Just.AlternativeAnalysis2009 Rev2

49 U.S.C Section 5339 ALTERNATIVES ANALYSIS PROGRAM

JUSTIFICATION STATEMENT

Summary of Submission

This submission is a request for approval of a new information collection.

The total number of burden hours associated with this submission and accounted for by FTA is 780. An additional 100 burden hours is reflected in the Department of Health and Human Services (HHS) information collection, to reflect burden associated with the grant application Federal Standard Form 424 (SF-424), since HHS administers that form.

1. Circumstances that make collection necessary.

The Alternative Analysis Grant Program was created to fund the alternative analysis portion of a project. It is the transportation planning process conducted at the local level to decide the best mode, or the best corridor, in the development of major capital investments. Under the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU), it is the part of the environmental process to make decisions for the locally preferred alternatives to include how to invest capital funding and address transportation needs.

FTA intends to evaluate the effectiveness of the program by collecting information such as milestones, and financial status reports.

2. How, by whom, and for what purpose the information is to be used.

Funds may be used to assist State and local governmental authorities in conducting alternatives analyses when at least one of the alternatives is a new Fixed Guideway System or any extensions to an existing Fixed Guideway System.

Eligible applicants include public agencies, including States; municipalities and other subdivisions of States; public agencies and instrumentalities of one or more States; and public corporations, boards, and commissions established under State law. Applicants must have legal, financial, and technical capacity to carry out proposed project and maintain facilities and equipment purchased with federal assistance. Private non-profit organizations are not directly eligible recipients. Grant requirements under this program are comparable to those for Section 5309 grants. 

Discretionary applications will be used to determine project eligibility. If the application is found eligible, it will be used to determine the amount awarded to the project.

3. Describe whether collection of information involves information technology and any consideration of using information technology to reduce the burden.

Alternative Analysis Program grant applicants are able to submit applications electronically through the GRANTS.GOV website by the deadline for submission of applications. The electronic submission option was exercised by 100 percent of the respondents.

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.

The application is project-specific and therefore cannot be obtained from other sources.

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

The information collected does not involve small businesses.

6. Describe consequences to federal program or policy activities if the information were not collected or collected less frequently, as well as any technical or legal obstacles to reducing burden.

If applications are not submitted when discretionary funding is available, FTA would not be in compliance with the Congressional directive to award funds to specific projects. FTA would not have the essential information to decide how the funds would be used.

7. Explain any special circumstances that would cause information collection to be conducted in a manner inconsistent with 5 CFR 1320.6.

The information collected is consistent with the guidelines in 5 CFR 1320.6.

8. Describe efforts to consult with persons outside the agency to obtain their views.

A 60-day Federal Register notice was published on May 13, 2009 (page 22629), soliciting comments prior to submission to the Office of Management and Budget (OMB). No comments were received. A 30-day Federal Register notice was published on August 18, 2009 (pages 41780 and 41781).

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

No payment or gift is made to respondents.

10. Describe any assurance of confidentiality provided respondents.

There is no assurance of confidentiality regarding submissions.

11. Additional justification for any questions of a sensitive nature.

None of the information is of a sensitive nature.

12. Estimate of the hour burden of the collection of information and annualized cost to respondents.

1. Estimate of the burden of the collection of information:

Requirements	Annual Submissions	Burden Hours per Submission	Total Burden Hours
Application Stage
Competitive Proposal	30	5	144
Standard Assurance	30	5	144
Description of System	30	5	144
Project Budget	30	5	144
Project Justification	30	5	144
Completion of HHS’s SF 424	30	1	(30)
Subtotal			690
Project Management Stage
Financial Status Report	30	3	90
Subtotal			90
Grand Total			780

The total number of burden hours associated with this submission in FTA’s information collection inventory is 780 hours. The 30 burden hours associated with the use of HHS’s Standard Form 424 (grants.gov application form), as shown above, have been reassigned to HHS’s information collection approval for their Standard Form 424.

b. Estimate of the cost to respondents.

Requirements	Annual Personnel Hours per Submission from 12a above	Average Salary/Hour of Staff	Total Annual Cost to the Grantee
Application Stage
Competitive Proposal	5	$32	$160
Standard Assurance	5	$32	$160
Description of System	5	$32	$160
Project Budget	5	$32	$160
Project Justification	5	$32	$160
Subtotal			$960
Project Management Stage
Financial Status Report	3	$32	$96
Subtotal			$96
Grand Total			$1,056

It is estimated that the cost to each respondent will be $1,056. (30 respondents x $1,056 = $31,686).

x 30 respondents

13. Estimate of total annual cost burden to respondents or record keepers resulting from the collection of information (not including the cost of any hour burden shown in Items 12 and 14).

The information requested is collected and reviewed in the course of normal business practices; therefore, no additional costs are associated beyond that shown in items 12 and 14.

14. Estimates of the annualized cost to the federal government.

Requirements	Annual Personnel Hours per Submission	Average Salary/ Hour of Headquarters Staff Reviewing Documents	Total Annual Cost to the Federal Government
Application Stage
Competitive Application Review	4	$42	$168
Standard Assurance	1	$42	$42
Description of System	1	$42	$42
Project Budget	1	$42	$42
Project Justification	1	$42	$42
Subtotal			$336
Project Management Stage
Financial Status Report	1	$42	$42
Subtotal	1		$42
Grand Total			$378

It is estimated that the annual cost to the federal government will be $378 per respondent and it should be noted that these figures assume that the applications are complete, fundable and non-controversial. More complex projects or programs of projects would consume additional time. (30 respondents x $378 = $11,340)

15. Explain reasons for changes in burden, including the need for any increases.

This is a new collection and no hours were previously approved.

16. Plans for tabulation and publication for collections of information whose results will be published.

FTA does not plan to publish the results of the information collected for statistical use.

17. If seeking approval not to display the expiration date of OMB approval, explain the reasons.

FTA is not seeking approval not to display the expiration date of OMB approval.

18. Explain any exceptions to the certification statement identified in item 19 of Form 83-I.

No exceptions are stated.

6