Icr 2506-0187

Paperwork Reduction Act Submission

Please read the instruction before completing this form. For additional forms or assistance in completing this forms, contact your agency’s Paperwork Reduction Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 Seventeenth St. NW, Washington, DC 20503.

1. Agency/Subagency Originating Request: U.S. Department of Housing and Urban Development Office of Community Planning and Development Office of Environment and Energy Environmental Review Division		2. OMB Control Number: a. 2506-0187	b. None      
3. Type of information collection: (check one) New Collection Revision of a currently approved collection Extension of a currently approved collection Reinstatement, without change, of previously approved collection for which approval has expired Reinstatement, with change, of previously approved collection for which approval has expired Existing collection in use without an OMB control number For b-f, note item A2 of Supporting Statement instructions.	4. Type of review requested: (check one) Regular Emergency - Approval requested by       Delegated 5. Small entities: Will this information collection have a significant economic impact on a substantial number of small entities? Yes No 6. Requested expiration date: a. Three years form approval date b. Other (specify)      

7. Title:

"HUD NEPA ARRA Section 1609(c) Reporting" 

8. Agency form number(s): (if applicable)

N.A.

9. Keywords:

Housing, Recovery Act Grantees, Sec. 1609(c) of the American Recovery and Reinvestment Act of 2009 (ARRA), Reporting status and progress of environmental compliance with the National Environmental Policy Act (NEPA) requirements and documentation. 

10. Abstract:

Grantees who receive ARRA funding for projects must report on the status and progress of their projects and activities with respect to compliance with the National Environmental Policy Act (NEPA) requirements and documentation. HUD consolidates and transmits the information received from grantees to the Council on Environmental Quality and OMB for the Administration's reports to the House and Senate committees designated in the legislation.

11. Affected public: (mark primary with “P” and all others that apply with “X”) a.   Individuals or households e.   Farms b.   Business or other for-profit f.   Federal Government c. X Not-for-profit institutions g. P State, Local or Tribal Government		12. Obligation to respond: (mark primary with “P” and all others that apply with “X”) a.   Voluntary b. X Required to obtain or retain benefils c. P Mandatory
13. Annual reporting and recordkeeping hour burden: a. Number of respondents 6,000 b. Total annual responses 24,000 Percentage of these responses collected electronically 100% c. Total annual hours requested 12,000 d. Current OMB inventory 12,000 e. Difference (+,-) 0 f. Explanation of difference: 1. Program change: 0 2. Adjustment:      		14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) a. Total annualized capital/startup costs       b. Total annual costs (O&M)       c. Total annualized cost requested $0.00 d. Total annual cost requested       e. Current OMB inventory $0.00 f. Explanation of difference: 1. Program change: $0 2. Adjustment:      
15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”) a.   Application for benefits e.   Program planning or management b.   Program evaluation f.   Research c. X General purpose statistics g. P Requlatory or compliance d.   Audit		16. Frequency of recordkeeping or reporting: (check all that apply) a. Recordkeeping b. Third party disclosure b. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biennually 8. Other (describe)      
17. Statistical methods: Does this information collection employ statistical methods? Yes No	18. Agency contact: (person who can best answer questions regarding the content of this submission) Name: Jerimiah Sanders Phone: (202) 402-4571

19. Certification for Paperwork Reduction Act Submissions

On behalf of the U.S. Department of Housing and Urban Development, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9.

Note: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320/8(b)(3). appear at the end of the instructions. The certification is to be made with reference to those regulatory provisions as set forth in the instructions.

The following is a summary of the topics, regarding the proposed collections of information, that the certification covers:

1. It is necessary for the proper performance of agency functions;

2. It avoids unnecessary duplication;

3. It reduces burden on small entities;

4. It uses plain, coherent, and unambiguous terminology that is understandable to respondents;

5. Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

6. It indicates the retention periods for recordkeeping requirements;

7. It informs respondents of the information called for under 5 CFR 1320.8(b)(3):

1. Why the information is being collected;

2. Use of the information;

3. burden estimate;

4. Nature of response (voluntary, required for a benefit, or mandatory);

5. Nature and extent of confidentiality; and

6. Need to display currently valid OMB control number;

8. It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to collected (see note in item 19 of the instructions);

1. It uses effective and efficient statistical survey methodology; and

2. It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.

     

Signature of Program Official: X Charles Bien, Director, Environmental Review Division, signed September 23, 2009

Date:

Supporting Statement for Paperwork Reduction Act Submissions

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.

Section 1609(c) of the American Recovery and Reinvestment Act of 2009 (ARRA) requires that grantees who receive funding under ARRA (i.e., ARRA grantees/Respondents) must report on the status and progress of their projects and activities with respect to compliance with the National Environmental Policy Act (NEPA) requirements and documentation. The Council on Environmental Quality(CEQ) has provided to heads of federal departments and agencies a reporting framework for implementation of Section 1609(c). Section 1609(c) reads:

"The President shall report to the Senate Environmental and Public Works Committee and the House Natural Resources Committee every 90 days following the date of enactment until September 30, 2010 on the status and progress of projects and activities funded by this Act with respect to compliance with the National Environmental Policy Act requirements and documentation."

"HUD NEPA ARRA Section 1609(c) Reporting" is the name of copy attached for which HUD is seeking OMB approval for an three year extension of the current approval. The Department of Housing and Urban Development (HUD) is putting into operation the proposed HUD electronic data system that will be made available to grantees to facilitate their reporting on all ARRA funded activities including Section 1609(c). See item A. 2. below.



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.

The respondents to the attached copy are the grantees that received ARRA assistance. The information on the attached copy will report on the status and progress of the ARRA grantees' projects and activities with respect to compliance with NEPA requirements and documentation. See:http://portal.hud.gov/portal/page/portal/RECOVERY/Reporting

HUD has a permanent Information Technology system in place with the capability to capture NEPA data as required by Section 1609(c) of the ARRA. HUD’s Chief Information Officer (CIO) deployed such a system, called RAMPS (Recovery Act Management Performance System). The attached copy was given to the RAMPS designers with the instruction to have the system gather this information, because it contains all of the ARRA section 1609 information that HUD will need to collect from ARRA grantees in order for HUD to complete its report to CEQ.

HUD publicized the URL of the RAMPS site via links on the WWW.HUD.GOV/RECOVERY website and via listserve email broadcasts. ARRA grantees will go to the URL and enter their data at the project level. Please note that there can be multiple projects within each grant; for instance the City of Albuquerque may receive 1 grant under the ARRA "Neighborhood Stabilization Program 2" but will have multiple projects at various sites/locations around the city. Most ARRA grantees have special legislation that authorizes them to perform the HUD's Federal environmental compliance review for NEPA. For each “project” grantees will report NEPA review data each quarter on the RAMPS site. At the end of each reporting period, HUD will download the raw data from the RAMPS site. HUD will bring the data into Microsoft Excel, then aggregate/summarize/format the data as necessary to produce a report in the required CEQ format. HUD will submit the report to OMB as directed by CEQ. The CEQ Report to Congress is posted on www.NEPA.gov. Also, the website provides CEQ guidance to Federal Agencies on NEPA reporting under the Recovery Act.



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 attached copy for reporting Sec. 1609(c) data is designed to assure that the percentage of responses collected electronically will be 100%. The collection will be efficient and help reduce burden to respondants by using current available information technology. See response to A.2. above for detailed description.

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.

Not applicable. Duplication is highly unlikely, because HUD previously had no need or statutory authority or information technology readiness (See response to A.2. above) to undertake such nationwide data collection for reporting on the status and progress of the ARRA grantees' projects and activities with respect to compliance with the National Environmental Policy Act (NEPA) requirements and documentation. 

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 burden.

Not applicable. The information collection does not involve or impact small businesses.

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.

Not applicable. Sec. 1609(c) prescribes reporting every 90 days following the date of enactment until Septmeber 30, 2010. Failure to perform would be a violation of statute and the directives from OMB and CEQ to heads of federal agencies to perform this mandate.

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 than quarterly;

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

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

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

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

• requiring the use of a statistical 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

• 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.

Not applicable. None of the above special circumstances apply to this data collection for implementing Sec. 1609(c).

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 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 preclude consultation in a specific situation. These circumstances should be explained.

Consultation is ongoing with staff of the Council on Environmental Quality to assure conformity with CEQ guidance for implementing Sec. 1609(c). A notice of proposed information collection with request for public comment was published in the Federal Register for this review and extension of the current approval request to OMB (74 FR 46446, September 9, 2009).

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

Not Applicable. Respondents will not receive any payment or gifts for responding to this data collection. 

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

Not Applicable. The information collected is public information.

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.

Not Applicable. The information collection does not pertain to any of the above-listed topics.

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 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; and

• 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.

Estimated number of respondents is 6,000. Frequency of response is once quarterly. Annual number of responses is 24,000 (6,000 x 4).

Estimate 30 minutes for response. Annualized burden hours is 12,000 (24,000 x 0.5 hour).

Estimate annualized cost for collection of information is $480.000 (12,000 x $40 estimate hourly cost). The estimated hourly cost figure of $ 40 is determined for an experienced professional that approximates the hourly (mid-range) salary of a GS-13 employee. Individual ARRA grantees charge their costs for this data collection as ARRA project management and administration costs. The annualized cost is funded by the Federal government. See item below A.14.



13. Provide an estimate of 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) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance 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.

Not Applicable. There is no need to purchase or lease any equipment for this information collection.

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 not have been incurred without this collection of information. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.

By law, the Sec. 1609(c) reporting is required of ARRA grant recipients and the cost for the collection of information is paid from their ARRA grant award funding. 

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

Not Applicable. This is a currently approved collection.

16. For collection 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.

Not Applicable. HUD has no plans to publish this information as general statistical information. To comply with ARRA 1609(c), HUD will collect this information every 90 days following the date of enactment until September 30, 2010 and will consolidate and transmit the information received from ARRA grantees to the Council on Environmental Quality and OMB for the Administration's reporting to the Senate Environmental and Public Works Committee and the House Natural Resources Committee every 90 days following the date of enactment until September 30, 2010 as prescribed in the legislation. 

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.

Not Applicable. The expiration date of the OMB approval will be displayed on attached copy.

18. Explain each exception to the certification statement identified in item 19.

Not Applicable.

B. Collections of Information Employing Statistical Methods

Attachment:

"HUD NEPA ARRA Section 1609 Reporting"

[RAMPS Sec 1609 Templates.docx)

www.hud.gov/recovery



OMB 83-I 10/95