Supporting Statement - ICR_2577-0062

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.

This information collection is necessary to comply with the requirements of 24 CFR Part 965, Subpart C, which implements HUD policies in support of national energy conservation goals by requiring Public Housing Agencies (PHAs) to conduct energy audits and undertake certain cost-effective energy conservation measures. All PHAs shall complete an energy audit for each PHA-owned project under management, not less than once every five years. Solicitations for energy performance contracting shall be submitted to the HUD Field Office for review and approval prior to contract award. A benefit/cost analysis shall be made to determine whether a change from a master-metering system to individual meters will be cost effective. Optional form HUD-50078 is used to collect facility type and utility cost and consumption data to create an on-line model that allows PHAs to measure the energy efficiency of their buildings in comparison to other PHA-owned and operated buildings of a similar type.

Additionally, 24 CFR Part 965, Subpart E, requires PHAs to establish, review and revise utility allowances for PHA-furnished utilities for all check-metered utilities and allowances for resident-purchased utilities for all utilities purchased directly by residents from the utilities suppliers. The PHA shall maintain a record that documents the basis on which allowances and scheduled surcharges, and revisions thereof, are established and revised. Such record shall be available for inspection by residents.

The PHA shall review, at least annually, the basis on which utility allowances have been established and, if reasonably required.

Optional form HUD-50078 has been revised with updated contact information.

Authority: 42 U.S.C. 1437, 1437a, 1437d, 1437g, and 3535(d).

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.

PHAs establish utility allowances, conduct energy audits, solicit for energy performance contracts, and conduct a benefit/cost analysis for master-metering system versus check-metered utilities as required by statute and HUD regulations. Optional form HUD-50078 is used to gather information from PHAs to create a tool that allows PHAs to measure the energy efficiency of their buildings in comparison to other PHA-owned and operated buildings of a similar type. The data collected is a compilation of facility and utility data for each PHA-owned project that is used to establish comparative standards for energy efficiency. With the exception of form HUD-50078, which may be transmitted electronically, faxed, or mailed to a designated location, all other required documents are submitted to appropriate HUD field offices. Additionally, PHAs are required to maintain records for establishing annual utility allowances for resident inspection/review.

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.

This collection of information does not require the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology. Consideration of using information technology to reduce burden has been discussed. At this time no automation plans have been developed, except for the collection of data related to HUD benchmarking (form HUD-50078), which is a voluntary submission. The fact that establishment of utility allowances, energy performance contracts, and benefit/cost analysis would be different for each PHA creates a barrier to using a uniform technology across all PHAs. Requiring this would need further analysis and costing.

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.

HUD regulations permit PHAs to use or modify similar information for establishing utility allowances, if available. Energy audits, energy performance contracts and benefit/cost analysis are conducted and solicited for each PHA. The information provided differs by each PHA.

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.

If a small PHA cannot develop the required utility allowance information, HUD regulation allows them to use information from other sources.

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.

The Federal Government provides most PHAs with subsidies for operating costs of public housing developments. Included in the operating costs is the cost of utilities. If utility allowances are more than reasonable, the PHA may be receiving more subsidies than it should. If utility allowances are too low, residents may, by litigation, receive court-imposed amounts from the PHA which could cause added Federal subsidies. By requiring periodic review of utility allowances, both of these situations can be avoided.

Energy audits, required to be performed once every five years for each PHA, allow the PHAs to identify where energy efficiency could be improved. These improvements result in lowered utility bills and subsidies. No audits or reduced frequency of audits would result in fewer improvements and continually high operating subsidies. Individual meters would allow PHAs to closely track utility consumption, making it easier to identify where greater efficiencies can be achieved. PHAs are required to weigh the benefits (increased utility savings) against the costs (cost of installing individual meters) to determine if this strategy would be cost effective. No analyses would result in failure to identify where greater efficiencies can be achieved, resulting in higher operating subsidies.

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; prepare a written response to a collection of information in fewer than 30 days after receipt of it; submit more than an original and two copies of any document; retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than three years; that is not designed to produce valid and reliable results that can be generalized to the universe of study; that requires the use of a statistical data classification that has not been reviewed and approved 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 requires 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.

There are no special circumstances that would cause this information collection be conducted more than quarterly; written response fewer than 30 days after receipt of it; submit more than an original and two copies of any document; retain records, use of statistical data classification that has not been reviewed and approved by OMB, etc.

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.

A notice was published in the Federal Register, volume 75, number 61, page 16161, dated March 26, 2010, announcing the intent to submit the proposed information collection to the Office of Management and Budget and invited comments. No comments were received in response to the Federal Register notice.

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

No payment or gift is 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 assurance of confidentially provided to respondents.

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.

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 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.

* 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 1.

The reporting and recordkeeping requirement are estimated as follows:

Regulation Reference	No. of Respondents	X	Frequency of Response	Total Responses	X	Estimated Hours	=	Total Annual Burden Hours
965.302 - Energy Audits	640		1	640		46		29,440
965.308 - Energy Performance Contracts	5		1	5		24		120
965.402 - Benefit/Cost Analysis	15		1	15		3		45
965.502 - Establish utility allowances	*		*	*		*		*
965.506 - Establishment of Surcharges For Excess Consumption	200		1	200		1		200
965.507 – Review and revise utility allowances	1,920		1	1,920		25		48,000
965.508 Individual Relief Criteria	1,000		1	1,000		1		1,000
Optional Form HUD-50078	350		1	350		1.5		525
TOTALS	4,130			4,130				79,330

*PHAs use the same method to calculate new utility allowances as to update utility allowances. These calculations are generally done at the same time as utility allowance revisions. Therefore, the burden hours to calculate new allowances (965.502) are included within the burden hour calculations for reviewing and revising utility allowances (965.507).

13. Provide an estimate for the total annual cost burden to respondents or record-keepers resulting from the collection of information. (Do not include the cost of any hour burden shown in Items 12 and 14).

No other costs are associated with this collection.

14. Provide estimates of annualized costs 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 may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

The cost to the Federal Government is not determinable, since it will be part of the general cost to operate the PHA.

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

This is a revision of an existing information collection. There is a substantial increase in burden hours. The increase in burden hours is based upon data obtained from PHAs indicating that energy audits and the calculation/recalculation of utility allowances takes significantly more time than had previously been estimated. Estimates for Energy Performance Contracts (EPC) were reduced due to a revised number of new EPCs generated every year. Utility allowances are reviewed annually when significant change in reasonable consumption occurs and changes in utility rates increase greater than 10%. The majority of PHAs have already established utility allowances for PHA-furnished utilities and resident-purchased utilities. PHAs have indicated that any new utility allowances calculations are included in annual review and revisions. In addition, burden hours were added for optional form HUD-50078. Data collected on this form has been used to create an on-line tool for PHAs to assess their relative energy and water efficiency against other buildings of similar type. This tool will be updated in the future, thus the form is being renewed to make it available for this future effort.

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.

The information collection results will not be published.

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.

HUD is not seeking approval to not display the expiration date of the OMB approval.

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

There are no exceptions to the certification statement identified in item 19, OMB 83-I

B. Collections of Information Employing Statistical Methods

This collection of information will not employ statistical methods.