1024-0031__supporting_statement_August_16_10

Supporting Statement A for Paperwork Reduction Act Submission

OMB Control Number 1024-0031

Land and Water Conservation Fund Description and Notification Form

Form NPS 10-903

Terms of Clearance: OMB approved this information clearance on August 8, 2007, with the following terms of clearance: Upon the agency's next request for OMB approval, the agency must post this grant opportunity on grants.gov and provide, if practicable, an electronic submission option matching those opportunities.

Response: We considered announcing Land and Water Conservation Fund grant opportunities on Grants.gov, but believe it is not feasible. Based on its Statewide Conservation Outdoor Recreation Plan, each State determines priorities for LWCF funding and announces available grants on the State website. States establish their own criteria for awarding their allocated funding through a competitive selection process. The grants are specific to each State and each State has a different process and grant schedule. Announcing LWCF grants on grants.gov would create a lot of confusion to potential applicants.

1. Explain the circumstances that make collection of information necessary.

The Land and Water Conservation Fund Act of 1965 (LWCF Act) (16 U.S.C 4601-4 et seq.) was enacted to help preserve, develop, and ensure access to outdoor recreation facilities. The LWCF Act provides funds for and authorizes Federal assistance to the States for planning, acquisition, and development of needed land and water areas and facilities.

In accordance with the LWCF Act, the National Park Service (we, NPS) administers the LWCF State Assistance Program, which provides matching grants to States, and through the States to local units of government. As used in this information collection request, the term “States” includes the 50 States; the Commonwealths of Puerto Rico and the Northern Mariana Islands; the District of Columbia; and the territories of Guam, the U.S. Virgin Islands, and American Samoa.

LWCF grants are provided to States on a matching basis for up to 50 percent of the total project-related allowable costs. Grants to eligible insular areas may be for 100 percent assistance. The LWCF State Assistance Program gives maximum flexibility and responsibility to the States. States establish their own priorities and criteria and award their grant money through a competitive selection process based on a Statewide recreation plan. Payments for all projects are made to the State organization that is authorized to accept and administer funds paid for approved projects. Local units of government participate in the program as subgrantees of the State with the State retaining primary grant compliance responsibility.

The basis for this information is the Description and Notification Form (DNF), NPS 10-903. We use this form to collect project details at the beginning of each project and any changes made through amendments or Conversion of Use Provisions requests. The data is used to analyze overall trends in LWCF assistance. The DNF becomes part of the official project agreement.

2. Indicate how, by whom, how frequently, and for what purpose the information is to be used. If the information collected will be disseminated to the public or used to support information that will be disseminated to the public, explain how the collection complies with all applicable Information Quality Guidelines.

The DNF captures information about LWCF grants and the parks and recreation areas assisted through either approval of a new grant, an amendment to an existing grant, or for a Conversion of Use Provisions request. The data collection includes the specific grant details and data related to each park or recreation area impacted by the grant. This information is used to aid in reporting the performance of the program to Members of Congress and the American people. NPS personnel enter the data into the LWCF program’s automated project information. Summary data of the each grant project may be viewed by the public at nps.gov/lwcf under “Finding LWCF in your neighborhood”. Data pertinent to the thousands of active and completed LWCF projects can be retrieved from the database.

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 [and specifically how this collection meets GPEA requirements.].

The DNF is available in a fillable format at http://www.nps.gov/ncrc/programs/lwcf/pub.htm. The completed form may be submitted by mail or email.

4. Describe efforts to identify duplication.

There is no duplication of the information between this collection and collections by other entities because the data is project specific for the LWCF State Assistance Program. There may be some duplication of data within this collection when the form is completed for amendments and Conversion of Use Provisions requests. However, this is necessary to ensure that we have accurate, up-to-date information on the project.

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

The collection of information does not impact small businesses or other small entities.

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.

We collect this data to record each project and how funds are being used. Without this data NPS would not have the sufficient overall LWCF program information to quickly report on inquiries or analyze trends in assistance. We only collect the data at the onset of a project or when changes are made to the project; therefore, we could not collect the data less frequently.

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;

* 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 that 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 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 of the listed circumstances above apply.

8. Provide 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 (or in response to a PRA statement) and describe actions taken by the agency in response to those 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, or reporting format (if any), and on the data elements to be recorded, disclosed or reported. [Please list the name, titles, addresses, and phone numbers of persons contacted.

A notice announcing the extension of the collection and requesting public comments was published in the Federal Register on March 24, 2010 (75 FR 14181) for a 60-day period. The comment period ended on May 24, 2010. The NPS did not receive any comments in response to the Federal Register notice.

The State Liaison Officers listed below, who are appointed by the State governor to administer the LWCF Program, have been consulted concerning the reporting requirements and format. Also, through the National Association of State Outdoor Recreation Liaison Officers, an on-going mechanism exists for direct input into program administration. The consensus was that the form is easy to complete and the time burden is accurate.

Mr. Wayne M. Sames

Local Grants Manager

Office of Management and Budget (DNR)

500 Lafayette Road, Box 10

St. Paul, MN 55155-4010

651-259-55559

[email protected]

Mr. Randy Kittle

Program Specialist/Grants Coordinator

Department of Game, Fish and Parks

Foss Building, 523 East Capitol

Pierre, SD 57501-3182

605-773-5490

[email protected]

Ms. Susan R. Moerschel, Program Manager

Park Resource Office

Division of Parks and Recreation

89 Kings Highway

Dover, DE 19901

302-739-9420

[email protected]

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

There are no payments or gifts provided to respondents.

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

There are no assurances of confidentiality provided to respondents.

11. Provide additional justification for any question of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

No sensitive questions are asked.

12. Provide estimates of the hour burden of the collection of information.

We are estimating 448 annual responses and 448 burden hours for this collection. The maximum number of respondents is 56 and we estimate an average of 8 responses per respondent. NPS estimates that approximately 1 hour is the burden time for completing the LWCF DNF.

We estimate the dollar value of the annual burden hours to be $29,192. State LWCF Coordinators complete the LWCF DNF. The mean hourly wage is approximately $43.44 based on the Bureau of Labor Statistics, Occupational Employment and Wages, May 2009, http://www.bls.gov/oes/2009/may/oes111021.htm. A multiplier of 1.5 was added for benefits for State/local/tribal governments in accordance with BLS news release USDL 10-0774, June 9, 2010 (http://www.bls.gov/news.release/pdf/ecec.pdf) resulting in an hourly wage of $65.16.

The annual burden estimate is summarized as follows:

13. Provide an estimate of the total annual [nonhour] cost burden to respondents or record keepers resulting from the collection of information.

There are no nonhour costs.

14. Provide estimates of annualized costs to the Federal Government.

The annual cost to the Federal Government is $25,115 (rounded) ($56.06 X 448 hours). The NPS estimates 1 hour per form for an Outdoor Recreation Planner to review the forms, enter the data into the database, and compile any reports to Congress. The hourly rate for a GS-12/step 5 is $37.37, based on the Office of Personnel Management Salary Table 2010-RUS http://www.opm.gov/oca/10tables/pdf/rus_h.pdf . A multiplier of 1.5 was added for benefits in accordance with BLS news release USDL 10-0774, June 9, 2010 (http://www.bls.gov/news.release/pdf/ecec.pdf), resulting in an hourly wage of $56.06.

15. Explain the reason for any program changes or adjustments.

We are reporting a decrease of 2 annual responses and 2 burden hours. This is an adjustment based on our experience in administering this collection over the last several years.

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

We do not publish this 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.

We will display the OMB control number and expiration date on appropriate materials.

18. Certification

There are no exceptions to the certification statement.