Revised_Supporting_Statement,_1024-0018[1][1][2]

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION

36 CFR 60 AND 63: National Register of Historic Places Registration form; Continuation Sheet;

NR Multiple Property Documentation form

OMB Control Number 1024-0018

Terms of Clearance: None

A. Justification

1. Explain the circumstances that make the collection of information necessary. 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.

The National Historic Preservation Act of 1966, as amended, authorizes the Secretary of the Interior to maintain a National Register of Historic Places as a list of the Nation's historic, architectural, and archeological resources worthy of preservation. Nominations to the National Register are made by Federal agencies (FPO), State Historic Preservation Officers (SHPOS), Territories, the District of Columbia, and Indian Tribes (THPO) on tribal lands as required by the law and 36 CFR Part 60. These officials are responsible for documenting the nominated properties to the satisfaction of the Secretary. The 1980 amendments to the Act allow for the nomination of properties by local governments or individuals in cases where there is no approved State program. The National Register of Historic Places Registration Form and the National Register of Historic Places Multiple Property Documentation Form (known as MPS, for multiple property submissions) are completed by individuals or the SHPO, FPO, THPO, or other nominating organizations. They are then forwarded to the National Park Service (NPS) for nomination to the National Register. The forms are also completed by Federal agencies seeking a determination of eligibility for listing as required by the law, as amended and 36 CFR 63. The forms collect only that information which is necessary to conform to the requirements of the National Historic Preservation Act and the Federal regulations which implement that Act.

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

The information provided on forms 10-900, 10-900-a, and 10-900-b is used by the NPS to evaluate the eligibility of properties and approve them for inclusion in the National Register. Registration and multiple property documentation forms are evaluated by the National Register staff before listing and reviewed after listing during periodic program reviews. NPS approval of forms is based on 1) the sufficiency of information provided in the forms and supporting documentation, such as photographs and maps that accompany the forms, and 2) the eligibility of the property when evaluated according to the National Register criteria. Much of the information requested on the form corresponds to data fields in the National Register computerized database, the National Register Information System (NRIS). The NRIS provides a readily accessible, on-line source of information about the National Register and the properties it contains. Information on the registration and multiple property forms is routinely used by States, Federal agencies, Indian Tribes, and others in applying the Federal protections and rehabilitation incentives afforded properties listed in the National Register. The information is used for heritage education and interpretation to provide a tangible understanding of our common heritage. Historic context information in multiple property documentation forms also assists States and others in planning for the identification, evaluation, and protection of historic resources.

Justification for the 11 items contained on the National Register of Historic Places Registration Form (10-900) is as follows:

1. Name of Property: This block identifies the specific property being registered in the National Register according to the various names by which the property has been known. Although the historic name is generally considered the official name of the property, the inclusion of other names provides an appropriate means of differentiating one property from other similarly named properties already listed in the National Register. It also assists the public and other users who may know the property by these other names.

2. Location: This block identifies the geographic location of the property by street number, street, city, county, state, and ZIP code. The "not for publication" item is used primarily for resources, such as archeological sites, which would be adversely affected by amateur excavation or vandalism by the general public if the location were disclosed. In accordance with the National Historic Preservation Act, the National Register is allowed to withhold information on specific locations of properties which might be adversely affected by the release of such information. The item "vicinity" is used to help locate properties outside of incorporated political jurisdictions.

3. State/Federal Agency or Tribal Certification: The signature of the State, Federal, or Tribal certifying official certifies that the documentation provided on the form meets the National Register documentation standards and that its submission meets the professional and procedural requirements set forth in the regulations. This statement clarifies the accountability of the Federal, State or Tribal official for the content and submission of the form, in keeping with the intent of the National Historic Preservation Act. It also provides for clear statements of the opinion of the certifying official and any commenting officials, as outlined in the regulations, on whether or not the property meets the National Register criteria. The item for the level at which the certifying official has considered the significance of the property indicates the contextual level at which evaluation of the property has taken place, that is, locally, statewide, or nationally.

4. National Park Service Certification: This block is completed by the NPS to record the nature and dates of actions taken regarding the registration of the property in the National Register.

5. Classification: This block is used to classify the property by ownership of the property, type of property, and the number and nature of resources comprising it. Since some resources within a property, such as a district, may have been previously listed, that number is also requested. The name of a related multiple property listing provides a useful cross-reference to the multiple property file, if applicable. This block provides useful information that quickly provides essential facts that relate the property to specific provisions of the National Register program as outlined in the regulations.

6. Function or use: This block requests information on the current and historic functions or uses of the property. The block is completed from a list of categories that correspond to those entered in the NRIS.

7. Description: The narrative description of the physical appearance and condition of a property requested in this block is important in making an accurate assessment of the significance and integrity of the property being registered. The items for Architectural Classification and Materials are completed from lists of categories corresponding to those entered in the NRIS. They provide quick reference to the physical aspects of the property that relate to its integrity, significance, and need for specific preservation treatments.

8. Statement of Significance: The narrative statement of significance requested here is based on documentary research of the property and the specific assessment of how the property qualifies for listing in the National Register. Applicable National Register criteria and criteria considerations (exceptions) quickly link the property to the qualifying National Register criteria as specified in the regulations. Areas of Significance, Period of Significance, Significant Dates, Cultural Affiliation, Significant Person, and Architect/Builder provide easy reference to the specific facts, dates, and associations that underscore the property's historic importance and relate it to the National Register criteria. All items directly correspond to data elements and categories included in the NRIS.

9. Major Bibliographic References: This block lists the sources from which the documentation given on the form was compiled and the assessment of the property's significance was made. This information is necessary to verify information given in the Description and Significance blocks. This block also requests indication of 1) any previous documentation on file in the NPS, and 2) the location of additional documentation. This cross-referencing proves useful to tie documentation sources and administrative processes together regarding how the property has been evaluated and for what purposes previously.

10. Geographical Data: This block provides information on the acreage, UTM references, and boundaries for the property being registered. Acreage, given to the nearest acre, specifies the size of the property being registered. UTM references provide for a simple and accurate method for recording the geographical location of the property. The verbal boundary description specifies exactly what land is included and defines its legal boundaries for purposes of listing in the National Register. The block also requests a concise explanation or justification of how the boundaries and acreage were selected. Information in this block is essential for identifying exactly what property is being registered and for ensuring that the boundaries and acreage selected are appropriate to the property's historic significance.

11. Form Prepared by: This block identifies the name, organization, address, and phone number of the person(s) directly responsible for compiling the information. This information enables the National Register staff to contact the person directly, if necessary, after consultation with the SHPO, FPO or THPO.

Form 10-900-a, National Register of Historic Places Continuation Sheet, is used to complete items from forms 10-900 and 10-900-b for which additional space is needed: it is actually just a blank page with a National Register of Historic Places header. Although concise information is requested, the complexity and size of some kinds of properties, such as historic districts, necessitates additional space for completing the requested information.

Form 10-900-b, National Register of Historic Places Multiple Property Documentation Form (known as a MPS, for multiple property submission) is also used to document properties for inclusion in the National Register. This form is used in conjunction with the Registration Form, 10-900, and continuation sheets, 10-900-a. The MPS cover form efficiently provides, in a single document, the contextual information necessary for the evaluation of many historic resources related through geography and/or theme. Because the registration forms for related individual properties do not restate this information—it is required to merely relate the individual property to the historic context information recorded in the multiple property documentation cover form--their recordation is substantially facilitated and the time to accomplish it significantly expedited. Furthermore, the evaluation of newly surveyed or discovered resources also will be expedited when they can be related to existing historic context documentation contained in extant MPS cover forms. All historic contexts approved for MPS nominations to the National Register nationwide are available on-line to further facilitate and expedite the identification, evaluation and registration of additional similar properties.

Justification for the nine items contained on the National Register of Historic Places Multiple Property Documentation Form is as follows.

A. Name of Multiple Property Listing: This block identifies the multiple property submission and provides an easy reference by which to link individual properties related to the form. The name is based on common physical characteristics, on historical events or persons to which the group relates, or architectural or archeological types which describe the properties.

B. Associated Historic Contexts: This block lists the historic contexts or an organizational format that groups the information about the related properties. The titles of the historic contexts include the unifying theme, period of significance, and geographical area. The block is used to list the themes with which the properties included in the MPS submission are associated.

C. Form Prepared By: This block identifies the name, organization, address, and phone number of the person(s) directly responsible for compiling the documentation. This information enables the National Register staff to contact that person directly, if necessary, after consultation with the SHPO, FPO, or THPO.

D. Certification: The signature of the State, Federal or Tribal certifying official certifies that the documentation provided on the form meets the National Register documentation standards and that its submission meets the professional and procedural requirements set forth in the regulations. The statement clarifies the accountability of the Federal, State, or Tribal official for the content and submission of the form, in keeping with the intent of the 1980 amendments to the National Historic Preservation Act. Upon approval of the form, the Keeper signs and dates it.

E. Statement of Historic Contexts: This block includes a discussion of the themes on which contexts listed in block B are based. Each context is related to significant patterns of American history, architecture, archeology, engineering and culture. It is discussed in terms of the historic development of the locality, State, or Nation, and in terms of the general areas of significance for which properties related to the group may be listed.

F. Associated Property Types: In this block, all of the variety of property types representing the contexts discussed in block E are listed. Property types link the ideas incorporated in the theoretical historic context with actual historic properties that illustrate the underlying themes. For each property type given, this section will include: a description of the physical characteristics or common associations with events or persons that define the property type; a statement of how the property type is significant to the areas outlined in the historic context; and the registration requirements, (what features or characteristics individual properties must retain in order to convey the significance of the property type and thus be eligible for inclusion in the National Register) based on an analysis of the data collected on the property type. This section will be a tool in identifying and evaluating resources for nomination to the National Register.

G. Geographical Data: This block describes the geographic limitations of the area where properties included within the multiple property submission exist. The information is essentially a list of towns, cities, counties, parts of counties, multiple counties, areas of states, regions or multiple states where the resources are located.

H. Summary of Identification and Evaluation Methods: This block explains the methods used to identify and analyze property types and determine the requirements for listing. The summary of methods assists the NPS in evaluating and verifying the information given in blocks E and F.

1. Major Bibliographic References: This block lists major bibliographic references, surveys, and study units used to document the property types and historic contexts. This information is necessary to verify the statements made in blocks E and F.

Form 10-900-a, the National Register of Historic Places Continuation Sheet, is also used to complete items from 10-900-b

or which additional space is required: it is actually just a blank page with a National Register of Historic Places header.

Although concise information is requested, documenting the historic contexts, significance, and registration requirements

for a number of property types will require additional space.

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.

While currently forms must still be submitted on paper for archival purposes, with the required accompanying maps and photographs, now almost all forms that are submitted were originally created using an electronic template (found on-line at http://www.cr.nps.gov/nr/publications/forms.htm). The NPS has developed an electronic form, which includes features such as on-line links to guidance materials, edit checking to catch technical errors, "pop-up" tables with accepted choices for items that must be drawn from a list, and the ability to extract data for electronic transfer to databases (found on-line at http://www.nr.nps.gov/NRISFORMS). The electronic forms currently must be printed out and signed by the nominating authority for submission to the NPS because an industry standard for electronic signature has yet to be established government wide. In connection with this electronic form, and to work toward further achieving the requirements mandated by the Government Paperwork Elimination Act, NPS is also exploring electronic submission of the documentation, if it can streamline the process and reduce the burden to respondents. If a streamlined process that reduces the burden to respondents is determined, then we will adopt the electronic submission of documentation at such time that the industry standards for doing so have been established government wide.

In addition, all historic contexts approved for MPS nominations to the National Register nationwide are available on-line to further expedite the identification, evaluation and registration of similar properties, and to reduce the burden of their registration form preparation. The expanded photographic policy implemented in March 2005 now allows for the submission of digital images as supporting documentation for nominations. This expansion will facilitate the preparation of nomination documentation and is viewed as another incremental step toward the development of a full electronic submission process for nominations.

4. Describe the 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.

There is no duplication. No similar information is collected by the agency. No other agency collects this type of information. Each property is unique and must be assessed individually to determine if it meets the National Register criteria.

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 burden.

Collection of information is voluntary and initiated by individuals and organizations interested in having historic properties listed in the National Register. Forms are processed through the SHPOs, FPOs and THPOs, involving chief elected officials and their staffs. The agency has carefully analyzed the collection requirements to ensure that the information requested is the minimum necessary. The agency has also encouraged the use of computers, and has distributed thousands of templates to create the form, to assist respondents. Further, all historic contexts approved for MPS nominations to the National Register nationwide are available on-line to further facilitate the identification, evaluation and registration of similar properties. The expanded photographic policy implemented in March 2005 now allows for the submission of digital images as supporting documentation for nominations. This expansion will facilitate the preparation of nomination documentation and is viewed as another incremental step toward the development of a full electronic submission process for nominations.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

If information were not collected, it would not be possible to maintain the National Register list, and to administer the related Federal programs such as required Advisory Council for Historic Preservation review and comment, Federal historic preservation tax incentives, Federal project planning, and preservation grant programs. The information would not be available to States, Federal agencies, Indian Tribes, and others in applying the Federal protections and rehabilitation incentives afforded properties listed in the National Register. The information would not he available for heritage education and interpretation to provide a tangible understanding of our common heritage. Information on historic contexts contained in multiple property documentation forms would not be available to assist States, Federal agencies and Indian Tribes in planning for the identification, evaluation, and protection of historic resources.

7. Explain any special circumstances that would cause an information collection to be collected in a manner:

*requiring respondents to report information to the agency more often than quarterly;

*requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

*requiring respondents to submit more than one original and two copies of any document;

*requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years;

*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;

*requiring the use of statistical data classification that has not been reviewed and approved by OMB;

*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; or

*requiring respondents to submit propriety trade secrets, or other information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.

Not applicable.

8. If applicable, provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice, required by 5CFR 1320.8(d), 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 those comments. Specifically address comments received cost and hour burden.

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. [Please list the names, titles, address and phone numbers of persons contacted.]

Consultation with representatives of those from whom information is to be obtained or those who must compile records should consult at least once every three years – even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

The NPS published a 60-day Notice in the Federal Register soliciting public comments on July 11, 2008, (Vol. 73, No.134, Page 39984). No public comments were received.

NPS is in constant contact with respondents in the State, Federal, and Tribal historic preservation offices and in the public, concerning the National Register program, including the National Register of Historic Places Registration and Multiple Property Documentation Forms. Contact occurs through a variety of venues including professional meetings and daily phone and e-mail consultations. NPS periodically publishes National Register Bulletins which provide guidance on evaluating and documenting different types of historic resources. Each of these Bulletins is broadly distributed for comment before they are finalized. NPS routinely makes a special effort to solicit input about the program and the information collection requirements. For example, in early 1994, the program was examined as part of the National Performance Review of the Historic Preservation Fund Partnerships. In May 1995, a letter was broadly distributed in the preservation community inviting comment on suggestions that grew out of this review. A photograph requirement policy expansion draft to facilitate photographic documentation as part of the nomination package was widely distributed to the public in October 2004 soliciting comments; public comments were integrated into the policy expansion, and it was implemented in March 2005.

Following publication of the 60-day notice in the Federal Register, one request for copies of the forms and the National Register technical guidance on how to complete them was mailed out. No comments were received on the forms or the burden estimates following up that request. Over the course of the comment period, the agency contact, Lisa Deline, telephoned approximately five individuals who work with the National Register forms regularly to try and solicit comments on the burden estimates provided therein. The outreach was conducted informally and the Federal Register notice reference was given. Although no written comments were forthcoming, several individuals stated verbally that the National Register nomination preparation process varies widely and is influenced by many contributing factors. In general, there was consensus that the agency burden estimates were reasonable to meet minimum program requirements. The following persons representing State Historic Preservation Offices have extensive experience in completing the subject forms as part of their job responsibilities and shared in this consensus:

Claudette Stager

National Register Coordinator

Tennessee Historical Commission

2941 Lebanon Road

Nashville, Tennessee 37243

Telephone: 615/532-1550 x.105

Email: [email protected]

Christi Mitchell

National Register Coordinator

Maine Historic Preservation Commission

55 Capitol Street, State House Station 65
Augusta, Maine 04333
Telephone: 207/287-3123

Email: [email protected]

Greg Smith Cindy Toffelmier

National Register Coordinator National Register Coordinator

Texas Historical Commission OHP, Department of Parks & Recreation

P.O. Box 12276 Capitol Station P.O. Box 942896

Austin, Texas 78711 Sacramento, California 94296

Telephone: 512/463-6013 Telephone: 916/653-8936

Email: [email protected] Email: [email protected]

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payments or gifts are provided.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

The Secretary of the Interior is required by law to withhold from disclosure to the public information about the location, character or ownership of a historic resource if such disclosure might cause a significant invasion of privacy, risk harm to the historic resources or impede the use of a traditional religious site by practitioners. The only information collected that could be considered confidential in nature is the location of specific properties, their traditional cultural use, and the informants, such as tribal elders, who may testify in the nomination documentation to their cultural importance. Although this information is reported on the form, and necessary to establish precisely which property is listed, the NPS maintains the confidentiality of certain specific information in order to protect properties. This is particularly the case with many archeological sites and rural properties that are subject to vandalism. It is also the case with places used in traditional cultural practices. Section 304 of the National Historic Preservation Act, as amended, establishes this authority.

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.

The Secretary of the Interior is required by law to withhold from disclosure to the public information about the location, character or ownership of a historic resource if such disclosure might cause a significant invasion of privacy, risk harm to the historic resources or impede the use of a traditional religious site by practitioners. There are no questions on the forms that are of a sensitive nature in and of themselves, yet sometimes the information given that documents the historic significance of a property may be considered sensitive information. For example, in the case of historic places that are still used for traditional cultural practices, the location of the property, the identity of its specific users, and the informants, such as tribal elders, who may testify to the cultural importance of these properties are also kept confidential so as not to interfere with these traditional uses. The information recorded is given voluntarily, with the understanding that it will be confidential. Section 304 of the National Historic Preservation Act, as amended, establishes this authority.

12. Provide estimates of the hour burden of the collection of information. The statement should:

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 desirable. 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 estimates should not include burden hours for customary and usual

business practices.

*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.

*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 be included here.

Individuals and organizations seek the honor and related benefits of National Register listing and prepare nominations voluntarily. The preparation of National Register documentation varies in a myriad of ways influenced by a host of factors: it may vary considerably from case to case, measurably from place to place, and widely from historic resource to historic resource. Nominations document properties as different as a single statue or house to miles-long roadways and historic districts encompassing numerous properties. The length and breadth of nominations vary significantly as well, as does the amount of research or information gathering necessary to produce an adequate one that meets minimum Federal requirements.

Some nominations are the barest bones versions that just cross the threshold of minimum documentation, while some represent the other end of the continuum, demonstrating original research, field work and analysis and far exceeding the burden of what is minimally required by the nomination form and the National Register program. Many nominations are produced as one facet of a much larger project in which case it is inappropriate to ascribe all the research for the project overall to the preparation of the nomination form.

Nominations are submitted to the National Register by 56 SHPOs, more than one hundred FPOs, and dozens of THPOs, and they may be prepared by anyone: property owners, educators, students, cultural resource professionals, etc. For this reason, the program and its requirements have much inherent flexibility--this is also demonstrated by the length and content of nomination forms. Thus, it is impossible to come up with precise burden estimates for completing the form that apply across the board to each and every possible nomination preparation scenario. Weighing all of these complex factors, the following are reasonable estimates of average burdens on the public to fulfill minimum Federal program requirements to receive the benefit of National Register listing by completing adequate forms ranging from 18-120 hours/form, with an estimated 36 hours for the vast majority of individual forms submitted. The total number of forms submitted varies annually because nomination preparation is voluntary.

Number of National Register Nominations: 1,513 (total number of non-Federal properties listed FY ’07) and includes use of forms NPS 10-900, 10-900a, and 10-900b.

Frequency of response: 1,513 annually

Annual respondent hour burden: 55,560 hours annually

This is further broken down as shown:

Individual National Register Forms (10-900) and (10-900a Continuation Sheet) includes new nominations under existing Multiple Property Cover Documents.

State and Local Governments

Position-State/Local Governments	Hourly pay rate ($/hr est.)	Hourly rate including benefits (1.5 x hourly rate)****	Percent of time spent on nomination preparation		Weighted average ($hr)
Admin.Assist.	$11*	$17	8%		1
Historic Preservation Professional	$28**	$42	90%		38
State Historic Preservation Officer*****	$47***	$71	2%		1
Weighted Average ($/hr)				40
* Administrative Assistant, library (Department of Labor 1998, http://www.bls.gov/oes/current/oes434121.htm). ** The median wage estimates for historic preservation professions included architects, archeologists, historians, and landscape architects is $27.53 and ranges from $24.42-$32.51 per hour (Department of Labor 2008, http://www.bls.gov). *** The mean hourly wage for a chief executive of a local or state government agency ranges from $43.88 to $46.91 per hour (Department of Labor 1998, http://www.bls.gov/oes/current/oes111011.htm#ind). The higher state chief executive rate of $46.91 has been used for this analysis. **** Employer Costs for Employee Compensation-September 2007, Bureau of Labor Statistics, USDL 07-1883. http://www.bls.gov/news.release/archives/ecec_12112007.pdf ***** Includes Federal Preservation Officers and Tribal Preservation Officers

Based on these assumptions, the estimate of burden hours for state or local governments is:

1. Total burden hours for nomination research/review/completion and NR Review Board preparation (384 x 36 hours): 13,824 hours.

2. Total burden hours for nominations submitted under existing MPS Cover Documents (196 x 18 hours): 3,528 hours

3. Total annual, recurring cost (17,352 hours for nomination completion x $40): $694,080.

National Register Multiple Property Documentation Form (a.k.a. MPS Cover Document 10-900b) and (10-900a Continuation Sheet)

State and Local Governments

Position-State/Local Governments	Hourly pay rate ($/hr est.)	Hourly rate including benefits (1.5 x hourly rate)****	Percent of time spent on nomination preparation		Weighted average ($hr)
Admin.Assist.	$11*	$17	8%		1
Historic Preservation Professional	$28**	$42	90%		38
State Historic Preservation Officer*****	$47***	$71	2%		1
Weighted Average ($/hr)				40
* Administrative Assistant, library (Department of Labor 1998, http://www.bls.gov/oes/current/oes434121.htm). ** The median wage estimate for historic preservation professions included architects, archeologists, historians, and landscape architects is $27.53 and ranges from $24.42-$32.51 per hour (Department of Labor 2008, http://www.bls.gov). *** The mean hourly wage for a chief executive of a local or state government agency ranges from $43.88 to $46.91 per hour (Department of Labor 1998, http://www.bls.gov/oes/current/oes111011.htm#ind). The higher state chief executive rate of $46.91 has been used for this analysis. **** Employer Costs for Employee Compensation-September 2007, Bureau of Labor Statistics, USDL 07-1883. http://www.bls.gov/news.release/archives/ecec_12112007.pdf ***** Includes Federal Preservation Officers and Tribal Preservation Officers

Based on these assumptions, the estimate of burden hours for state or local governments is:

1. Total burden hours for nomination research/review/completion and NR Review Board preparation (50 x 120 hours): 6,000 hours.

2. Total annual, recurring cost (6,000 hours for nomination completion x $40): $240,000.

Individual National Register Forms (10-900) and (10-900a Continuation Sheet) includes new nominations under existing Multiple Property Cover Documents.

Historic Preservation Consultants

Position-Private	Hourly pay rate ($/hr est.)	Hourly rate including benefits	Percent of time spent on collection		Weighted average ($hr)
Consultants	$25.00	n/a	100%		25
Weighted Average ($/hr)				25
Based on an estimated average consultant rate (includes architects, archeologists, historians, and landscape architects.)

Based on these assumptions, the estimate of burden hours for consultants is:

1. Total burden hours for consultants for proposed nomination research/ review/completion (870 nominations x 36 hours): 31,320 hours.

2. Total annual, recurring cost (31,320 x 25): $783,000.

National Register Multiple Property Documentation Form (a.k.a. MPS Cover Document 10-900b) and (10-900a Continuation Sheet)

Historic Preservation Consultants

Position-Private	Hourly pay rate ($/hr est.)	Hourly rate including benefits	Percent of time spent on collection		Weighted average ($hr)
Consultants	$25.00	n/a	100%		25
Weighted Average ($/hr)				25
Based on an estimated average consultant rate (includes architects, archeologists, historians, and landscape architects.)

Based on these assumptions, the estimate of burden hours for consultants is:

1. Total burden hours for consultants for nomination research/review/completion (5 nominations x 120 hours): 600 hours.

2. Total annual, recurring cost (600 x 25): $15,000.

Individual National Register Forms (10-900) and (10-900a Continuation Sheet) includes new nominations under existing Multiple Property Cover Documents.

Non-profit Organizations

Position-Private	Hourly pay rate ($/hr est.)	Hourly rate including benefits	Percent of time spent on collection		Weighted average ($hr)
Consultants	$22.00	n/a	100%		22
Weighted Average ($/hr)				22
Based on an estimated average rate (includes historians, archivists, curators)

Based on these assumptions, the estimate of burden hours for non-profits:

1. Total burden hours for nonprofits for nomination research/review/completion (8 nominations x 36 hours): 288 hours.

2. Total annual, recurring cost (288 x 25): $7,200.

National Register Multiple Property Documentation Form (a.k.a. MPS Cover Document 10-900b) and (10-900a Continuation Sheet)

Non-Profit Organizations

Position-Private	Hourly pay rate ($/hr est.)	Hourly rate including benefits	Percent of time spent on collection		Weighted average ($hr)
Historians*	$22.42	n/a	100%		22
Weighted Average ($/hr)				22
Based on an estimated average rate (includes historians, archivists, curators)

Based on these assumptions, the estimate of burden hours for non-profits:

1. Total burden hours for non-profits (0 nominations x 120 hours): 0 hours.

2. Total annual, recurring cost (0 x 22): $0.

13. Provide an estimate of the total annual cost burden to respondents or record keepers

resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

*The cost estimate should be split into two components: (a) total capital and start-up cost component (annualized over its expected useful life) and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors

Including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

*If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be part of this cost burden estimate. In developing cost burden estimates agencies may consult with a sample of respondents (fewer than 10), utilize the 60 day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

*Generally estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

There are no non-hour costs.

14. Provide estimates of the 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 not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 into a single table.

The annualized cost to the Federal government is about $181,498. This is based on staff time to process and review nominations and to administer the information collection. It includes the cost of designing National Register publications and for publishing notification of pending nominations in the Federal Register (as required by public law). Also included is a portion of the maintenance for the NRIS server. A weighted average cost per hour of $66 is calculated based on the following assumptions:

Position	Grade	Hourly pay rate ($/hr est.)*	Hourly rate including benefits (1.5 x hourly rate)**	Percent of time spent on processing	Weighted average ($hr)
Historian (e.g. nomination processing)	GS-9, step 5	$27.47	$41.20	4%	2
Historian (Skilled, technical)	GS-12, step 1	$35.14	$52.71	25%	13
Historian (Skilled, technical)	GS-13, step 5	$47.36	$71.04	70%	50
Management	GS-15, step 1	$58	$87	1%	1
Weighted Average ($/hr)					66
* Salary Table 2009-DCB. http://www.opm.gov/oca/09tables/pdf/salhr.pdf ** Employer Costs for Employee Compensation-September 2007, Bureau of Labor Statistics, USDL 07-1883. http://www.bls.gov/news.release/archives/ecec_12112007.pdf

1) Total burden hours for logging in/data entry, technical review of historic resources (1513 x 1 hour): 1513 hours.

2) Total burden hours for reviewing/evaluating/researching historic resources, and nominating properties (60 x 2 hours): 120 hours.

3) Total burden hours for publishing notices (pending/weekly/DOEs) in the Federal Register (105 notices x 4 hours): 420 hours.

4) For FY 2008, the total cost of publishing notices in the Federal Register is $40,000 and for National Register Bulletin publications $6,000. Total publications: $46,000. The costs are paid by the NPS.

5) Total annual, recurring cost (2053 hours x $66 + $46,000): $181,498.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form

83-1.

The increase of 2,736 in the total burden hours is due to a more accurate estimate of the Program Office. In the process of getting the 30-Day Notice published within the Federal Register, the collection expired on January 31, 2009. The burden estimates within ROCIS changed slightly to reflect this occurrence. The 30-Day Notice was published in the Federal Register on February 3, 2009.

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.

Forms are completed as part of an ongoing program: there is no ending date. Historic names and addresses of properties pending consideration for listing in the National Register are included in the Federal Register weekly upon receipt of the applications by the NPS. This notice is necessary to allow for public comment as required by federal regulations. A list of properties entered in the National Register is available from the NPS and on-line through the Internet. The list is used by Federal, State, Tribal, and local governments; libraries; historical societies; educators; scholars; and other individuals as a record of properties which are listed in the National Register.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

Not applicable.

18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," OMB Form 83-1.

Not applicable.