Supporting Statement 1660-0076 5-5-10

May 5, 2010

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660-0076

Title: Hazard Mitigation Grant Program (HMGP) Application and Reporting

Form Number(s): None

General Instructions

A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When Item 17 or the OMB Form 83-I is checked “Yes”, Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

A. Justification

1. Explain the circumstances that make the collection of information necessary (give details as to why this information is being collected). 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. Provide a detailed description of the nature and source of the information to be collected.

Section 404 of the Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. 5170c, established the Hazard Mitigation Grant Program. Grant requirements, and grants management procedures of the program are outlined in 44 CFR Part 13.

FEMA regulations require grantees to report to FEMA on a quarterly basis, certifying how the funds are being used and reporting on the progress of activities funded under the subgrant awards made to the Grantee by FEMA. Grantees administer the HMGP, which is a post-disaster program that contributes funds toward the cost of hazard mitigation activities in order to reduce the risk of future damage, hardship, loss or suffering in any area affected by a major disaster. Grantees are defined as any State of the United States, the District of Columbia, Puerto Rico, the Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern Mariana Islands, or an Indian tribal government that chooses to act as a grantee.

44 CFR 206.436 HMGP regulations describe the application process. Information collected through the grant applications is the minimum necessary to administer grants under the HMGP and includes the project narrative, analysis of the measure’s cost-effectiveness referred to as the benefit-cost determination, and environmental review and used in conjunction with OMB No. 1660-0025.

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. Provide a detailed description of: how the information will be shared, if applicable, and for what programmatic purpose.

Project Narrative, Explains the FEMA application and review process to the respondent and provides instruction as to what detail is required. The Project Narrative describes the proposed activity for which funding is sought. FEMA uses this information to certify that the project meets minimal mitigation eligibility criteria.

Benefit-Cost Determination: This is a requirement to establish that Federal funds awarded as a grant are applied in a cost-effective manner. This information is used by FEMA to determine if the benefits of the proposed mitigation work exceed the costs of the mitigation activity.

Environmental Review: Respondents are responsible for providing most of the necessary information to complete environmental reviews under the National Environmental Policy Act and other laws and Executive orders. FEMA works with the respondents to collect environmental information necessary to implement the project.

The following forms are approved under OMB No. 1660-0025, FEMA Grants Administration Forms. The following forms are utilized for this collection:

FEMA Form 112-0-3, 112-0-3A, 112-0-3B, and 112-0-3C Summary Sheet for Assurances and Certifications is used by States and other recipients to certify compliance with important Federal requirements.

FEMA Form 112-0-4, Outlay Report and Request for Reimbursement for Construction Program, is used by State and local governments to report outlays for construction grants when directed by FEMA.

FEMA Form 112-0-5, Report of Government Property, is used by grantees to provide a listing of inventoried, non-expendable equipment purchased under a grant or cooperative agreement or Federally-owned equipment that is provided by the agency to be used by the grantee.

FEMA Form 112-0-6, Reconciliation of Grants and Cooperative Agreements, is used by grantees and FEMA personnel to reconcile awards, outlays, and draw downs during and at completion of a grant or cooperative agreement.

FEMA Form 112-0-8, Budget Information—Non-construction Programs, on non-disasters, used by States and other recipients to submit budget data when applying for a grant or cooperative agreement where the major purpose is not construction. The information can include budget narrative that is used to relate items to program activities and to justify and explain budget items. Budget narrative information is made available to FEMA only upon request by FEMA. On the FEMA disaster grants, this form is used to compile the information necessary to fill out the SF424 face sheet. FEMA has a variety of disaster grants that use OMB approved forms to gather information relating to the nature and extent of the disaster damage. Often, States rely upon FEMA to provide estimates as to the extent of the damage and the projected amounts of federal dollars that will be available. FEMA instructs our State partners to fill in the “Other” column for each grant program that is activated under the disaster, and to provide a breakdown by Federal, State, and Local share as appropriate. The individual program offices in FEMA and their State counterparts maintain the detailed information as to what each program is estimated to cost, and then this information is modified as the disaster response and recovery activity progresses. This practice is consistent with OMB guidance that for any form, except the SF424 face sheet, agencies may shade out or instruct the applicant to disregard any line item that is not needed.

The following Standard Forms are also required for this collection. The forms are approved for use under the OMB Control Number listed for each.

SF-424, Application for Federal Assistance, is a standard form used by applicants as a required face-sheet for pre-applications and applications submitted for Federal assistance. It is used by Federal agencies to obtain application certification, and is approved for use under OMB No. 4040-0004.

SF-425, Federal Financial Report, State and local governments use this form to report the status of financial expenditures for FEMA grants. It is approved for use under OMB No. 0348-0061.

SF-LLL, Disclosure of Lobbying Activities, is a standard form used by applicants as a required agreement to comply with all requirements of the awarding agency. It is approved for use under OMB No. 0348-0046.

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 information management and grants processing system that presently supports the HMGP programmatic lifecycle processes is the National Emergency Management Information System (NEMIS). Applicants use NEMIS to create the applications and submit them in digital format, or the information can be e-mailed as attachments to the FEMA regional representative for the particular disaster.

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.



The information asked for in the HMGP data collection is not duplicative, nor are the data collection tools. Each item asks for unique information. FEMA is looking to unify all the mitigation grant programs, which will include a uniform application package so that all data collection instruments are similar.

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.

The respondents to this data collection are States, Territories, and Indian tribes. Small businesses and other small entities are not eligible to apply directly to FEMA for HMGP funding and are, therefore, not impacted under this data collection.

6. Describe the consequence to Federal/FEMA program or policy activities if the collection of information is not conducted, or is conducted less frequently as well as any technical or legal obstacles to reducing burden.

The Stafford Act established specific eligibility criteria for the use of the HMGP grant program authority. FEMA will not be able to determine eligibility of potential applicants, proposed mitigation activities, cost-effectiveness of the proposed activity, or the effect on the environment, without the information requested in the data collection. Without approval of this information collection, FEMA will not be able to provide disaster assistance for mitigation activities to State and local communities that have been declared under a Presidential Disaster Declaration. This collection is used in conjunction with OMB No. 1660-0025.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

a. Requiring respondents to report information to the agency more often than quarterly.



Once a data collection has been submitted to FEMA, respondents would not be required to report information more often than quarterly unless the respondent chose to amend the information in the data collection.

b. Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.



HMGP data collections are submitted within 12 months of the date of the disaster declaration, unless the Regional Director has granted a request for an extension. Therefore, respondents will not have to prepare a written response to a collection of information with less than 30 days notice.

c. Requiring respondents to submit more than an original and two copies of any document.



Respondents are not required to submit more than an original and two copies of any document.

d. Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years.



FEMA does not require respondents to retain records for more than three years.

e. 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.



There is no statistical survey involved with this data collection.

f. Requiring the use of a statistical data classification that has not been reviewed and approved by OMB.

There is no use of statistical data classification involved with this data collection.

g. 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.



There is no pledge of confidentiality that is not supported by authority in statute or regulation necessary for this data collection.

h. 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.



There are no requirements for respondents to submit proprietary trade secret or other confidential information for this data collection.

8. Federal Register Notice:



a. Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice 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.



A 60-day Federal Register Notice inviting public comments was published on January 25, 2010, Volume 75 pp 3912. No comments were received. See attached copy of the published notice included in this package.

A 30-day Federal Register Notice inviting public comments was published on May 5, 2010, Volume 75 pp 24732. No comments were received. See attached copy of the published notice included in this package.

b. 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.

FEMA has received input from States and local governments about information collections for the HMGP through meetings with FEMA. FEMA also has invited various State and local stakeholders to participate in meetings to discuss program improvements, ways to simplify application requirements to include discussions on data collection and electronic information gathering/processing for FEMA mitigation grant programs. In addition, FEMA meets with National Emergency Management Agency (NEMA) representatives and the Association of Flood Plain Managers (ASFPM) at their annual conferences. The Respondents are members of NEMA and ASFPM. The results of these consultations are clarifications made in the guidance for the grant program. This would allow the respondents to better prepare their applications so that FEMA can more efficiently process them. The current updates (listed on pages 3-5 of the guidance) do not change how information is collected or what type of information is necessary but rather provide a more informative process and explain changes to the program in terms of what new items are covered, how to provide more concise details.

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’s regional offices have discussed the HMGP with our State counterparts in training sessions and meetings. In addition, FEMA has involved State representatives (as nominated by the National Emergency Management Association) in established meeting sessions regarding data collection and electronic data processing for FEMA mitigation grant programs. FEMA uses the feedback to review the guidance and make any necessary updates to it so that respondents can better understand the program requirements and would be incorporated as indicated in Question 8b above.

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

There is no payment or gift to respondents for this data collection.

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 the respondents for this information collection.

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.

There are no questions of a sensitive nature involved with this data collection.

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. 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.

It is estimated that 56 respondents will complete the Project Narrative and that each respondent will provide 18 narratives each year. Each narrative is estimated to require 12 hours to complete, and the total annual hour burden for the Project Narrative is 56 respondents X 18 responses per year x 12 hours per response = 12,096 hours burden.

It is estimated that 56 respondents will complete the Benefit Cost Determination and that each respondent will provide 18 determinations each year. Each determination is estimated to require 5 hours to complete, and the total annual hour burden for the Benefit Cost Determination is 56 respondents X 18 responses per year x 5 hours per response = 5,040 hours burden.

It is estimated that 56 respondents will complete the Environmental Review and that each respondent will provide 18 determinations each year. Each review is estimated to require 7.5 hours to complete, and the total annual hour burden for the Environmental Review is 56 respondents X 18 responses per year x 7.5 hours per response = 7,560 hours burden.

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 Item13 of OMB Form 83-I.

c. 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 14.

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
State, Local or Tribal Government	Project Narrative Section /No Form	56	18	1,008	12	12,096	$37.45	$452,995
State, Local or Tribal Government	Benefit-Cost Determination/No Form	56	18	1,008	5	5,040	$37.45	$188,748
State, Local or Tribal Government	Environmental Review/No Form	56	18	1,008	7.5	7,560	$37.45	$283,122
Total		56		3,024		24,696		$924,865

•  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

Instruction for Wage-rate category multiplier: Take each non-loaded “Avg. Hourly Wage Rate” from the BLS website table and multiply that number by 1.4. For example, a non-loaded BLS table wage rate of $42.51 would be multiplied by 1.4, and the entry for the “Avg. Hourly Wage Rate” would be $59.51.

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for State Hazard Mitigation Office Staff Worker is estimated to be $37.45 per hour including the wage rate multiplier, therefore, the estimated burden hour cost to respondents State Hazard Mitigation Office Staff Worker is estimated to $2,434,849 annually.

The following FEMA forms are utilized for this collection, and the burden hours are calculated and approved under collection 1660-0025.

Type of Respon-dent	Form Name / Form Number	No. of Respon-dents	No. of Responses per Respon-dent	Total Number of Respons-es	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate ($)	Total Annual Respondent Cost ($)
State, Local or Tribal Government	Budget Information - Non-construction Programs / FEMA Form 112-0-8	56	18	1,008	9.7	9777.6
State, Local or Tribal Government	Assurances and Summary Sheet for Assurances / FEMA Forms 112-0-3,A,B,C	56	18	1,008	1.7	1713.6
State, Local or Tribal Government	Outlay Report and Request for Reimbursement for Construction Programs / FEMA Form 112-0-4	56	18	1,008	17.2	17337.6
State, Local or Tribal Government	Report of Government Property / FEMA Form 112-0-5	56	18	1,008	4.2	4233.6
State, Local or Tribal Government	Reconciliation of Grants and Cooperative Agreements / FEMA Form 112-0-6	56	18	1,008	0.084	84.7
Total		56		5,040		33,147

The following Standard Forms are utilized for this collection and the burden hours are approved for use as indicated above in Question 2.

Type of Respon-dent	Form Name / Form Number	No. of Respon-dents	No. of Responses per Respon-dent	Total Number of Respons-es	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate ($)	Total Annual Respondent Cost ($)
State, Local or Tribal Government	Application for Federal Assistance / SF 424	56	18	1008	0.75	756.0
State, Local or Tribal Government	Disclosure of Lobbying Activities / SF LLL	56	18	1008	0.167	168.3
State, Local or Tribal Government	Federal Financial Report / SF 425	56	18	1008	1.5	1512.0
Total		56		312		2436.3

13. Provide an estimate of the total annual cost burden to respondents or record-keepers 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. The cost estimates should be split into two components:

There are no annual capital, start-up, maintenance or operation costs associated with this 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.

Annual Cost to the Federal Government

Item	Cost ($)
Contract Costs [Describe]
Staff Salaries* See description below	$1,895,695
Facilities [cost for renting, overhead, ect. for data collection activity]
Computer Hardware and Software [cost of equipment annual lifecycle]
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]
Travel
Printing [number of data collection instruments annually]
Postage [annual number of data collection instruments x postage]
Other
Total	$1,895,695

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

The staff salaries were calculated as a GS 11/5 ($29.47/hr x 1.4 multiplier = 41.26) employee reviewing the project narrative for two hours times 1,008 total narratives = $83,180; a GS 11/5 ($29.47/hr x 1.4 multiplier = 41.26) employee reviewing and recalculating the benefit-cost determination for 3 hours times 1,008 cost/benefit determinations received = $124,770; a GS 12/5 ($35.32/hr x 1.4 multiplier = $49.45) employee managing an environmental review for 13 hours times 1,008 reviews received = $647,993; and four GS 11/5 ($29.47/hr x 1.4 multiplier = 41.26) employee conducting an audit at 25 hours each times 1,008 audits received = $1,039,752. The total cost is $1,895,695.

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.

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.

Explain: There are no changes to the Annual Hour Burden .

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
Project Narrative Section /No Form				$323,568	$452,995	+$129,427
Benefit-Cost Determination/No Form				$134,820	$188,748	+$53,928
Environmental Review/No Form				$202,230	$283,122	+$80,892
Total(s)				$660,618	$924,865	+$264,247

Explain: The change to the Benefit/Cost Determination, Environmental Review and the Project Narrative result from the increase in average wages in the BLS tables as well as the application of the 1.4 multiplier to each collection activity.

16. For collections 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.



This information collection will not be published for statistical purposes.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain reasons that display would be inappropriate.

FEMA will display the expiration date for OMB approval of this information collection.



18. Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

FEMA does not request an exception to the certification of this information collection.

B. Collections of Information Employing Statistical Methods.



The collection of information for HMGP does not employ statistical methods.

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