May / 2009
SUPPORTING STATEMENT
(0572-0076)
RUS Specification for Quality Control and Inspection of Timber Products
This is an extension of a currently approved information collection package.
TERMS OF CLEARANCE: Terms of the previous clearance remain in effect. In accordance with 5 CFR 1320, OMB is withholding approval at this time. Prior to publication of the final rule, the agency must submit to OMB a summary of all comments related to the information collection contained in the proposed rule and the agency response. The Agency should clearly indicate any changes made to the information collection as a result of these comments.
AGENCY RESPONSE TO THE TERMS OF CLEARANCE: RUS published a proposed rule to eliminate the requirement of borrowers to send in an annual summary report and reserve stock notices and treaters to send in annual notices. Public comments were received which are currently under consideration by the Agency as it continues to work on revising these bulletins. The Agency intends to publish a final rule to implement these changes as well as comply with OMB’s terms of clearance.
A. Justification
1. Explain the circumstances that make the collection of information necessary.
The Rural Utilities Service (RUS) is a credit agency of the U.S. Department of Agriculture. It makes mortgage loans and loan guarantees to finance electric, telecommunications, and water and waste facilities in rural areas. Loan programs are managed in accordance with the Rural Electrification Act (RE Act) of 1936, 7 U.S.C. 901 et seq., as amended.
RUS has a tremendous amount of interest in loan security and protection of the Government’s interest over the long term life of a loan, which is generally secured by a first mortgage and amortized over a period of up to 35 years. Therefore, RUS necessarily has a strong interest in the business, financial, and operating aspects of its borrowers. Prior to receiving loan funds, an RUS borrower must enter into a loan contract with RUS. In accordance with Article V, Section 5.14 of the loan contract, “the borrower shall use design standards, construction standards and lists of acceptable materials in conformance with RUS Regulations.”
In order to ensure the security of loan funds, adequate quality control of timber products is vital to loan security on electric power systems where hundreds of thousands of wood poles and crossarms are used. Since RUS and its borrowers do not have the expertise or manpower to quickly determine imperfections in the wood products or their preservatives treatment, they must obtain the services of an inspection agency to insure that the specifications for wood poles and crossarms are being met. 7 CFR 1728.202 and RUS Bulletin 1728H-702 provide RUS borrowers with policy guidance on the quality control and inspection of timber products.
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.
RUS is currently in the process of revising these bulletins to eliminate the requirement of borrowers to send in an annual summary report and reserve stock notices. A proposed rule was published in the Federal Register (73 FR 56513) on September 20, 2008. The Agency is currently reviewing public comments and preparing a final rule.
RUS uses this information in verifying acceptability of poles and crossarms purchased by RUS borrowers. RUS cross references borrowers and treating plants so that if during an inspection trip by an RUS staff member a plant is found in violation of the specification, RUS can quickly determine which borrowers purchased from the plant and take appropriate action to correct the violation. The information required by this collection is as follows:
Annual Summary of Purchases from Borrowers
Each RUS borrower shall submit to the Director of the Electric Staff Division in January of each year a list of plants from which it obtained poles or crossarms during the preceding calendar year.
Use of Inspection Agencies to Inspect Poles
7 CFR 1728.202 provides that the purchaser or the treating company may obtain the services of an inspection agency to perform certain services. This inspection is the industry standard and would normally be performed even if RUS did not specify it. This requirement is necessary because timber, by nature, is non-uniform. RUS borrowers design their systems based on assumptions about the strength and durability of the poles they purchases. These assumptions are only valid if limitation are imposed on the defects in the wood and if minimum levels of preservation are retained in the wood in its treatment. Since RUS borrowers are generally not experts in wood quality, it is essential that this verification work be contracted to someone who is. Also, treating plants are frequently a great distance from the borrower service area.
Reserve Stock Notices from Treaters
The Treaters of the timber products must notify RUS each year that they will be treating poles for the upcoming year.
Test Reports from Inspectors
7 CFR 1728.202(i) requires that copies of test reports on various preservatives must accompany each charge (a charge being a load of poles treated at the same time in a pressure cylinder). This is the standard operating procedure in the treated wood industry. However, RUS feels it is important enough to justify requiring it in this specification. Test reports are needed so that the purchaser, the inspector, and RUS will be able to spot check the general accuracy of the tests.
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.
Rural Development is committed to meeting the requirements of the E-Government Act, which requires Government agencies in general to provide the public the option of submitting information or transacting business electronically to the maximum extent possible. The agency is currently working on a final rule which will reduce the burden on respondents and which may eliminate the need for developing an electronic method for collecting data.
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.
The required information is specific to each borrower and/or each treating plant, therefore, there is no duplication of information.
5. If the collection of information impacts small businesses or other small entities (item 5 of OMB Form 83-1), describe any methods used to minimize burden.
All but a few electric borrowers meet the Small Business Administration criteria for a small business. RUS has made every effort to ensure that burden on these small entities is the minimum necessary to effectively administer the Agency programs.
6. Describe the consequences to Federal program or policy activities if the collection is not conducted or conducted less frequently, as well as any technical or legal obstacles to reducing burden.
RUS could not conduct the collect information less frequently and continue to ensure that borrower’s are using quality timber products.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
a. Requiring respondents to report information more than quarterly.
There is no requirement to respond more than quarterly.
b. Requiring written responses in less than 30 days.
There is no requirement to respond in less than 30 days.
c. Requiring more than an original and two copies.
There is no requirement for more than an original and two copies.
d. Requiring respondents to retain records for more than 3 years.
Record retention requirements are in accordance with 7 CFR 1767.
e. That is not designed to produce valid and reliable results that can be generalized to the universe of study.
This collection does not involve a survey.
f. Requiring use of statistical sampling which has not been reviewed and approved by OMB.
This collection does not involve statistical sampling.
g. Requiring a pledge of confidentiality.
There is no requirement for a pledge of confidentiality.
h. Requiring submission of proprietary trade secrets.
There is no such requirement.
8. If applicable, identify the date and page number of publication in the Federal Register of the agency’s notice soliciting comments on the information collection. Summarize public comments received and describe actions taken by the agency in response to these comments. 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, reporting format (if any), and on data elements to be recorded, disclosed, or reported.
As required by 5 CFR 1320.9(d), a Notice to request public comments was published on April 2, 2009, 74 FR 14955 (copy attached). No public comments were received.
RUS maintains close contact with borrowers through general field representatives and a headquarters staff. RUS also conducts seminars for its borrowers. Suggestions are always considered by the Agency.
9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.
No such decision has been made.
10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or Agency policy.
No assurances of confidentiality have bee provided.
11. Provide additional justification for any question of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private.
There are no questions of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information.
The hour burden associated with information collection is estimated to be 40,363 hours with 400 hours of record retention and the estimated costs are as follows:
Annual Summary of Purchases from Borrowers
.5 hr X 700 responses = 350 hours X $ 20/hr = $7,000.
Use of Inspection Agencies to Inspect Poles and Inspection of Reports
This burden consists of the inspection of about 40,000 lots of poles by 25 different inspection agencies (poles are inspected in lots of about 50 poles). A lot of poles takes about 1 hour to inspect, including the time to prepare the accompanying report. It is estimated that it takes 1 minute of record retention time per report.
1 hr X 40,000 responses = 40,000 hours X $100/hr = $400,000
.01 hr X 40,000 reports = 400 hours total recordkeeping/25 recorkeepers = 16 hours per
recordkeeper
Reserve Stock Notices from Treaters
Each of the Treaters participating with RUS borrowers sends RUS a letter each year stating that they will be treating poles during the upcoming year. There are currently 25 treaters working with RUS borrowers.
.5 hr X 25 responses = 12.5 hours X $20/hr = $250
Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information.
Total capital and start-up cost component (annualized over its expected useful life); and
There are no capital and start-up costs associated with this collection.
(b) Total operation and maintenance and purchase of services component.
There are no operation and maintenance or purchase of services costs association with this collection.
14. Provide estimates of annualized cost to the Federal Government.
The cost to the Federal Government is estimated at $4,955 and was derived as follows:
Review of Annual Summary of Purchases
Professional Time: 700 responses X .08 hours X $47.21/hr (GS 13, step 5) = $2643.76
Clerical Time: 700 responses X .01 hours X $20.14/hr (GS 6, step 5) = $ 140.98
Total Cost for Review of Annual Summary of Purchases $2784.74
Processing of Reserve Stock Notices from Treaters
Professional time: 700 responses X .08 minutes X $47.21/hr (GS 13, step 5) = $2643.76
Clerical Time: 700 responses X .01 minutes X $20.14/hr (GS 6, step 5) = $ 140.98
Total cost for Processing of Reserve Stock Notices from Treaters $ 2784.74
Both items require review of the submitted data by a Professional-type position and entry into a database by a Clerical-type position.
15. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of the OMB Form 83-1.
This is an extension of a currently approved collection.
16. For collection of information whose results will be published, outline plans for tabulation and publication.
There are no plans to publish information.
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.
No such approval is sought.
18. Explain each exception to the certification statement identified in item 19 on OMB 83-1.
There are no exceptions to the certification statement.
Collection of Information Employing Statistical Methods.
This information collection does not employ statistical methods.
| File Type | application/msword |
| File Title | May / 2009 |
| Author | MaryPat.Daskal |
| Last Modified By | MaryPat.Daskal |
| File Modified | 2009-04-17 |
| File Created | 2009-04-17 |