Supporting_Statement_for_Youthbuild_Program[1]

Supporting Statement for Youthbuild Program

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.

The Youthbuild program is authorized under subtitle D of title IV of the Cranston Gonzales national Affordable Housing Act (42 USC 8011), as added by section 164 of the Housing and Community development Act of 1992 (Pub.L. 102-550). The program regulations are at 24 CFR §585. Grants are awarded to projects that provide educational and training opportunities to high school dropouts while increasing the supply of affordable housing.

Beginning with Fiscal Year 2007, the Youthbuild Transfer Act of 2006, Public Law 190-282, transferred the program to the Department of Labor. The Youthbuild Transfer Act provides authority to HUD to administer grants from FY 2006 and earlier until closeout.

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.

Since the year 2000, the post award responsibilities have been delegated to HUD’s Field Offices, Community Planning and Development. These divisions are the Department’s liaison to the Youthbuild grantees and have the responsibility to collect, receive, review, and monitor the program activities through the semi-annual and close-out reports. The information that is collected is used to assess performance and evaluate overall risk for monitoring. HUD’s CPD Field Office divisions will retain this responsibility for FY 2006 and earlier grants until grant close-out.

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.

HUD has used GRANTS.GOV for application submission for the FY 2005 and FY 2006 cycles. However, given the transfer of the program to the Department of Labor, post approval program submissions will not be collected electronically.

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.

Each funded program is a new program. Information collected is unique to that program.

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.

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.

Without the information collection, grantees would not be able to report progress, make drawdowns or close-out the funded grants.

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 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 than 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 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 special circumstances that require information collection to be conducted in the manner listed in this item.

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. Specifically address comments received on cost and hour burden.

• 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 the data elements to be recorded, disclosed, or reported.

• Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years -- even if the collection of information activity is the same as in prior periods. There may be circumstances that preclude consultation in a specific situation. These circumstances should be explained.

The Federal Register Notice requesting comment was published on April 13, 2010, Volume 75, Page 18873. No comments were received.

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

Information collection does not involve any payment or gifts to respondents other than remuneration of contractor or grantees.

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

No confidentiality promised.

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.

No requests are made for information of a sensitive nature.

12. Estimates of the hour burden of the collection of information:

Submissions	# of Respondents and Responses	Annual Burden Hours	Total	Annualized Cost @ $8/hour
Semi-Annual reports for all open grants (2 x 86)	86 2 172	20	3440	$27,520
Total	86 2 172	20	3440	$27,520

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information (do not include the cost of any hour burden shown in Items 12 and 14). There are no additional costs other than those shown in #12.

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 not have been incurred without this collection of information.

Annualized Cost to the Federal Government: Grant Administration

172 semi-annual reports $40/hr x 5 hours = $34,400

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

This is a reinstatement without change of a previously approved collection. Beginning in fiscal year 2007, the Youthbuild Program transferred to the Department of Labor. This information collection is for grant administration only. HUD will retain this responsibility for all Fiscal Year 2006 and earlier grants until grant closeout.

16. For collection 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. 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. Expiration date for OMB approval will be displayed

18. Explain each exception to the certification statement identified in item 19.

There are not exceptions to the certification statement.

B. Collections of Information Employing Statistical Methods

None