The purpose of this submission is to request OMB reauthorization of the SBA Form 987, “Disaster Survey Worksheet.”
A. Justification
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 Small Business Administration (SBA) is authorized to make loans to victims of disasters for the purpose of restoring their damaged property to, as near as possible, pre-disaster conditions. SBA also has authority to offer loans to small businesses to help them recover from economic injury caused by a disaster. See 15 U.S.C. 636 (b) and (c) and implementing regulations at 13 CFR 123. (Copies of the pertinent provisions are attached.) A disaster declaration, which can be issued by either the President or the SBA Administrator, is a prerequisite to the availability of any disaster loan assistance. The minimum criteria for declarations by the SBA’s Administrator are listed in 13 CFR 123.3. For physical disaster declarations in particular, SBA personnel must make certain threshold determinations, as described in section 123.3 (3), regarding the amount of damage in an affected area. The information collected on this form facilitates that process.
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.
13 CFR 123.3 establishes the minimum criteria necessary for the Agency to declare a physical disaster. SBA Form 987 is used by SBA’s Office of Disaster Assistance (ODA) staff to record information regarding disaster damage. The information is gathered by questioning affected individuals about the extent of their damage and potential insurance recovery for Presidential and Agency declarations. State and local officials are also questioned to obtain information helpful for the decision process. With this information, ODA determines if sufficient damage has occurred to warrant a disaster declaration by the Administrator of SBA.
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 the burden.
Although information is collected from the public, the SBA 987 is not filled out by the public. ODA representatives collect the information from public and State government officials in person after a disaster has occurred. The information is used to complete the form. ODA representatives who use electronic mobile devices collect information contained on the SBA 987. The data is temporarily stored on the remote devices and then transferred to a core database at a secure location through secure connections within the Disaster Credit Management System (DCMS). DCMS is a web-based system that supports all ODA loan-processing activities, including the disaster management, loss verification, legal, document management, and portfolio maintenance tasks.
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.
SBA collaborates and consults other Federal Agencies to ensure duplicate infomation is not collected. Information is not available before the disaster occurs. No other form used by the SBA collects this information.
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
Small businesses or small entities comprise a portion of the respondent sample. There is no significant economic impact on them. In any event, where possible, a visual inspection is made without the need to question the affected party. When this is not possible, questions are limited to very general information about damage sustained and insurance coverage in effect.
Describe the consequence to the 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.
If this information were not collected, ODA could not process disaster declaration
requests because there would be no basis upon which to determine if sufficient damage
has occurred to warrant a disaster declaration by the Administrator of SBA. Since this
information is collected only after a written request for a disaster declaration is made by
the Governor or Governor’s authorized representative of the affected state, it cannot be
collected less frequently.
Explain any special circumstances that would cause an information collection to be conducted in a manner, etc.
There are no special circumstances.
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. Describe efforts to consult with persons outside the agency to obtain their views.
ODA solicited comments in Federal Register Vol. 74, No. 209, page 56245-dated October 30, 2009 (copy attached). The comment period closed Dec 29, 2009, and no comments were received.
Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
There are no 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.
The information is not specifically linked to any person or entity nor is it retrieved by a personal identifier. Therefore, there is no need for assurances of confidentiality. The information is however, subject to disclosure under the Freedom of Information Act (5 U.S.C. §552).
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, specific uses to be made of the information, 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 asked.
12. Provide estimates of the hour burden of the collection of information, well as the hour cost burden. Indicate the number of respondents, frequency of response, annual hour and cost burden, and an explanation of how the burden was estimated.
We estimate that an average of 40 individuals and businesses (respondents) are queried regarding damage to their property per survey. It takes an estimated 5 minutes per response, which is based on the actual experience of employees in the field who ask these questions.
The hour burden is based on survey activity for the 3 most recent fiscal years (FY 07, 08, and 09). Requests for Presidential and SBA Administrative declarations (both declined and approved) are calculated as these are the declaration types that require surveys. In the breakdown below, declines are listed separately because we track them separately; however, they are essentially either Presidential or Administrative declaration requests that were declined rather than approved, based on the criteria not being met.
Presidential &
Presidential SBA Administrative Administrative Total
FY Declarations Declarations Declines Surveys
07 33 44 1 78
08 37 55 1 93
09 25 40 0 65
Total surveys past 3 FYs = 236 divided by 3 = 79 average surveys per year
79 surveys x 40 respondents per survey = 3160 responses
3160 responses x .083 (5 minutes) per response = 262 hours
There are minimal financial costs to respondents. The cost estimate for a respondent is based on a GS-5, Step 1 ($15.94 per hour), which is the level of expertise (minimal) that is required to respond to simple questions. The annual cost is calculated below:
262 hours x $15.94 per hour = $4,176 annual cost to respondents
13. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. Do not include hour cost burden from above.
There are no additional costs beyond that identified in Item 12 above.
Provide estimates of annualized costs to the Federal Government. Also provide a description of the method used to estimate cost, including a 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.
We estimate that it takes approximately 10 hours to survey all respondents per disaster declaration request. This information is based on actual experience. Agency burden hours are calculated below:
79 surveys x 10 hours per survey = 790 Agency burden hours
The annual cost estimate for the Agency is based on the salary of a GS-11, Step 1, ($29.22 per hour), which is the typical grade for an employee performing these surveys. The cost is calculated as follows:
790 total hours x $29.22 per hour = $23,084 Cost to the Government
Explain reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.
The estimated cost to the respondent of $4,176 is an increase of $1,071 from the last submission. The estimated cost to the Government of $23,084 is an increase of $5,924 from the last submission. These changes resulted from an increase in the basic salary for the General Schedule grade levels on which the costs estimates are based. The agency burden hours of 790 increased by 130 hours from the previous submission due to more disaster declaration requests. The public burden hours increased as compared to the last reporting period due to an increase in disaster activity (196 total surveys conducted for FY 04-06 versus 236 for the period FY07-09.
For collection of information whose results will be published, outline plans for tabulation and pubication. Address complex analytical techniques. Provide time schedules for the entire project.
No publication is anticipated.
If seeking approval to not display the expiration date for OMB approval of the information collection, excplain the reasons why the display would be inappropriate.
ODA will display the expiration date.
Explain each exception to the certiifcation statement identified in Item 19, “Certfication for Paperwork Reduction Act Submission,” of OMB Form 83-I.
There are no exceptions to the certification statement.
B. Collections of Information Employing Statistical Methods.
N/A
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | .Supporting Statement, SBA Form 987 |
| Author | Bridget Dusenbury |
| File Modified | 0000-00-00 |
| File Created | 2021-02-03 |