Supporting Statement 1660-0068 2-11-09

February 11, 2009

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660 - 0068

Title: Federal Hotel and Motel Fire Safety Declaration Form

Form Number(s): FF75-13

General Instructions

A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When Item 17 or the OMB Form 83-I is checked “Yes”, Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

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. Provide a detailed description of the nature and source of the information to be collected.

Public Law 101-391, Hotel and Motel Fire Safety Act of 1990 (HotMot), requires the United States Fire Administration (USFA)¹ to establish and maintain a National Master List (NML) of hotels and motels and other places of public accommodations under Section 28(a) (15 USC 2224). The collected information is public and readily available through advertising directories and telephone books. The information includes the name of the property, telephone numbers, manager, web site, and fire safety equipment on the property.

State Governors are required under Public Law 101-391 to provide FEMA a list of qualified properties for inclusion on the Hotel and Motel National Master List (NML). Using an electronic web based system, hotels and motels voluntarily submit an application to the State for approval and inclusion in the NML. Applications coming from 27 States and Territories go directly to the Governor’s designee for action and are then electronically forwarded to FEMA. The remaining States and Territories accept the application declaration and the property is automatically listed in the NML.

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 collection. Provide a detailed description of: how the information will be shared, if applicable, and for what programmatic purpose.

Federal employees on official travel are required to stay in properties listed on the NML. The Administrator of the General Services Administration (GSA) may not include in any directory, which list lodging …that does not meet the requirements of the fire prevention and control guidelines described in Section 29 of the Fire Prevention Act of 1974.

The information collected is available to the general public, Federal employees, and the hotel and motel industry. Those properties on the NML have certified their compliance with the requirements of PL 101-391 and are therefore eligible to accommodate the Federal traveler while on official travel.

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.

The primary method of registering a property on the NML is by submitting an application on the USFA web site at www.usfa.dhs.gov/applications/hotel. Conventional means for submitting an application are still available via USPS and Fax. Ninety percent of applications are expected via online registration.

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4. Describe 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 known commercially available listing of the information similar to that required under PL 101-391.

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.

There is no known impact. The one-time application process takes about 15 minutes per application. Those applicants who choose to apply online will require a personal computer with internet connection.

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

If this information is not collected and made available, it would put an undue burden on the Federal traveler to locate accommodations that meet the requirements of PL 101-391 and the Fire Prevention and Control Act of 1974.

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

This information collection is conducted in a manner consistent with the guidelines in 5CFR 1320.5(d) (2).

1. Requiring respondents to report information to the agency more

often than quarterly.



 (b) Requiring respondents to prepare a written response to a

collection of information in fewer than 30 days after receipt of it.



3. Requiring respondents to submit more than an original and two

copies of any document.



3. Requiring respondents to retain records, other than health,

medical, government contract, grant-in-aid, or tax records for more than three years.



3. 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.



 (f) Requiring the use of a statistical data classification that has not

been reviewed and approved by OMB.

 (g) 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.



 (h) Requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law.



8. Federal Register Notice:



 a. Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice 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 these comments. Specifically address comments received on cost and hour burden.



A 60-day Federal Register Notice inviting public comments was published on November 28, 2008, Volume 73, Number 230, pp. 72496. One comment was received regarding continued collection of the information. The response generated is that the collection will be continued as per the request for approval for an additional 3 years. See attached copy of the published notice included in this package.

 b. 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.

The USFA has offered the Society of Government Travel Professionals (SGTP) the opportunity to comment on the form. Some SGTP suggestions were incorporated in form.

c. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities 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 information collection is intended as a one time effort, although information feedback on the data collection are accepted and reviewed and the sender is responded to.

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

FEMA does not provide payments or gifts to respondents in exchange for a benefit sought.

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



Participation in the Hotel and Motel Fire Safety Program is voluntary and the information collected is of a non-confidential nature. The information is business-related (hotel or motel entity) and does not involve personal identifiable information. Participants are aware of the voluntary nature of registration and the intended publication on the USFA web site of the information contained in the NML. There are no assurances of confidentiality provided to the respondents for this information collection.



11. Provide additional justification for any question 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.

There are no questions of sensitive nature.

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



 a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated for each collection instrument (separately list each instrument and describe information as requested). 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 desired. 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.

It is estimated that 2000 lodging managers (Business or other For-Profit) will complete 1 FEMA Form 516-1 (formerly FEMA Form 75-13) per respondent and that the average burden per response will be 15 minutes (.25 hours), for a total of 500 burden hours.

It is estimated that 27 State, local or Tribal Government managers will review an average of 33 responses from hotels and motels, and that the total time per response will be 20 minutes (.33 hours) to review each FEMA Form 516-1 (formerly FEMA Form 75-13) for a total of 297 burden hours.

 b. 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.

Non-applicable

c. Provide an estimate of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost to the respondents of contracting out or paying outside parties for information collection activities should not be included here. Instead this cost should be included in Item 13.

Type of Respond-ent	Form Name / Form Number	No. of Respon-dents	No. of Respon-ses per Respon-dent	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Total Number of Responses	Avg. Hourly Wage Rate	Total Annual Respon-dent Cost
Business or other For-Profit	Federal Hotel and Motel Fire Safety Declaration Form / FEMA Form 516-1	2,000	1	15 minutes (.25 Hour)	500	2000	$23.47	$11,735.00
State, local or Tribal Government	Review of FEMA Form 516-1	27	33	20 Minutes (.33 Hour)	297	891	$26.84	7,971.48
Total		2,027			797	2,891		$19,706.48

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for lodging manager is estimated to be $23.47 per hour; therefore, the estimated burden hour cost to respondent’s government managers is estimated to be $11,735.00 annually.

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for government manager is estimated to be $26.84 per hour; therefore, the estimated burden hour cost to respondent’s government managers is estimated to be $7,971.48 annually.

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. (Do not include the cost of any hour burden shown in Items 12 and 14.)

There are no record keeping, capital, start-up or maintenance costs associated with this information collection.

The cost estimates should be split into two components:

a. Operation and Maintenance and purchase of services component. These estimates should take into account cost associated with generating, maintaining, and disclosing or providing 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.

b. Capital and Start-up-Cost should include, among other items, preparations for collecting information such as purchasing computers and software, monitoring sampling, drilling and testing equipment, and record storage facilities.

Annual Cost Burden to Respondents or Record-keepers

Data Collection Activity/Instrument	*Annual Capital Start-Up Cost (investments in overhead, equipment and other one-time expenditures)	*Annual Operations and Maintenance Cost (such as recordkeeping, technical/professional services, etc.)	Annual Non-Labor Cost (expenditures on training, travel and other resources)	Total Annual Cost to Respondents
Total	N/A

14. Provide estimates of 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 have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.

Annual Cost to the Federal Government

Item	Cost ($)
Contract Costs - Data entry	$22,000
Staff Salaries [ 1 of GS 12 employees spending approximately 50% of time annually reviewing data received for this data collection]	$35,000
Facilities [cost for renting, overhead, etc. for data collection activity]
Computer Hardware and Software [cost of equipment annual lifecycle]
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]
Travel
Printing [number of data collection instruments annually]
Postage [annual number of data collection instruments x postage]
Other
Total	$57,000

 15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I in a narrative form. Present the itemized changes in hour burden and cost burden according to program changes or adjustments in Table 5. Denote a program increase as a positive number, and a program decrease as a negative number.

A "Program increase" is an additional burden resulting from a federal government regulatory action or directive. (e.g., an increase in sample size or coverage, amount of information, reporting frequency, or expanded use of an existing form). This also includes previously in-use and unapproved information collections discovered during the ICB process, or during the fiscal year, which will be in use during the next fiscal year.

A "Program decrease", is a reduction in burden because of: (1) the discontinuation of an information collection; or (2) a change in an existing information collection by a Federal agency (e.g., the use of sampling (or smaller samples), a decrease in the amount of information requested (fewer questions), or a decrease in reporting frequency).

"Adjustment" denotes a change in burden hours due to factors over which the government has no control, such as population growth, or in factors which do not affect what information the government collects or changes in the methods used to estimate burden or correction of errors in burden estimates.

Itemized Changes in Annual Burden Hours
Data collection Activity/Instrument	Program Change (hours currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (hours currently on OMB Inventory)	Adjustment (New)	Difference
FEMA Form 516-1	1,182	797	-385
Total(s)	1,182	797	-385

Explain:

The difference in the Annual Burden Hours is due to two separate actions. First, the prior
PRA submission in 2006 had an incorrect burden calculation in Question 12. The total number of respondents was 2,356 and the average burden per respondent was indicated to be 15 minutes (.25 hours). Multiplying 2,356 respondents by 15 minutes (.25 hours) is 35,340 minutes (589 hours). However, the total burden hours listed for the submission in 2006 was 1,182 hours, an overstatement of 593 hours.

Second, the current total Annual Burden Hours requested is 797, reflecting an update to the expected annual respondents (2027) that the program expects to respond. The Annual Hours Burden for this submission are calculated as 2000 x 15 minutes (.25 hour) x 1 response per respondent = 30,000 minutes (500 hours), and 27 x 20 minutes (.33 hour) x 33 responses per respondent = 17,820 minutes (297 hours). The total Annual Burden Hours requested for this submission is 797 hours, subtracted from the 1,182 Annual Burden Hours submitted at the last request results in a net difference of 385 Annual Burden Hours.

Itemized Changes in Annual Cost Burden
Data collection Activity/Instrument	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New)	Difference
FEMA Form 516-1	$29,550.00	$19,706.48	-$9,843.52
Total(s)	$29,550.00	$19,706.48	-$9,843.52

Explain:



The changes to the Annual Cost Burden are due to two separate actions. First, as the Annual Burden Hours were overstated on the 2006 PRA submission, the associated Annual Cost Burden was also overstated at $29,550.00. The actual cost should have been 589 Annual Burden Hours x BLS rate of $25.00 = $14,725.00, for a difference of $14,825.00.

Second, the annual cost burden has been updated to reflect more recent BLS data, for a total requested Annual Cost Burden of $19,706.48. Taking the original cost burden of $29,550.00 and subtracting the current submission cost burden of $19,706.48 results in a difference of $9,843.52.



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.



FEMA does not intend to employ the use of statistics or the publication thereof for this information collection.

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

FEMA will display the expiration date for OMB approval of this information collection.



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

 FEMA does not request an exception to the certification of this information collection.

B. Collections of Information Employing Statistical Methods.



When Item 17 on the Form OMB 83-I is checked “Yes”, the following documentation should be included in the Supporting Statement to the extent it applies to the methods proposed:

THERE IS NO STATISTICAL METHODOLOGY INVOLVED IN THIS COLLECTION.

1 The USFA is currently a Directorate under FEMA and the Department of Homeland Security.

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