwork Reduction Act Submission

Please read the instruction before completing this form. For additional forms or assistance in completing this forms, contact your agency’s Paperwork Reduction Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 Seventeenth St. NW, Washington, DC 20503.

1. Agency/Subagency Originating Request:

U.S. Department of Housing and Urban Development

Office of Community Planning and Development

2. OMB Control Number:

a. 2506-0153


b.   None

     

3. Type of information collection: (check one)

  1. New Collection

  2. Revision of a currently approved collection

  3. Extension of a currently approved collection

  4. Reinstatement, without change, of previously approved

collection for which approval has expired

  1. Reinstatement, with change, of previously approved collection

for which approval has expired

  1. Existing collection in use without an OMB control number

For b-f, note item A2 of Supporting Statement instructions.

4. Type of review requested: (check one)

  1. Regular

  2. Emergency - Approval requested by      

  3. Delegated

5. Small entities: Will this information collection have a significant economic impact on a substantial number of small entities?

Yes No

6. Requested expiration date:

a. Three years from approval date b. Other (specify)

     

7. Title:

Brownfields Economic Development Initiative (BEDI) Grant Application



8. Agency form number(s): (if applicable)

HUD-40122, HUD-40123, SF 424, SF 424S, SF LLL, HUD-424-B, HUD-2880, HUD-2990, HUD-96010-l, HUD-2993



9. Keywords:

Housing, Economic Development, Brownfields



10. Abstract:

This information collection is required to rate and rank applications submitted as part of a funding competition and to ensure funding eligibility of applicant activities. Respondents are units of general local government eligible for Section 108 Loan Guarantees under 42 USC 5308.



11. Affected public: (mark primary with “P” and all others that apply with “X”)

a.   Individuals or households e.   Farms

b.   Business or other for-profit f.   Federal Government

c.   Not-for-profit institutions g. P State, Local or Tribal Government

12. Obligation to respond: (mark primary with “P” and all others that apply with “X”)

a.   Voluntary

b. P Required to obtain or retain benefils

c. Mandatory

13. Annual reporting and recordkeeping hour burden:

a. Number of respondents 50

b. Total annual responses 50

Percentage of these responses collected electronically 100%

c. Total annual hours requested 2000

d. Current OMB inventory 2000

e. Difference (+,-)

f. Explanation of difference:

1. Program change: -

2. Adjustment:      

14. Annual reporting and recordkeeping cost burden: (in thousands of dollars)

Do not include costs based on the hours in item 13.

a. Total annualized capital/startup costs $0.00

b. Total annual costs (O&M) $0.00

c. Total annualized cost requested $0.00

d. Current OMB inventory $0.00

e. Difference $0.00

f. Explanation of difference:

1. Program change: 0

2. Adjustment: 0

15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”)

a. P Application for benefits e. X Program planning or management

b.   Program evaluation f.   Research

c.   General purpose statistics g. X Requlatory or compliance

d.   Audit

16. Frequency of recordkeeping or reporting: (check all that apply)

a. Recordkeeping b. Third party disclosure

c. Reporting:

1. On occasion 2. Weekly 3. Monthly

4. Quarterly 5. Semi-annually 6. Annually

7. Biennually 8. Other (describe)


17. Statistical methods:

Does this information collection employ statistical methods?

Yes No


18. Agency contact: (person who can best answer questions regarding the content of this submission)

Name: David Kaminsky, Brownfields Economic Development Initiative

Coordinator

Phone: 202-402-4612



19. Certification for Paperwork Reduction Act Submissions

On behalf of the U.S. Department of Housing and Urban Development, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9.

Note: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320/8(b)(3). appear at the end of the instructions. The certification is to be made with reference to those regulatory provisions as set forth in the instructions.


The following is a summary of the topics, regarding the proposed collections of information, that the certification covers:

  1. It is necessary for the proper performance of agency functions;

  2. It avoids unnecessary duplication;

  3. It reduces burden on small entities;

  4. It uses plain, coherent, and unambiguous terminology that is understandable to respondents;

  5. Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

  6. It indicates the retention periods for recordkeeping requirements;

  7. It informs respondents of the information called for under 5 CFR 1320.8(b)(3):

  1. Why the information is being collected;

  2. Use of the information;

  3. Burden estimate;

  4. Nature of response (voluntary, required for a benefit, or mandatory);

  5. Nature and extent of confidentiality; and

  6. Need to display currently valid OMB control number;

  1. It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to collected (see note in item 19 of the instructions);

  2. It uses effective and efficient statistical survey methodology; and

  3. It makes appropriate use of information technology.


If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.

     


Signature of Program Official:




X

     

Date:

Supporting Statement for Paperwork Reduction Act Submissions


A. Justification


1. CIRCUMSTANCES THAT MAKE COLLECTION OF INFORMATION NECESSARY:

Brownfields Economic Development Initiative (BEDI) grants are used to enhance the security of a Section 108 guaranteed loan or to improve the feasibility of proposed projects through techniques such as interest rate subsidies, loan loss reserves, debt service reserves and write downs of project costs. Eligible applicants for both programs are Community Development Block Grant (CDBG) entitlement units of general local government, and non-entitlement units of general local government which are eligible to receive Section 108 loan guarantees under 24 CFR 570.702. Eligible expenses are those authorized under 24 CRF 570.703 of the Community Development Block Grant program. The National Objectives criteria of 24 CFR 570.208 and the economic development project guidelines of 24 CFR 570.209 also apply. By statute, BEDI grants may only be awarded to eligible recipients in conjunction with Section 108 loan guarantee commitments. The BEDI grant program is governed by the administrative requirements applicable to the CDBG and Section 108 loan guarantee programs. As such, the BEDI grant program relies heavily upon the existing information collection requirements and approval for the CDBG program (OMB No. 2506-0077) and Section 108 Loan Guarantee program (OMB 2506-0161). An application for assistance for the BEDI grant program will be a discretionary act on the part of the applicant.

The BEDI grant program is authorized by Title I of the Housing and Community Development Act of 1974 (the Act) (42 USC 5301-5320), specifically under Section 108(q) of the Act. The BEDI program is being implemented through the Super Notice of Funding Availability (SuperNOFA) for FiscalYear 2007 (FR-4900-N-07). Implementing regulations are set forth in 24 CFR part 570.



2. USE OF INFORMATION COLLECTION:

The information collection is required to assist HUD in selecting applicants to receive BEDI grant funds and to document program compliance. Information to be collected is specified in the SuperNOFA. The information collected is essential in order to rate and rank proposals, in keeping with the statutory provisions, and in order to determine the eligibility of applicants and proposed activities. The selection criteria are required by the Act, and may include additional criteria if the Secretary deems necessary. After the Congressional notification of grant awards are made, recipients are required to follow applicable federal CDBG (OMB No. 2506-0077) and Section 108 loan guarantee requirements (OMB No. 2506-0161). Information required to satisfy the record keeping requirements of these programs will be collected and maintained. Information collected will be used in the approval of the Section 108 loan guarantee and to monitor grantee compliance with program requirements.


3. USE OF INFORMATION TECHNOLOGY:

Since Fiscal Year 2005, all applications for BEDI assistance have been accessed through the www.grants.gov website and have been electronically transmitted to HUD for rating and ranking.



4. DUPLICATION:

HUD has made every effort to avoid duplication of information collection and record keeping. HUD intends to continue to utilize to the greatest extent possible information and records collected for the applicant’s CDBG and Section 108 loan guarantee programs, and where applicable, the applicant’s Renewal Community, Empowerment Zone or Enterprise Community program. Use of applicable pre-existing approved Neighborhood Revitalization Strategies, Consolidated Plans, or Renewal Community, Empowerment Zone or Enterprise Community plans will be permitted. Other information which is specific to the eligibility and selection criteria under the NOFA is unique to the BEDI grant program, and is essential so that HUD staff may determine the eligibility, qualifications and capacity of the applicants to carry out a BEDI grant program.


  1. SMALL BUSINESSES AND OTHER SMALL ENTITIES:

The impact on small businesses is not significant.



  1. CONSEQUENCE TO FEDERAL PROGRAMS IF INFORMATION IS NOT COLLECTED OR COLLECTED LESS FREQUENTLY:

HUD will review the information provided by applicants against the selection criteria contained in the NOFA in order to rate and rank the applications and select the best and most qualified individual applications for funding. Applicants will be notified of their selection or rejection. If the information were not collected, there would be no basis for selecting grantees through the competitive process, and no means of assessing the feasibility or eligibility of the program design. Program accountability depends substantially upon the recipient documenting compliance with program requirements (including requirements for financial accountability) and comparing performance against established benchmarks. Inadequate or incomplete information will create substantial risk to the Department of fraud and abuse with respect to the use of federal program funds. The collection of information necessary for the review of applications will occur on a one-time basis only. It cannot be done less frequently. Reporting intervals are the maximum, and content requirements are the minimum established by the applicable CDBG and Section 108 loan guarantee regulations and administrative requirements (OMB Circular A-87, OMB Circular A-128 and applicable sections of 24 CFR Part 85.



  1. SPECIAL CIRCUMSTANCES:

The information collection requirements are consistent with the guidelines in 5 CFR 1320.6.



  1. CONSULTATIONS WITH PERSONS OUTSIDE THE AGENCY:

The information collection is being submitted under the regular review procedures, with a three year expiration date from the approval date. On September 18, 2007 a notice was published in the Federal Register (FR-5118-N-05, p.53254) soliciting public comments. One comment was received and responded to via email.


  1. PAYMENTS OR GIFTS TO RESPONDENTS:

No gifts or payments will be given to respondents.



  1. ASSURANCES AND CONFIDENTIALITY:

Applications for BEDI grant assistance submitted to HUD will be subject to Freedom of Information Act (FOIA) requirements. “Trade secretes and commercial or financial information obtained from a person and privileged or confidential” are specifically exempted from release under FOIA pursuant to 5 USC 552(b) (4). Records of other information collected will be maintained by the recipients of the assistance. Information on activities and expenditures of grant funds is public information and is generally available for disclosure.



  1. QUESTIONS OF A SENSITIVE NATURE:


No questions of a sensitive nature are included in the information to be collected.


  1. ESTIMATED ANNUAL HOUR BURDEN:

Much of the burden associated with the BEDI grant program is already captured under the information collection requirements of the CDBG and Section 108 loan guarantee programs. Applicants for BEDI grants need to prepare additional information to apply for assistance. Other administrative requirements will be addressed through the Section 108 guarantee application process since the BEDI funding will be used in conjunction with Section 108-assisted projects.


Description of Information Collection (Application Submission Requirements)

Number of Respondents

Responses per Year

Total Annual Responses

Hrs per Response

Total Hours

SF-424 - Application for Federal Assistance

50

1

50

0.75

37.5

Narrative Statement

50

1

50

25.25

1262.50

SF-424-Supplemental, Survey on Ensuring Equal Opportunity for Applicants

50

1

50

0.1

5

HUD-424-B Applicant Assurance and Certification

50

1

50

0

0

SF LLL - Disclosure of Lobbying Activities

50

1

50

0.17

8.5

HUD-2880 - Applicant/Recipient Disclosure/ Update Report (2510-0011)

50

1

50

0

0

HUD-2990 - Certification of Consistency with the RC/EZ/EC Strategic Plan

50

1

50

0

0

HUD-96010-I - Logic Model (2535-0114)

50

1

50

0

0

HUD-40123 Brownfields Economic Development Application

Distress/Extent of Problem

Soundness of Approach Financial

Soundness of Approach Timeline

Section 108 / CDBG Eligibility

50

1

50

13.73

686.50

HUD-40122 Sec. 108 Loan Guarantee Certification

50

1

50

0

0

HUD-2993 Acknowledgement of Application

50

1

50

0

0


50

1

50

40

2000


50 applicants x 40 hours x $50/hour = $200,000


  1. ESTIMATED ANNUAL COSTS TO RESPONDENTS:


No capital or start-up costs are anticipated since applicants are units of general local government which should already possess the required facilities, equipment and staff.


  1. ADDITIONAL COST TO THE FEDERAL GOVERNMENT:

No additional costs to the Federal government are anticipated. Application and program performance will be reviewed by HUD’s existing staff in accordance with established review and monitoring procedures.


  1. INCREASE/DECREASE IN BURDEN REPORTED FROM PREVIOUS OMB INFORMATION COLLECTION REQUEST:

This is an extension of a currently approved collection. There are no changes to item 13 of the OMB 83-I.


  1. PUBLICATION OF INFORMATION:

Information collected through the forms or the BEDI application is not published.

  1. EXPIRATION DATE DISPLAY:

The expiration date of the OMB approval of the form will be displayed on the form.


  1. CERTIFICATION EXCEPTIONS:

No exceptions to the certification in item 19 are requested.


B. Collections of Information Employing Statistical Methods


     


OMB 83-I 10/95

File Typeapplication/msword
File TitlePaperwork Reduction Act Submission
AuthorWAYNE EDDINS
Last Modified ByPreferred User
File Modified2008-03-04
File Created2007-11-16

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