REV FINAL supporting statement 12 16 2009 Secure Rural Schools[1] v2

The Supporting Statement for OMB 0596-NEW

SECURE RURAL SCHOOLS ACT

January 2010

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 USDA Forest Service is requesting OMB approval to collect information from counties receiving funds under Title III of Secure Rural Schools and Community Self-Determination Act. The information will certify and describe the amounts expended and the uses of the funds during the applicable year. The Department of Interior, Bureau of Land Management (BLM), will coordinate on this information collection where the BLM administers Federal lands covered by the Act.

The Secure Rural Schools and Community Self-Determination Act of 2000 (the Act), reauthorized in Public Law 110-343, requires the appropriate official of a county that receives funds under Title III of the Act to submit to the Secretary concerned (the Secretary of Agriculture or the Secretary of the Interior, as appropriate) an annual certification that the funds have been expended for the uses authorized under section 302(a) of the Act. The entire provision reads as follows:

SEC. 303. CERTIFICATION.

(a) IN GENERAL.-Not later than February 1 of the year after the year in which any county funds were expended by a participating country, the appropriate official of the participating country shall submit to the Secretary concerned a certification that the county funds expended in the applicable year have been used for the uses authorized under section 302(a), including a description of the amounts expended and the uses for which the amounts were expended.

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.

1. What information will be collected, reported or recorded? (If there are pieces of information that are especially burdensome in the collection, a specific explanation should be provided.)

The information will include the amount of Secure Rural Schools Act Title III funds expended in the applicable year and the uses for which the amounts were expended, referencing the authorized categories, and terminology used in section 302(a) of the Act. Specifically, the appropriate official will report the amount of Title III funds expended in the applicable year in these categories:

1. To carry out activities under the Firewise Communities program, described at www.firewise.org.

2. To reimburse the participating county for emergency services performed on Federal land and paid for by the participating county.

3. To develop community wildfire protection plans in coordination with the appropriate Secretary or designee.

The information collection will identify the participating county and the year in which the expenditures were made and will include the name, title, and signature of the official certifying that the expenditures were for uses authorized under section 302(a) of the Act, and the date of the certification.

The certification will include a statement that all expenditures were for proposals that had a publication and comment period and were submitted to any resource advisory committee for the county, as described in section 302(b) of the Act.

2. From whom will the information be collected? If there are different respondent categories (e.g., loan applicant versus a bank versus an appraiser), each should be described along with the type of collection activity that applies.

The information will be collected from the appropriate official in each county participating in Secure Rural Schools Act Title III payments. For the fiscal year 2008 payment, 344 counties or boroughs in 34 states participated in Forest Service Title III payments, resulting in funding of $26.4 million available beginning in 2009. Sixteen counties in Oregon received additional funding of $8.6 million from the Bureau of Land Management program. The determination of the appropriate certifying official is at the discretion of the county and borough and will vary depending on county or borough organization. For unorganized boroughs in Alaska, the appropriate state official may provide the information.

3. What will this information be used for? - provide ALL uses

The information will be used to verify that participating counties have certified that funds were expended as authorized in the Act. The verification will not rely on statistical analysis. The information in the certification documents may be summarized to inform reports to Congress or others with oversight authority. The information collected may be shared with the Department of the Interior in relation to its Payments in Lieu of Taxes (PILT) program, and with the Bureau of Land Management (BLM) which administers Federal lands in the State of Oregon covered by the Act. See additional discussion under item 4.

4. How will the information be collected (e.g., forms, non-forms, electronically, face-to-face, over the phone, over the Internet)? Does the respondent have multiple options for providing the information? If so, what are they?

The information will be collected in the form of conventional correspondence such as a letter and, at the respondent’s option, attached tables or similar graphic display. At the respondent’s discretion, the information may be submitted by hard copy and/or electronically scanned and included as an attachment to electronic mail. Public comments received have specifically asked for an optional form to record and present required data. An optional form was created and is presented in this package to be used per user’s discretion.

5. How frequently will the information be collected?

The information will be collected annually beginning February 1, 2010 and is expected to continue through February 2014. The Act requires the reporting by February 1^st of the year after the calendar year in which any Title III county funds were expended by the participating county. The first report is due on February 1, 2010. The reporting requirement continues until the February following the calendar year in which any appropriately obligated funds were expended. The Act requires that any Title III county funds not obligated by September 30, 2012 shall be returned to the U.S. Treasury. Funds properly obligated by September 30, 2012 may be spent in the following calendar year or later.

6. Will the information be shared with any other organizations inside or outside USDA or the government?

The information may be shared with the Department of the Interior, the Bureau of Land Management, Congress, and other interested parties who request it.

7. If this is an ongoing collection, how have the collection requirements changed over time?

This is a new collection of information.

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 information will be collected in form of conventional hard copy correspondence and/or as an attachment to electronic mail.

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 Department of Agriculture (Forest Service) and the Department of the Interior are coordinating to ensure this information collection for implementation of the Secure Rural Schools Act would not be duplicative of information already collected by the Department of the Interior relative to its PILT program (OMB 1093-0005.)

The Department of Agriculture (Forest Service) and the Bureau of Land Management (BLM) are coordinating on this information collection because the BLM administers Federal lands in the State of Oregon covered by the Act. For fiscal year 2008, 16 Oregon counties received Title III funds associated with lands administered by the BLM. Of these 16 counties, 13 also received Title III funds associated with separate payments for lands administered by the Forest Service. The BLM will collect similar but separate information from these 16 counties concerning expenditures related to the separate BLM payment. To facilitate the information collection from these counties, the Forest Service has authorized DOI/BLM to participate in this information collection.

The DOI and BLM points of contact are listed below:

Table 1

William Howell DOI PILT coordinator 202 208-3157 [email protected] www.doi.gov/pilt/	Jon Menten BLM, Washington, DC 202 912-7234 [email protected]
Lindsey G Babcock BLM OR/WA State Office 503 808-6451 [email protected]	Sally Cresci BLM, Denver, CO 303 236-0144 [email protected]

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The information is not being collected from small businesses. Some of the counties and boroughs required by the Act to supply this information have populations of less than 50,000 people. In an effort to minimize the burden on counties, the Department of Agriculture has carefully requested the collection of only the information required by the Act.

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.

The language in the Act specifically requires counties to certify that Title III funds were used as authorized in the Act.

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

• Requiring respondents to report information to the agency more often than quarterly;

There are no anticipated circumstances in which the counties would be required to report this information more often than once a year.

• Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

Participating counties are currently aware of the requirement to certify Title III expenditures and expect to receive instructions on the information collection well in advance of the first reporting deadline of February 1, 2010.

• Requiring respondents to submit more than an original and two copies of any document;

There are no anticipated circumstances in which the counties would be required to submit more than the original of the reporting documents.

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

Respondents would be expected to retain records throughout the life of the program, 2010 through 2014.

• 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;

The information collected will not be used in a statistical survey.

• Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

The information collected will not include 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

The information collection does not include a pledge of confidentiality.

• 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.

There are no special circumstances that would require respondents to submit proprietary trade secret or other confidential information. The collection of information will be conducted in a manner consistent with the guidelines in 5 CFR 1320.6.

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 5 CFR 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 these comments. Specifically address comments received on cost and hour burden.

The Federal Register 60-day Notice for the renewal of this information collection was published on Monday, September 14, 2009, in Volume 74, Number 176, on pages 46967-46968. Two comments were received, both commenting on the need for a standardized form.

The first comment received from the County Commissioners of Idaho County on November 10, 2009. The letter reads, in part, as follows, “Burdens can best be reduced by carefully looking at the value of any added data needs. A Nationally developed check sheet that would simply answer questions could reduce the effort.” Additionally, County Commissioners commented on the lack of “value” the data would provide the Federal Government and how compiling the information would “double” the current burden on respondents. Since the information collected is mandated by The Secure Rural Schools and Community Self-Determination Act of 2000, respondents who receive Title III funds are required to certify that the county funds expended in the applicable year have been used for the uses authorized.

The second comment received from Sheila Unger, representing the Lewis County Commissioners, wrote, “Lewis County would not object to a certification procedure but we believe in being mindful of paperwork. We are hoping the certification process would consist of a form we could fill out and email to the Forest Service. We would like see a concise reporting form containing all pertinent information and would not take hours to compile the information. This process would save both of us time.”

The Forest Service has taken these comments into consideration and developed an optional form for respondents to certify that the county funds have been used for authorized uses.

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 record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 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 Forest Service consulted with representatives of the National Association of Counties; the National Forest Counties and Schools Coalition; and the Organization of Oregon and California Counties. These organizations represent or coordinate with most of the counties that will be required to certify the appropriate expenditure of Title III funds.

The following individuals were consulted:

1. Ryan Yates, National Association of Counties, (202) 942-4207, [email protected], website: www.naco.org;

2. Bob Douglas, National Forest Counties and Schools Coalition, (530) 527-0666, [email protected], website:  www.forestco.net; and

3. Rocky McVay, Association of O&C Counties, (541) 412-1624, [email protected], website: 

These three were given an opportunity to view the two comments received and to provide any additional comments from their respective organizations. Mr. Yates concurred with the intention to make the information collection as simple and convenient as possible to minimize the burden on county officials. He said an optional form may be helpful, as suggested in the two comments. Mr. Douglas and Mr. McVay had previously forwarded the Federal Register notice and related information to their member counties and did not provide any additional comments.

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

Neither the Department of Agriculture nor the Department of the Interior anticipates payments or gifts to respondents.

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

No information covered by a Privacy Act System of Records, Personally Identifiable Information, or other confidential information covered by a statute, regulation, or agency policy will be collected.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or 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.

This information collection does not include any questions of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, or other matters commonly considered private.

12. Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form.

a) Description of the collection activity

b) Corresponding form number (if applicable)

c) Number of respondents

d) Number of responses annually per respondent,

e) Total annual responses (columns c x d)

f) Estimated hours per response

g) Total annual burden hours (columns e x f)

Table 2a

(a) Description of the Collection Activity associated with Forest Service (FS) payments	(b) Form Number	(c) Number of respondents	(d) Number of responses annually per respondent	(e) Total annual responses (c x d)	(f) Estimate of burden hours per response	(g) Total annual Burden Hours (e x f)
Review annual expenditures of title III funds	N.A.	344	1	344	3	1032
Prepare certification correspondence and related documents	N.A.	344	1	344	1	344
Totals or summary associated with FS payments	---	344	1	344	4	1376

Table 2b

(a) Description of the Collection Activity associated with Bureau of Land Management (BLM) payments	(b) Form Number	(c) Number of respondents	(d) Number of responses annually per respondent	(e) Total annual responses (c x d)	(f) Estimate of burden hours per response	(g) Total annual Burden Hours (e x f)
Review annual expenditures of title III funds	NA	16	1	16	3	48
Prepare certification correspondence and related documents	NA	16	1	16	1	16
Totals or summary associated with BLM payments	---	16	1	16	4	64

• Record keeping burden should be addressed separately and should include columns for:

a) Description of record keeping activity:

b) Number of record keepers:

c) Annual hours per record keeper:

d) Total annual record keeping hours (columns b x c):

Table 3a

(a) Description of record keeping activity associated with Forest Service (FS) payments	(b) Estimated number of record keepers	(c) Estimated annual hours per record keeper	(d) Total estimated annual record keeping hours (b x c)
Maintain records of approved proposals	344	4	1376
Maintain records of expenditures for each approved proposal	344	16	5504
Totals or summary associated with FS payments	344	20	6880

Table 3b

(a) Description of record keeping activity associated with Bureau of Land Management (BLM) payments	(b) Estimated number of record keepers	(c) Estimated annual hours per record keeper	(d) Total estimated annual record keeping hours (b x c)
Maintain records of approved proposals	16	4	64
Maintain records of expenditures for each approved proposal	16	16	256
Totals or summary associated with BLM payments	16	20	320

The total estimated annual hour burden is 8,640 hours.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

Table 4a

(a) Description of the Collection Activity associated with Forest Service (FS) payments	(b) Estimated total annual burden on respondents (Hours)	(c)* Estimated average wage per hour	(d) Estimated annual cost to all respondents
Review annual expenditures of title III funds	1032	$38.96	$40,207
Prepare certification correspondence and related documents	344	$38.96	$13,402
Maintain records of approved proposals	1376	$38.96	$53,609
Maintain records of expenditures for each approved proposal	5504	$38.96	$214,436
Totals associated with FS payments	8256	$38.96	$321,654

* Estimated hourly wage estimate is from Bureau of Labor Statistics, National Compensation Survey for state and local government workers, March 2009, http://data.bls.gov/cgi-bin/print.pl/news.release/ecec.htm. The wage per hour is $25.97. The Benefit Multiplier for state and local government workers is 1.5x which can be found at http://www.bls.gov/news.release/pdf/ecec.pdf. .

Table 4b

(a) Description of the Collection Activity associated with Bureau of Land Management (BLM) payments	(b) Estimated total annual burden on respondents (Hours)	(c)* Estimated average wage per hour	(d) Estimated annual cost to all respondents
Review annual expenditures of title III funds	48	$38.96	$1,870
Prepare certification correspondence and related documents	16	$38.96	$623
Maintain records of approved proposals	64	$38.96	$2,493
Maintain records of expenditures for each approved proposal	256	$38.96	$9,974
Totals associated with BLM payments	384	$38.96	$14,961

* Estimated hourly wage estimate is from Bureau of Labor Statistics, National Compensation Survey for state and local government workers, March 2009, http://data.bls.gov/cgi-bin/print.pl/news.release/ecec.htm. The wage per hour is $25.97. The Benefit Multiplier for state and local government workers is 1.5x which can be found at http://www.bls.gov/news.release/pdf/ecec.pdf. Total cost to respondents in 4a and 4b is $336,614.

13. Provide estimates 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 estimates should be split into two components: (a) 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.

There are no identifiable capital and start-up costs. There are no identifiable operation and maintenance costs.

14. Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

The response to this question covers the actual costs the agency will incur as a result of implementing the information collection. The estimate should cover the entire life cycle of the collection and include costs, if applicable, for:

• Employee labor and materials for developing, printing, storing forms

• Employee labor and materials for developing computer systems, screens, or reports to support the collection

• Employee travel costs

• Cost of contractor services or other reimbursements to individuals or organizations assisting in the collection of information

• Employee labor and materials for collecting the information

• Employee labor and materials for analyzing, evaluating, summarizing, and/or reporting on the collected information

Table 5a

Action item associated with Forest Service (FS) payments	Personnel	GS grade	Hourly rate*	Estimated hours	Estimated annual cost to government
Employee labor for developing information collection instructions including coordinating with other agencies	Program manager and others	12-15	$60	40	$2400
Employee labor for reviewing and approving information collection instructions	ORMS, OGC, NRE	14-15	$60	20	$1200
Employee labor for collecting the information annually for four years	Program manager	14	$60	8	$480
Employee labor for analyzing, evaluating, summarizing, and/or reporting on the collected information annually for four years	Program manager	14	$60	40	$2400
Totals associated with FS payments	--	--	--	108	$6480

Table 5b

Action item associated with Bureau of Land Management (BLM) payments	Personnel	GS grade	Hourly rate*	Estimated hours	Estimated annual cost to government
Employee labor for coordinating with other agencies	Program manager and others	12-15	$60	10	$600
Employee labor for reviewing and approving information collection instructions	Program managers and others	14-15	$60	3	$180
Employee labor for collecting the information annually for four years	Program managers	14	$60	2	$120
Employee labor for analyzing, evaluating, summarizing, and/or reporting on the collected information annually for four years	Program managers	14	$60	10	$600
Totals associated with BLM payments				25	$1,500

* For Table 5a & 5b: Estimated hourly wage is approximated from Federal Salary Table 2009-GS-DCB. Government’s hourly wage rate in the chart includes a multiplier of 1.3x. The multiplier was applied to account for employee benefits, http://data.bls.gov/cgi-bin/print.pl/news.release/ecec.htm.

15. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of OMB form 83-I.

This is a new information collection.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

There are no plans for formal printed or electronic publication of the information collected.

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.

The optional form will display the expiration date and the OMB approval number.

18. Explain each exception to the certification statement identified in item 19, "Certification Requirement for Paperwork Reduction Act."

There are no exceptions to the Paperwork Reduction Act.

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