3090-0204-Justification

3090-0204-Justification.doc

GSAR Part 552.211-82 Notice of Shipment & Part 552.211-78 Commercial Delivery Schedule Clause and Notice of Shipment

OMB: 3090-0204

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Supporting Statement for Paperwork Reduction Act Submission

3090-0204 – Commercial Delivery Schedule Clause and Notice of Shipment


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 General Services Administration’s Federal Supply Service (FSS) directs and manages the Federal Supply Schedule program. Pursuant to 41 USC 259(b)(3), the Program provides Federal agencies with a simplified process of acquiring commercial supplies and services. FSS awards contracts to commercial firms under terms and conditions that mirror commercial practices for the supplies and services. In order to ensure the Government obtains the supplies within the respondent’s commercial delivery timeframe, the respondent must provide the information requested in the clause, Commercial Delivery Schedule.


The Federal Acquisition Regulation 42.1406-1 and General Services Administration Acquisition Regulation 511.404(a)(5) provide that a contracting officer may use a Notice of Shipment clause when it is in the Government’s interest to have a supply contractor furnish a notice of shipment. Such a notice is necessary when preparations need to be made for docking arrangements, storage, trans-shipment of materials handling equipment of supplies and equipment upon delivery, labor and inside delivery at destination.


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.


Contracting Officers use the information in the commercial delivery schedule clause to determine that the delivery timeframe offered to the Government is consistent with the respondent’s commercial practice. The notice of shipment clause requires a supply contractor to furnish a notice of shipment to the Government if specified in an order placed under the contract. The advance notice will allow the Government to prepare for storage, transportation, or equipment requirements prior to delivery.


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.


We use improved information technology to the maximum extent practicable. Where both the General Services Administration and contractors are capable of electronic interchange, the contractors may submit information requirements electronically.

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 information requested is required in response to every Federal Supply Schedule solicitation for supplies. The information is provided in a standard clause and there is no duplication. Similar information is not available elsewhere.


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


The burden applies equally to small organizations that want a Schedule contract and is the minimum necessary to meet the specific program objectives.


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.


Specific Schedule program objectives would not be met if FSS is not able to collect information about a respondent’s commercial delivery practice or, with respect to the Notice of Shipment clause the Government will not be able to plan in advance of receipt of supplies at a potential cost to the Government.


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;

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

  • Submit more than an original and 2 copies of any document;

  • Retain records, other than health, medical, government contracts, grant-in-aid, or tax records, for more than 3 years;

  • In connection with a statistical survey, that is not designed to produce valid, reliable results that can be generalized to the universe of study;

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

  • Include 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

  • Submit proprietary trade secrets, 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.


None


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.


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. 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.


GSA has conducted an internal inquiry for reports covered by this collection. Time and cost estimates are based on a combination of those responses and professional judgment.


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


GSA makes no such payments under this collection.


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


GSA makes no such payments under this collection.


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.


No sensitive questions are involved.


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.

  • 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 not be included here. Instead, this cost should be included in Item 13.


For identification of normal commercial delivery time:


The reporting burden was estimated for FY 2000 by determining the number of Multiple Award Schedule offers for supplies and estimating that it takes 15 minutes per offer to complete the information requested.


1662 offers x 15 minutes per offer = 416 total hours


For Notice of Shipment:


Based on FY 2000 data:


FSS: 2267 contracts/year x estimated 3 shipments per contract = 6801

Based on 15 minutes to prepare each notice = 1700 hours


PBS: 1842 notices based on 18 minutes to prepare each notice = 553 hours.


Estimated respondents/yr 5771

Total Responses annually 10,305

Estimated hours/response .266 hrs (16 minutes)

Estimated total burden hours 2741


13. Provide an estimate for the total annual cost burden to respondents or recordkeepers 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 collection services should be a 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.


Given the nature of the requests, reliable cost estimates are not available. Costs are captured in burden hours as shown in paragraph 12.


14. Provide estimates of annualized costs to the Federal Government. Also, provide a description of the method used to estimate cost, which should include qualification 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 may also aggregate cost estimates from Items 12, 13, and 14 in a single table.


Reviewing Time/hr .25 hr

Responses/year 10,305

Review Time/year 2576

Average Wages/hr $25.00 an hr

Total Government Cost $64,406


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







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.


Results will not be tabulated or published. Data collected will be used for internal administration of contracts.


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.


GSA is not seeking such approval for this collection.


18. Explain each exception to the certification statement identified in the

Certification for Paperwork Reduction Act Submissions”.


None.

B. Collections of Information Employing Statistical Methods


Statistical methods are not used in this information collection.



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JUSTIFICATION_3090-0204.doc
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File TitleJUSTIFICATION
AuthorSTEPHANIEAMORRIS
Last Modified Byhadanflowers
File Modified2009-06-08
File Created2005-01-10

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