OMB 535 supstat-08 (3)

Supporting Statement for Request of OMB Approval of the Extension of the Low Income Home Energy Assistance Program (LIHEAP)

Quarterly Allocation Estimate Form ACF-535

April 16, 2008

A. Justification

1. Circumstances Making the Collection of Information Necessary

Section 2610(a)(42 U.S.C. 8629) of the Omnibus Budget Reconciliation Act of 1981 (P.L. 97-35) provides the Secretary with the authority to collect information needed to carry out the provisions of the Act.

The quarterly estimate of obligations is required in order to develop apportionment requests, which are submitted to OMB, and to provide grant awards based on grantee needs. Those grantees requested to provide the estimates are State grantees and those tribal grantees that receive over $1 million annually for the Low Income Home Energy Assistance Program. Submission of this information is voluntary. Grantees that are subject to quarterly allocations and choose not to provide quarterly estimates will receive 25 percent of their allocation each quarter.

2. Purpose and Use of the Information Collection

ACF will use the information received from grantees to issue grant awards based on each grantee’s needs. The information will also be used to target grant funds to those grantees which indicate that they will expend most of their allocation during the winter months compared to others that need to utilize the bulk of their funds during the summer months or on an as needed basis throughout the year.

Information from this report will also be used to compile the quarterly apportionment request to OMB to release program funds to ACF for the issuance of grants.

3. Use of Information Technology and Burden Reduction

There is no improved information technology currently available to DEA that would reduce the reporting burden or any technical or legal obstacles to reducing the burden. This is a one-page form and requires very minimal written input from the grantee for completion. Grantees may submit the form by e-mail or fax.

4. Efforts to Identify Duplication and Use of Similar Information

The information collected provides a quarterly estimate of obligations for the Low Income Home Energy Assistance Program. This information is collected annually. The quarterly estimate form is the only form used by States and large tribes to request the issuance of their LIHEAP funds according to their quarterly needs. Information collected on this form is not available through any other Federal source.

5. Impact on Small Businesses or Other Small Entities

The LIHEAP Program is limited by statute to provide funds to State, Territorial and Tribal governments or tribal organizations. Small businesses, therefore, are not involved in providing this information. The information being requested or required has been held to the absolute minimum required for the intended use.

6. Consequences of Collecting the Information Less Frequently

Seventy percent of LIHEAP funds are used for winter assistance. Without this form, States and large tribes would received 25 percent of their allotment each quarter instead of having the opportunity to request funds at the rate they are needed. At 25 percent each quarter, some grantees would run out of funds during the winter season when the need for energy assistance funds is most critical. Additionally, collection of this data less frequently would not allow grantees the flexibility to assess their annual needs, the current economic status of their state, the current costs for energy, and other factors that would influence their estimate of obligations.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

No special circumstance requires the collection of information in a manner inconsistent with the guidelines in 5 CFR 1320.6.

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

Notice of the request for OMB approval of information collection for the LIHEAP Quarterly Allocation Estimate Form ACF-535 was published in the Federal Register and made available for review and comment on January 9, 2008 (Vol. 73 FR 1617). We sent a copy of the Federal Register notice and the proposed form to all LIHEAP grantees and persons on our “interested parties” mailing list and requested their comments. In addition, this package was also submitted to Mr. Mark Wolfe, Director, National Energy Assistance Directors Association for review and comment.

We received no comments.

9. Explanation of Any Payment or Gift to Respondents

There are no payments or gifts associated with this data collection effort.

10. Assurance of Confidentiality Provided to Respondents

No assurances of confidentiality are necessary based on the nature of this report.

11. Justification for Sensitive Questions

The data collection does not contain any questions of a sensitive nature.

12. Estimates of Annualized Burden Hours and Costs

The total annual reporting burden for the state and tribal grantees completing this form is estimated to be 13.75 hours. The estimated burden represents respondent time needed to review the questions, write in the estimates, and submit the form. This estimate is based on 55 respondents completing and submitting the form. We estimate the total average burden to be .25 hours per respondent, resulting in a total respondent burden of 13.75 hours. This estimate is determined by staff judgment. The annual hours for report preparation are computed as follows:

ANNUAL BURDEN ESTIMATES

INSTRUMENT	NUMBER OF RESPONDENTS	NUMBER OF RESPONSES PER RESPONDENT	AVERAGE BURDEN HOURS PER RESPONSE	TOTAL BURDEN HOURS
ACF-535	55	1	.25	13.75

Estimated Total Annual Burden hours: 13.75

13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers

There are no additional annual direct costs to respondents as a ersult of this information collection.

14. Annualized Cost to the Federal Government

The total annual Federal cost associated with the use of this form is estimated at $40. This figure is based on the premise that it takes the Federal government 2 hours to input 55 jurisdictions into the GATES system for an estimated hourly cost of $20.00 per hour. There are no printing costs associated with this form.

15. Explanation of Program Changes or Adjustments

There is no additional increase or decrease in burden hours.

16. Plans for Tabulation and Publication and Project Time Schedule

We do not plan to publish this information.

17. Reason(s) Display of OMB Expiration Date is Inappropriate

The OMB clearance number and expiration date will be displayed on the form.

18. Exceptions to Certification for Paperwork Reduction Act Submission

There are no exceptions necessary for this data collection effort.

B. Collection of Information Employing Statistical Methods

The collection of this information does not employ statistical methods.