NARRATIVE OF CHANGES for Supporting Statement Part A for OMB #: 1660-0102

Changes to Collection OMB No. 1660-0102

Form Number(s): FEMA Form 007-0-1 (formerly FEMA Form 86-26)

To: FEMA Form Number 86-26 is now FEMA Form 007-0-1. Note: Same form with new form numbers using FEMA’s new numbering system.

 8b. 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 note change in 8 b and c.

FEMA consults with J&E Associates, Inc., a professional services and management consulting firm, on the Housing Inspection Services Survey. Consultations are as often as weekly during the survey collection process as this contractor conducts the full survey collection for us and we consult with them on an as needed basis on questions that arise weekly or as needed.

c. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

FEMA Inspection Management Task Monitors review the comments provided from responding applicants. The qualitative and quantitative information gathered from the open-ended questions in the survey serve as the driving force for any changes FEMA Inspection Management may need. For example, the last question in the customer satisfaction survey instrument is “Please provide any ideas to improve the process” and to outline “any unmet expectations,” and such questions serve as regular and direct consultation from the respondents to us regarding the survey.



 12. Provide estimates of the hour burden of the collection of information. The statement should:



 a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated for each collection instrument (separately list each instrument and describe information as requested). 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 desired. 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. PLEASE NOTE: All changes are detailed in Question 15 (below).

 b. If this request for approval 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.

c. Provide an estimate of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. NOTE: The wage-rate category for each respondent must be multiplied by 1.4 and this total should be entered in the cell for “Avg. Hourly Wage Rate”. The cost to the respondents 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 Annualized Burden Hours and Costs
Type of Respondent	Form Name / Form Number	No. of Respon-dents	No. of Respon-ses per Respon-dent	Total No. of Responses	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate	Total Annual Respondent Cost
Individuals in Households	Federal Emergency Management Agency Housing Inspection Services Customer Satisfaction Survey /FEMA Form 007-0-1 (formerly FEMA Form 86-26)	10,164	1	10,164	.25 ( 15 minutes)	2,541	$28.45	$72,291.45
Total		10,164		10,164		2,541		$72,291.45

Note: The estimated annual number of respondents for all disasters is 10,164 which is derived from the estimate of 33 annual disaster declarations that result in housing inspections based on the average number of disasters that occurred during FY2008-2009 that resulted in housing inspections and number of actual respondents according to the sample size of 950 and a 32.4% of response rate (950 x 0.324 = 307.8, therefore 308 respondents multiplied by 33 disasters = 10,164). Average hourly wage rate = $20.32 x 1.4 wage rate multiplier= $28.45.

• Note: The “Avg. Hourly Wage Rate” for each respondent includes a 1.4 multiplier to reflect a fully-loaded wage rate.

• “Type of Respondent” should be entered exactly as chosen in Question 3 of the OMB Form 83-I

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for all occupations is estimated to be 28.45 per hour including the wage rate multiplier of 1.4, therefore, the estimated burden hour cost to respondents is estimated to be $72,291.45 annually.

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. (Do not include the cost of any hour burden shown in Items 12 and 14.) Costs are updated to more accurately reflect those associated with this collection.

The cost estimates should be split into two components:

a. Operation and Maintenance and purchase of services component. These estimates should take into account cost associated with generating, maintaining, and disclosing or providing 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.

b. Capital and Start-up-Cost should include, among other items, preparations for collecting information such as purchasing computers and software, monitoring sampling, drilling and testing equipment, and record storage facilities.

Annual Cost Burden to Respondents or Record-keepers

Data Collection Activity/Instrument	*Annual Capital Start-Up Cost (investments in overhead, equipment and other one-time expenditures)	*Annual Operations and Maintenance Cost (such as recordkeeping, technical/professional services, ect.)	Annual Non-Labor Cost (expenditures on training, travel and other resources)	Total Annual Cost to Respondents
Total	0	0	0	0

There are no record keeping, capital, start-up or maintenance costs associated with 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 have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table. Note change to cost to the Federal Government below.

Annual Cost to the Federal Government

Item	Cost ($)
Contract Costs $5,259 average per survey task order x 33 declarations per year	$173,547
Staff Salaries* 1 GS 12 Step 2 employee, at 5%  of their annual salary for coordinating with the contractor for duties associated with this data collection such as reporting on areas that housing inspection can work on. ([77,368 x .05] = 3,868.40x 1.4= $5,415.76)	$5,415.76
Facilities [cost for renting, overhead, etc. for data collection activity]	0
Computer Hardware and Software [cost of equipment annual lifecycle]	0
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]	0
Travel	0
Printing	0
Postage (Included in the contract cost of 4.47 per survey)	0
Other	0
Total	$178,962.76

* Note: The “Salary Rate” includes a 1.4 multiplier to reflect a fully-loaded wage rate.

 15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I in a narrative form. Present the itemized changes in hour burden and cost burden according to program changes or adjustments in Table 5. Denote a program increase as a positive number, and a program decrease as a negative number. See descriptions below each chart for changes.

A "Program increase" is an additional burden resulting from an federal government regulatory action or directive. (e.g., an increase in sample size or coverage, amount of information, reporting frequency, or expanded use of an existing form). This also includes previously in-use and unapproved information collections discovered during the ICB process, or during the fiscal year, which will be in use during the next fiscal year.

A "Program decrease", is a reduction in burden because of: (1) the discontinuation of an information collection; or (2) a change in an existing information collection by a Federal agency (e.g., the use of sampling (or smaller samples), a decrease in the amount of information requested (fewer questions), or a decrease in reporting frequency).

"Adjustment" denotes a change in burden hours due to factors over which the government has no control, such as population growth, or in factors which do not affect what information the government collects or changes in the methods used to estimate burden or correction of errors in burden estimates.

Itemized Changes in Annual Burden Hours
Data collection Activity/Instrument	Program Change (hours currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (hours currently on OMB Inventory)	Adjustment (New)	Difference
Federal Emergency Management Agency Housing Inspection Services Customer Satisfaction Survey /FEMA Form 007-0-1 (formerly FEMA Form 86-26)				2,652	2,541	-111
Total(s)				2,652	2,541	-111

Explain: There is a decrease in the burden hours requested in this submission. The values are lower in the last submission to OMB and because the number of annual disasters at that time was higher. It decreased from 34, the average upon last submission to 33, the current average. The number of disasters at the present submission is based on the average number of disasters that occurred during FY2008-2009 that resulted in housing inspections, and that average is 33. The response rate used is also slightly less based on tabulated results. It decreased minimally by .4% from 32.8% to 32.4%.

Itemized Changes in Annual Cost Burden
Data collection Activity/Instrument	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New)	Difference
Federal Emergency Management Agency Housing Inspection Services Customer Satisfaction Survey /FEMA Form 007-0-1 (formerly FEMA Form 86-26)	0	$72,291.45	+$72,291.45
Total(s)	0	$72,291.45	+$72,291.45

Explain: The cost for this collection was not previously on the OMB Inventory. The cost burden to respondents or record-keepers upon this submission is therefore a positive difference.





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