Icr 2577-0075 2

Supporting Statement for Paperwork Reduction Act Submissions

A. Justification: 1 and 15—change to forms that were just approved.

1. Why is this information necessary?

Under Sections 18, 22, 32, and 33 of the U.S. Housing Act of 1937, 42 U.S.C., 1437q (Act), the Secretary of the

Department of Housing and Urban Development (HUD) is authorized to approve requests from Public Housing Authorities

to remove certain public housing property (dwelling units, land, and non-dwelling structures) from their inventories via

through demolition, disposition, voluntary conversion, required conversion, or home ownership. In addition, due to HUD’s

third party beneficiary interest in public housing property under the Annual Contributions Contract (ACC) and Declaration

of Trust, HUD must approve condemnation of public housing property through eminent domain proceedings. PHAs

cannot remove public housing property from their inventories without HUD approval. HUD regulations implementing

Sections 18, 22, 32, and 33 are found at 24 CFR 970, 24 CFR 972, and 24 CFR 906.

In order to efficiently and effectively review requests from PHAs to remove public housing property from their inventories, HUD created Forms HUD-52860 (“Inventory Removal Application”) (and its addendums B-E) to centrally collect information from PHAs that is required by the applicable sections of the Act and HUD regulations. Form HUD-52860 organizes the information that PHAs are required to submit to HUD for approval of inventory removal requests and thus assists PHAs in submitting complete and correct applications. In addition, this information request will assist HUD in maintaining accurate records of the federal public housing stock. In addition to submitting Form-52860 on-line to HUD for review and approval, PHAs must also maintain this Form and supporting documentation on file and report to the HUD Field Office when the inventory removal action has been completed.

On October 23, 2007, OMB approved the reinstatement with changes of an information collection under Paperwork Reduction Act Submission (PRA) 2577-0075 under ICR Reference Number 200707-2577-004. This proposed revision to makes certain changes to this approved information collection to make the information collection consistent with HUD’s recently issued guidance on eminent domain and to correct certain typographical and other errors in that approved collection.

2. How is this information to be used?

This information is collected via on-line application and reviewed by HUD’s Special Application Center (SAC) to ensure that PHAs meet the statutory and regulatory requirements necessary for HUD to approve inventory removal actions. HUD approval is necessary prior to PHAs removing their public housing property in order to protect the federal interest in the public housing property under the ACC and Declaration of Trust. This information is also collected so that HUD has an accurate database of federal public housing inventory and so that the HUD Field Office can effectively monitor the implementation of the removal action. The following types of information are included in this collection: data about the public housing property proposed for removal, relocation plans, evidence of local government approvals, evidence of resident consultations, environmental reviews, appraisals and costs analyses, and homeownership and conversion plans. HUD is not requesting approval of any recordkeeping or reporting requirements as part of this collection of information.

3. Describe whether, and to what extent, the collection of information is automated?

HUD electronically collects public housing inventory data from the PHAs through its Public Housing Information Center, an

automated data entry/database system. This data is reported under other collection numbers throughout HUD’s Office of

Public and Indian Housing. Inventory Removal Actions requested through Form HUD-52860 will affect some of the data

in this system.

Form HUD-52860 (and its addendums) are available on Internet at the HUD website. The information requested in this

form can be submitted via the Internet through the Public Housing Information Center (PIC) system, an automated data

entry/database system. The PIC system allows PHAs to attach supporting documentation electronically. Although, on

occasion, PHAs may submit a paper copy of Form HUD-52860 to HUD, it will primarily serve as a reference and guide to

assist PHAs with their on-line applications.

4. Duplication of Information

This information is not being collected elsewhere and for the most part there is no similar information which has previously

been collected and could be used or modified. However, there are certain instances when information has been

previously collected by HUD for other purposes which provide for that separate HUD-approval for the inventory removal

action is not statutorily or regulatory required. Accordingly, the HUD-52860 does indicate certain instances where it is not

necessary for PHAs to apply for certain inventory removal actions via this form. These instances include: (1) demolition o

of units as part of an approved HOPE VI revitalization plan (as authorized by the Quality Housing and Work Responsibility Act (QHWRA)); and (2) disposition of units approved by HUD under 24 CFR 941 (Subpart F) (Mixed Finance). Also, by

requiring electronic submission of this information, PHAs need not submit any information that is already in PIC.

5. Does the collection of information impact small businesses or other small entities?

This collection of information does not significantly impact small businesses or entities.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or is

conducted less frequently.

HUD approval is required in order to protect the federal interest in public housing property, and, for all of the inventory

removal actions except Required Conversions, the information collected is only occasional, on an ad hoc basis,

depending on when a PHA may desire to removal public housing property from its inventory and must submit this

information to obtain that benefit of removing public housing property from its inventory. For Required Conversions, the

the frequency of this collection of information will depend on when a public housing development meets the standards

under Section 37 of the Act as being subject to Required Conversion and when the PHA develops a conversion plan. In

either case, if this information were collected less frequently, it would unreasonably delay inventory removals by PHAs

and prevent Section 37 of the Act from being properly carried out. If this information were collected less frequently, it

would also likely have an adverse impact on PHAs, their residents, and the communities in which public housing property

is located. This collection ensures that HUD has the necessary information it needs to approve inventory removal

requests of PHAs in a timely manner.

7. Explain any special circumstances

There are no special circumstances that apply to this collection of information.

8. Identify the date and page number of the Federal Register notice soliciting comments on the information.

A Federal Register Notice of Proposed Information Collection was published as a Reinstatement of this Collection (with

revision) on Thursday, December 21, 2006. The public comment period ended on February 20, 2007. HUD received no

comments on this information collection. OMB approved the collection on October 23, 2007. Revisions to that collection

are now necessary and a 60-day Federal Register Notice of the revision to this collection was published on March14,2008

The public comment period ended on May 14, 2008. No comments were received from the public.

9. Explain any payments or gifts to respondents, other than remuneration of contractors or grantees.

No payments or gifts to respondents are provided.

10. Describe any assurance of confidentiality provided to respondents.

The information provided is not of a confidential nature and thus assurance of confidentiality is neither provided nor

needed.

11. Justify any questions of a sensitive nature, such as sexual, religious beliefs, and other matters that are

commonly considered private.

The information collected does not contain questions of a sensitive nature.

12. Annual Reporting Burden

The annual reporting burden hours are based on the experience and estimated amount of time that takes to report the

requested information. The number of respondents is based on the historic number of PHAs that submitted inventory

removal applications in the past. All respondents are a sub-set of the 3,100 PHAs nationwide.

PHAs are required to submit the HUD-52860 application for all inventory removal actions. In addition, depending on the

type of inventory removal action proposed, PHAs may also be required to submit an addendum (B-F) in addition to the

HUD-52860. The addendum submission requirements are as follows:

HUD-52860-B: Total Development Cost (TDC) Calculation		Attach for all Demolition actions and for all Disposition actions where the justification is obsolescence
HUD-52860-C: Homeownership		Attach for all actions involving homeownership
HUD-52860-D: Required Conversion		Attach for all actions involving the required conversion of public housing units
HUD-52860-E: Voluntary Conversion		Attach for all actions involving the voluntary conversion of public housing units
HUD-52860-F: Eminent Domain		Attach for all disposition actions involving eminent domain proceedings

In addition, PHAs must maintain the application (along with the applicable addendum) and supporting

documentation on file, and report to the HUD Field Office when the inventory removal action is complete. The burden

represents an average of the time required for all types of inventory removal actions (e.g. demolition, disposition, home

ownership, eminent domain, etc.).

The information collection, recordkeeping, and reporting requirements will result in the

following approximate burden:

INFORMATION COLLECTION

	Form/Document	No. of Respondents	Frequency	Total Responses	Hours per Response	Total Hours	Cost per hour	Total Cost
1	HUD-52860 Inventory Removal Application	390	1	390	8	2,400	$30	$72,000
2	HUD-52860-B TDC Calculation	180	1	180	2	360	$30	$10,800
3	HUD-52860-C Home Ownership Addendum	17	1	17	10	1,700	$30	$51,000
4	HUD-52860-D Required Conversion Addendum	216	1	216	5	1,080	$30	$32,400
5	HUD-52860-E Voluntary Conversion Addendum	43	1	43	10	430	$30	$12,900
6	HUD-52860-F Eminent Domain Addendum	5	1	5	3	40	$30	$1,200
7	Total	851	1	851	38	6010	$180	$180,300

13. Additional Cost to Respondents

There are no additional costs to respondents other than what is reported in Item 12. There is no reporting or recordkeeping requirements associated with this Information Request.

14. Annualized cost to the Federal Government

The estimated annualized cost to the Federal Government is based on the yearly salary of $76,010, or the hourly rate of

$36.54, the 2006 General Pay Scale for a GS-12, Step 5, which represents the grade of the average staff member of

HUD’s Special Application Center (SAC). The SAC enables the HUD’s Office of Public and Indian Housing to assist

PHA’s in their efforts to efficiently and effectively meet the housing needs of their communities through the specialized

review and approval of non-funded, non-competitive applications, related to the removal of public housing property from

PHAs’ inventory. The SAC has approximately19 full-time employees that work on these programs. The average amount

of time an employee spends reviewing an application is 8 hours. Thus 851 Respondents x $36.54 x 8 hours =

$248,764.32.

15. Explain any program changes or adjustments.

This information collection makes certain revisions to the Paperwork Reduction Act Submission (PRA) for

2577-0075 that was approved by OMB on October 23, 2007 under ICR Reference Number 200707-2577-004. These

changes are necessary to make the collection consistent with HUD’s recently issued guidance on eminent domain and to

correct certain typographical and other errors in that PRA Submission.

Neither the reported annual burden or the annualized cost to the federal government have changed from the PRA Submission 2577-0075 that was approved by OMB on October 23, 2007.

16. If the information will be published, outline plans for tabulation and publication.

The results of this information collection will not be published.

17. OMB Expiration Date

HUD is not seeking approval to avoid displaying the OMB expiration date and the OMB approval number and expiration

date will appear on the form.

18. Certification of Paperwork Reduction Act Submission

There is no exception to Item # 19 "Certification of Paperwork Reduction Act Submission.”

B. Collections of Information Employing Statistical Methods.

The collection of information does not employ statistical methods.