Impact Aid Supporting Statement

2/2008
IMPACT AID PROGRAM
DISCRETIONARY CONSTRUCTION GRANTS
(TITLE VIII OF THE ELEMENTARY AND SECONDARY EDUCATION ACT)
REQUEST FOR OMB APPROVAL
SUPPORTING STATEMENT REQUIRED UNDER
THE PAPERWORK REDUCTION ACT
JUSTIFICATION
1.

Circumstances that make the collection of information necessary.
The Impact Aid Program, authorized by Title VIII of the Elementary and Secondary
Education Act (ESEA), provides financial assistance to local educational agencies
(LEAs) whose enrollment or revenues are adversely affected by Federal activities. The
program statute was amended and reauthorized on October 30, 2000, by the Impact Aid
Reauthorization Act of 2000, which was part of the Floyd D. Spence National Defense
Authorization Act for Fiscal Year (FY) 2000 enacted by P.L. 106-398. That
reauthorization authorized a new Discretionary Construction Grant program under
Section 8007(b). Further amendments to Section 8007(b) were enacted as part of the
ESEA reauthorization in January 2002.
The Impact Aid Discretionary Construction Program provides grants to eligible Impact
Aid school districts to assist in addressing their school facility emergency and
modernization needs. The eligible Impact Aid school districts have a limited ability to
raise revenues for capital improvements because they have large areas of Federal land
within their boundaries. As a result, these districts find it difficult to respond when their
school facilities are in need of emergency repairs or modernization. The fiscal year 2008
appropriation provides $17 million for this competitive construction grant program,
available for obligation through FY 2009.
An application package and final rule were published for the first year of the program. In
October of 2003, the Department of Education submitted a collection package with a
notice of proposed rulemaking that made minor changes in the rules published for the
first year of this competitive grant program as well as a new application package. The
NPRM was published October 22, 2003 providing the public an opportunity to comment.
Sections 222.183, 222.184, 222.185, and 222.186 of the regulation include information
collection requirements. The Department has completed the Final Regulations and has
attached them to this collection for OMB review and approval.

2.

Purposes for which the information is used.
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The Department will use the information collected in the application to determine
whether applicants meet the basic eligibility requirements of section 8007(b), to
determine whether the applicant is requesting an emergency or modernization grant, and
to determine which of the four priorities described in the statute applies to the individual
application. Among the criteria the Secretary is required to consider are the applicant’s
total assessed value of real property that may be taxed for school purposes, its use of
bonding capacity, and the nature and severity of its need for funds. In addition,
information on the application will be used to rank applications within each of the four
priorities.
3.

Use of information technology.
The Department of Education has developed an electronic application for this grant
program, which will be available for preparing and submitting the FY 2008 applications.
The software will populate certain data fields for applicants that submitted an FY 2008
Impact Aid section 8003 application, and will have built-in checks for completion of all
necessary items. This software will reduce the burden on applicants of organizing and
entering data that were already submitted to the Impact Aid Program, will help applicants
to determine whether their LEAs meet the program’s eligibility requirements, and will
reduce the number of errors in applications.

4.

Efforts to identify duplication.
As noted above, eligibility for this grant program relies partially on data that were
already submitted in FY 2008 Impact Aid applications for section 8003. The Department
has developed an electronic application that will allow certain data that are necessary for
this application, but that were already submitted by an Impact Aid applicant, to be
populated in the application. These data items include the applicant’s identifying
information and DUNS number, the applicant’s FY 2008 Impact Aid survey date, and the
Federal property codes that the applicant used on Tables 1 through 5 of the FY 2008
application. This will increase the accuracy of the information submitted in the
applications and eliminate duplication of effort on the part of the applicants. Further, the
eligibility requirements for this competitive grant are complex. Populating these data for
the applicants will assist them in determining whether their LEAs may be eligible, thus
possibly helping certain applicants avoid the burden of completing an application that
could not be successful.

5.

Collection of information involving small entities.
The respondents are LEAs and local officials. Small businesses or other small entities
are not significantly impacted by this collection of information.

6.

Consequence to Federal program or policy activities if the collection were
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conducted less frequently.
The statute requires applicants to apply for funds. The Department would not be able to
award these funds without the application to collect the required information.
7.

Special circumstances that require the collection to be conducted in a manner
inconsistent with the guidelines in 5 CFR 1320.5.
This application is consistent with all of the guidelines in 5 CFR 1320.5.

8.

Efforts to consult with persons outside the agency.
In modifying the application package, the Impact Aid Program considered informal
comments from school district officials that submitted applications, as well as
observations of common errors applicants made in previous applications. Changes were
made to the format of the cover page to discourage some common errors.

9.

Payments or gifts to respondents.
No gifts or payments will be made to respondents other than the funds awarded under the
statute.

10.

Assurances of confidentiality.
There is no assurance of confidentiality provided to the respondents concerning these
collections of information.

11.

Questions of a sensitive nature.
There are no questions of a sensitive nature in these collections of information.

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12.

Cost estimates of the hour burden of the collection requirements.

Burden data estimates
Collection

Number of
Respondents

Frequency

Number of
Responses

Average
Hours

Total

Section 8007(b)
application

180

1

180

5.25

945

Health/Safety
Emergency Certification
Letter

180

1

180

.75

135

TOTAL

360

1

360

3

1,080

The annual number of responses for this collection totals 360. The average number of
hours/response is 3, which results in a total of 1,080 annual burden hours.
Burden cost of collections: At an average cost of $25 per hour, the cost per response is
estimated to be:
-- Section 8007(b) application
-- Health/Safety Emergency Certification Letter

$
$
Total

13.

$

131.25
18.75
________
150.00

Cost burden to respondents or record keepers from the collection of information.
There are no start-up costs for this collection.

14.

Annualized cost to the Federal Government.

Section 8007(b) e-application development:
Analysis and processing (5 hrs./app. x $32.09 hr. x 150 apps.)
Peer Review: 12 reviewers x $1,500 (travel and stipend)
TOTAL

15.

20,000.00
24,067.50
18,000.00
67,067.50

Reasons for changes in burden.
The hours burden is slightly reduced by the removal of a table and data element that
required outside consultation. A budget table replaced this table, with a net change in
average burden hours of .3 hours. The monetary burden to the applicant remains the
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same, but the cost to the Department is decreased by an already established application
system.
16.

Publishing of the collection of information.
The information collected will not be published.

17.

Displaying the expiration date for OMB approval.
The expiration date will be displayed on the applications.

18.

Exceptions to the certification statement.
There are no exceptions to the certification statement.

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