Demonstration Planning Grant OMB Final 6.14.10 Part A

Evaluation of the
Demonstration
Planning Grant
Program
Task Order
C-CHI-01031/
GS-10F-0086K
OMB Paperwork
Reduction Act
Submission for
Survey of Section 202
Sponsors
Part A: Justification
June 14, 2010
Prepared for
Ashaki Robinson Johns, M.S.W.
Office of Policy Development and
Research
US Department of Housing and
Urban Development
451 7th St. SW, Suite 8120
Washington, DC 20410
Prepared by
Gretchen Locke
Melissa Vandawalker
Abt Associates Inc.
55 Wheeler Street
Cambridge, MA 02138

Table of Contents
Part A: Justification................................................................................................................ 1
A1 Circumstances That Make the Collection of Information Necessary.................... 1
A2 How and by Whom the Data Will Be Used........................................................... 3
A2.1 Project Overview ...................................................................................... 3
A2.2 Purpose of the Data Collection ................................................................. 4
A2.3 Who Will Use the Information ................................................................. 5
A2.4 Instrument Item-by-Item Justification ...................................................... 6
A3 Use of Improved Technologies............................................................................ 12
A4 Efforts to Avoid Duplication ............................................................................... 13
A5 Involvement of Small Entities ............................................................................. 14
A6 Consequences of Less Frequent Data Collection ................................................ 14
A7 Special Circumstances ......................................................................................... 14
A8 Consultations Outside the Agency....................................................................... 14
A9 Payments to Respondents .................................................................................... 15
A10 Arrangements and Assurances Regarding Confidentiality.................................. 15
A11 Sensitive Questions.............................................................................................. 15
A12 Estimate of Annualized Burden Hours ................................................................ 15
A13 Estimated Record Keeping and Reporting Cost Burden on Respondents ........... 15
A14 Estimated Cost to the Federal Government ......................................................... 16
A15 Reasons for Changes in Burden........................................................................... 16
A16 Tabulation Plan, Statistical Analysis, and Study Schedule ................................. 16
A17 Expiration Date Display Exemption .................................................................... 17
A18 Exceptions to Certification .................................................................................. 17
Appendix: Federal Register Notice ................................................................................... A-1

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Part A: Justification
A1

Circumstances That Make the Collection of Information
Necessary

This request is for the clearance of a telephone survey instrument for the evaluation of the
Housing and Urban Development’s Section 202 Demonstration Planning Grant program.
The Section 202 Supportive Housing for the Elderly program, established under the Housing
Act of 1959, provides capital advances and operating funding in the form of Project Rental
Assistance Contracts (PRACs) to nonprofit “sponsors” to develop and operate housing for
very low-income seniors. Section 202 awards can also be used to fund full-time service
coordinators who assist residents with their daily living needs and connect them to supportive
services in the community.
The Section 202 program is funded by competitive grants (capital advances) administered by
HUD’s Office of Housing’s Multifamily HUBs and Program Centers, or “field offices.”
Section 202 capital advance awardees include a wide range of types of organizations, from
large national organizations with extensive Section 202 development experience, such as
National Church Residences, Catholic Charities, and Volunteers of America, to local
community and faith-based organizations that may not have in-house development expertise.
Before construction can start, sponsors need to complete several activities during the
predevelopment period, including design, permitting, zoning, and environmental site
assessments. HUD guidelines stipulate that these predevelopment activities should be
completed within 18 months, but the field office can extend up to 24 months. If additional
time is needed beyond 24 months, the sponsor may request a waiver. Waivers for additional
Section 202 funding can also be granted for exceptional circumstances that are beyond the
control of the sponsor. Both waivers for additional time and waivers for additional funding
must be submitted to and approved by the field office and HUD Headquarters.
HUD’s goal is for Section 202 properties to reach initial closing within 18 months of fund
reservation. However, a 2003 General Accounting Office (GAO) report1 found that
approximately 70 percent of Section 202 properties funded between 1998 and 2000 did not
meet HUD’s target for gaining approval to start construction within 18 months of fund
reservation. The GAO report also stated that properties that did not meet the timeline took an
average of 29 months, contributing to unexpended fund balances. Sponsors and field office
respondents attributed the delays to a number of factors, including a lack of predevelopment
funding.
1

Government Accountability Office (2003). Elderly Housing: Project Funding and Other Factors Delay
Assistance to Needy Households. Washington, DC.

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The Demonstration Planning Grant Program (DPG) was implemented in fiscal year 2004 in
response to concerns identified in the GAO report. Eligible activities include consulting
services, architectural and engineering services, environmental site assessments, legal fees,
organizational costs, building permits, and relocation expenses. Congress appropriated funds
for the DPG in FY2004; and from FY2004 through FY2008, more than 350 Section 202
sponsors applied for grants. Sponsors can request DPG funding of up to $400,000 per
property. The funding is based on predevelopment cost estimates developed by the sponsor
and submitted with the DPG application.
With five rounds of DPG awards completed, it is a good time to assess the experience and
outcomes of the program both for grant recipients and for Section 202 sponsors that did not
apply for or receive DPG grants. It is important for HUD to understand whether the DPG
program is meeting its stated goal of reducing the predevelopment time period for Section
202 properties. The study will help HUD understand which sponsor and property
characteristics and other factors are associated with faster development of affordable elderly
housing. Information collected from this study will also help HUD better understand the
DPG application and administrative processes and how they affect the development of
Section 202 properties. Between FY2004 and FY2008, approximately two-thirds of Section
202 properties were awarded Demonstration Planning Grants. The study will help HUD
understand why the program is not being fully utilized and whether aspects of the program
deter participation.
The research activities for this project include both quantitative and qualitative analysis of
information on the Section 202 capital advance and DPG programs. The study will draw on
the following sources of information:


Administrative data extracted from HUD systems, including:
 The Development Application Process (DAP) system that tracks properties
receiving funding provided by the Office of Housing;
 The Integrated Real Estate Management System (iREMS) that provides
additional property-level data elements;
 HUD Headquarters’ DPG Selection Spreadsheets that identify properties
awarded DPG funding; and
 Amendment waiver information available in Federal Register notices and
quarterly reports provided by HUD staff.



Semi-structured surveys with HUD field office staff in offices that administer the
Section 202 capital advance and DPG programs; and



Semi-structured surveys with Section 202 project sponsors, including
representatives of sponsors that have received DPG grants (referred to here as

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“recipients”) and those that have not applied for or received DPG grants (referred
to here as “non-recipients”).
This OMB submission addresses the semi-structured surveys with Section 202 sponsors.
OMB approval for the field office surveys is not necessary because the surveys will be
conducted with HUD staff.
This data collection activity is authorized under [12.U.S.C. 170 1z-1], which reads as
follows:
TITLE 12 – BANKS AND BANKING
CHAPTER 13 – NATIONAL HOUSING
Sec. 1701z-1. Research and demonstrations; authorization of appropriations; continuing
availability of funds.
The Secretary of Housing and Urban Development is authorized and directed to undertake
such programs of research, studies, testing and demonstration relating to the mission and
programs of the Department as he determines to be necessary and appropriate.

A2

How and by Whom the Data Will Be Used

A2.1

Project Overview

The study will gather information on the characteristics of Section 202 sponsors and the
properties they develop, including why sponsors do or do not apply for the competitive
program, the effectiveness of the DPG application and administrative processes, and whether
the DPG program reduces delays in the development of affordable housing for very lowincome elderly residents. The survey will be administered to a purposive sample of sponsors
who have developed properties under the Section 202 Supportive Housing for the Elderly
program. Surveys will be conducted with both DPG recipients and non-recipients. Nonrecipients are sponsors who have never applied for or received a DPG.
The survey will be conducted via telephone by trained interviewers. Contingent upon OMB
approval, the survey data collection will be conducted over a 10-week period, beginning in
November 2010.
The goal of the study is to address the following main research questions:


What are the property and sponsor characteristics of DPG recipients and nonrecipients?

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A2.2



Has the DPG helped Section 202 sponsors get to initial closing within the HUD
established timeline requirement of 18 months of fund reservation?



Has the DPG reduced delays in property completion?



Has the DPG reduced the need for amendment fund waivers?



What are HUD field offices’ and sponsors’ experiences with the DPG?



What leads Section 202 sponsors to apply for the DPG or not?



How has the DPG affected the Section 202 development process?



What other factors influence the Section 202 development process?

Purpose of the Data Collection

This research is intended to help HUD better understand sponsor perspectives on the
effectiveness of the DPG program in providing predevelopment funding to help Section 202
properties reach initial closing within 18 months from fund reservation. The study will also
provide HUD information on sponsor perspectives of the marketing of the DPG program by
HUD field office staff, the DPG application process, and the overall administration of the
grant program. The data collection will help HUD understand whether these activities could
be improved to increase sponsor participation in the DPG program and to decrease the
amount of time needed for Section 202 properties to reach initial closing.
Initial preliminary analysis was conducted on the administrative data during the research
design period. The purpose of the analysis was to provide a broad overview of the Section
202 properties that have received the DPG to date and the larger universe of properties
funded by the Section 202 capital advance program over the years. While the study sample
of DPG recipients and non-recipients is drawn from Section 202 properties awarded between
FY2004 and FY2008, the administrative data analysis includes properties funded between
FY1998 and FY2008 in order to look at patterns in processing time from before and after the
introduction of the DPG program.
Over the FY1998-FY2008 administrative data analysis period, a total of 1,497 properties
were funded by the Section 202 program. On average, about 136 properties were funded per
year over this period, although the number of properties funded has trended downward in
recent years. Over the study period of FY2004-FY2008, a total of 50 HUD field offices
administered Section 202 awards, and 47 had at least one property with a DPG award. The
field offices with the largest volume of DPG awards also processed the largest volume of
Section 202 properties during that period.
The preliminary analysis included an analysis of processing time (the period between fund
reservation and initial closing), comparing DPG recipients and non-recipients. Processing

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times varied considerably across Census regions and field offices. Time from Section 202
funding award to initial closing was declining before the DPG program was implemented and
has continued to decline since the DPG launch. However, the duration of the
predevelopment period is still longer than HUD’s recommended time period for many
Section 202 properties, with typically only a quarter of the reaching initial closing in 18
months.
Initial descriptive statistics on processing time showed no appreciable difference between the
DPG recipients and non-recipients in average processing time during each fiscal year. In
fact, for FY2006 and FY2007 awards, fewer DPG recipients reached initial closing in 18
months than non-recipients. This implies that other factors beyond availability of
predevelopment funding influence the duration of the predevelopment period.
Reconnaissance discussions with sponsor and field office staff confirmed that a number of
other factors may intervene, including the need for additional funding to supplement the
capital advance and time for local and HUD approval processes.
In addition to processing time, no appreciable difference was found in the receipt of
amendment waivers between DPG recipients and non-recipients. Non-completions, or
properties that receive a Section 202 award but are terminated before being completed, were
also reviewed as part of the preliminary analysis. Between FY1998 and FY2008, there were
only 71 non-completions, and none was a DPG recipient.
The preliminary data analysis was conducted on initial data extracts obtained in January 2010
for use in the study’s research design. Updated data extracts will be obtained at the start of
the data collection period to update and extend the preliminary descriptive analysis.
Additional analysis using multiple regressions will also be conducted separately during the
data analysis phase of the study. The sponsor DPG recipient and non-recipient surveys will
add to the administrative analysis by providing additional detailed Section 202 sponsor and
property information as well as sponsor perspectives on the DPG program.
Both DPG recipients and non-recipients will be asked about sponsor and property
characteristics that are not available through other data sources. The surveys will capture
information on sponsor knowledge of the DPG program and reasons why sponsors did or did
not apply for the grant. DPG recipients will also be asked about their experience with the
DPG application process, how the program is administered by the HUD field offices, and
how the DPG affects sponsor and property outcomes.
A2.3

Who Will Use the Information

The survey findings will be used to assess the effectiveness of the Demonstration Planning
Grant program in helping Section 202 sponsors reduce delays in the development of
affordable elderly housing. HUD’s Office of Policy Development and Research (PD&R)
will use the survey results to better understand the types of organizations and properties that
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benefit from the DPG program and what factors increase program participation and
effectiveness.
The sponsor surveys will also help inform PD&R about a possible change in the DPG award
process from a competitive grant process to one in which the level of predevelopment
funding is determined by a funding formula. Survey responses will provide information on
which sponsor and property characteristics and other factors are associated with quicker
predevelopment periods and whether the inclusion of a DPG award mitigated any
development delays associated with those characteristics.
HUD’s Office of Housing, which administers the Section 202 and Demonstration Planning
Grant programs, will use the survey results to gain a better understanding of how the DPG
grant program is marketed and administered by HUD field office staff and whether changes
to the application and administrative processes should be considered. The survey results will
also help the Office of Housing understand what factors, other than access to predevelopment
funding, contribute to the untimely processing of Section 202 grants prior to initial closing.
The survey will include questions similar to those asked of sponsors in the 2003 GAO study
about other factors that contribute to development delays. Including these questions will
allow researchers to compare the results from before and after the implementation of the
DPG program to see if other factors affecting processing time have changed.
A2.4

Instrument Item-by-Item Justification

Exhibits 1 and 2 describe the content and reason for inclusion of each question in the survey
instrument. The DPG Recipient and Non-Recipient Surveys are submitted under separate
covers with this OMB submission.

Exhibit 1: Item-by-Item Justification of Survey – DPG Recipients
Question(s)

Content and Reason for Inclusion

Section I:
Knowledge of the
DPG Program

The first section asks about key information on the sponsor organization’s
affordable housing development experience including experience with the
Section 202 and DPG programs. The survey will confirm the accuracy of
HUD’s administrative data on the number of Section 202 and DPG grants
applied for and obtained by the sponsor organization.
In addition to asking about the Section 202 and DPG experience of the
sponsor organization, this section also asks about the respondent’s personal
experience with the grant programs and asks the respondent to rate his or
her overall knowledge of the DPG program. We will use results from these
initial questions to determine if there are any differences in DPG application
rates or processing time based on the previous Section 202 or DPG
experience of the sponsor.

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Exhibit 1: Item-by-Item Justification of Survey – DPG Recipients
Question(s)

Content and Reason for Inclusion

Section II:
Property and
Sponsor
Characteristics of
Recipients

Sponsor and property characteristics that will be collected in this section
include data on the internal development capacity vs. the use of
development consultants or other outside contractors, the percent of
development cost funded by the Section 202 capital advance, other sources
of funding used for the development of the property, and access to
predevelopment funding.
The survey results will provide insight on property and sponsor
characteristics that cannot be determined by administrative data. We will
present survey respondents’ views on whether a DPG award affects a
sponsor’s ability to procure consultants or other outside contractors for the
Section 202 development process. We will present what other sources of
funding sponsors receive for the targeted property and whether the sources
can be used to pay predevelopment costs. From this data, we will analyze
differences in uses of contractors or consultants and access to
predevelopment funding between DPG recipients and non-recipients. We
will also present what percent of the total development cost is funded by the
Section 202 capital advance by region, property size, and predevelopment
time.

Section III:
Marketing of the
DPG Program

This section asks about the respondent organization’s interaction with the
HUD field office about the DPG program both prior to and during the DPG
application process. Respondents are asked how and when HUD field
office staff provided information about the DPG to them, and are asked to
rate HUD field office staff member’s knowledge of the program.
The survey data will help us determine how often and at what point during
the Section 202 award process HUD field office representatives provide
information to sponsors about the DPG and whether the methods or timing
affects whether sponsors apply for the grant. The responses to these
questions will help HUD understand how sponsors are learning about the
DPG program, whether field office staff members are knowledgeable about
the grant program, and whether there are differences in marketing and
program knowledge among field offices.

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Exhibit 1: Item-by-Item Justification of Survey – DPG Recipients
Question(s)

Content and Reason for Inclusion

Section IV: DPG
Application
Process

This section asks the respondent about the DPG application process and
why the respondent’s organization decided to apply for the DPG.
Respondents are also asked if their organization had any other Section 202
properties which were eligible for a DPG but for which sponsors did not
apply, and the reasons the sponsor organizations did not apply.
The survey responses will help us analyze differences in the reasons
sponsors apply for the DPG and determine whether there are differences by
location, field office, sponsor type, and sponsor experience.
Responses to this section will also inform HUD about the effort needed to
complete the DPG application. This section addresses the cost (in hours
and dollars) to the sponsor of applying for the DPG, how difficult sponsors
found the application process to be, and how sponsors estimated the
predevelopment costs required for the application. The purpose of this
analysis is to determine if there are any aspects of the application process
that deter participation in the grant program or add to processing time from
fund reservation to initial closing. From the survey responses, we will
summarize findings on the extent of sponsor resources needed to fulfill the
DPG application requirements and provide averages and ranges of the
reported cost in dollars and staff hours.
Finally, this section will ask about issues sponsors report about the
application process, with particular attention to those that may cause delays
in processing time. This section will also provide information on suggestions
that sponsors may have about the DPG application process.

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Exhibit 1: Item-by-Item Justification of Survey – DPG Recipients
Question(s)

Content and Reason for Inclusion

Section V: DPG
Administration

This section asks questions related to DPG administration including DPG
activities that take place after the sponsor receives the DPG grant award.
The survey asks DPG recipients about their experience with HUD on several
key DPG activities including receiving access to HUD’s Line of Credit
Control System (LOCCS), receiving approval for payment voucher requests,
and moving DPG funds between budget line items. Respondents are asked
how long each step took, whether there were any issues throughout the
processes, and how HUD resolved the issues.
This section will provide valuable information to the HUD Office of Housing
regarding efficiencies of the administration and management of the DPG
program. We will pay particular attention to whether there are any aspects
of the administration of the program that may add to processing time
between fund reservation and initial closing. From the survey results from
this section, we will analyze whether different steps in the administrative
process are completed within reasonable amounts of time, including the
time from grant execution to fund obligation, processing sponsors’ access to
LOCCS in order to drawdown funds, field office LOCCS authorization, and
processing of DPG payment vouchers. We will compare these processes
by field offices to determine any differences in administration.
We will also determine findings on the incidence of sponsors moving DPG
funds between line items after grant award. We will include in our analysis
the proportion of sponsors who say they requested to move funds, the
frequency with which the requests are granted, and whether moving funds
had any effect on processing time. We will also summarize the results of
the sponsor surveys that provide information on the amounts of DPG funds
that are moved, reflecting how accurate sponsors were in their estimates of
predevelopment funding.

Section VI: DPG
Outcomes

This section addresses whether the DPG helps sponsors decrease the time
period between fund reservation for a property and its initial closing and
whether the DPG had any effect on the organization’s ability to access other
development funds outside of the Section 202 program.
The survey responses from this section will add to the administrative data
analyses on the effect of the DPG program. HUD’s administrative data
provides information on the funding categories in which sponsors planned to
spend their DPG, based on approved estimates from the DPG applications.
We will supplement the administrative data on actual DPG fund uses with
results from the sponsor recipient surveys.
Responses from this section will also add to the analysis of administrative
data on processing time. We will analyze what effect the DPG had on
processing time based on opinions of sponsors that received DPGs. We will
also present the opinions of DPG recipients on whether the receipt of DPG
had any effect on the sponsor’s ability to access other sources of funding.

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Exhibit 1: Item-by-Item Justification of Survey – DPG Recipients
Question(s)

Content and Reason for Inclusion

Section VII:
Factors Affecting
Time from Fund
Reservation to
Initial Closing

This section asks what factors, other than access to predevelopment
funding, contribute to the time it takes to process Section 202 grants from
fund reservation to initial closing. DPG recipients are asked about the
impact of certain state and local factors such as zoning, permitting, site
contamination, and litigation on processing time. Respondents are asked
about both the impact of each factor on time between fund reservation and
initial closing for the target property, and whether receipt of a DPG had a
positive, negative, or no effect on the effect of each factor on the
predevelopment process.
From the survey responses, we will present views of sponsor recipients on
the effect of state and local factors on processing time. We will summarize
the percentage of sponsors who stated that each factor had either no
impact, minor impact, moderate impact, or significant impact on the
organization’s ability to reach initial closing within 18 months. Responses to
these questions will be compared to a similar question posed in the survey
of sponsors for the 2003 GAO study to compare differences in the effects of
certain factors from before and after the DPG program was introduced.
Respondents will also be asked in this section for any suggestions for HUD
to aid the timely processing of Section 202 properties or about the Section
202 and DPG programs in general. We will present suggestions that
sponsors may have on what actions HUD could take to aid the timely
processing of Section 202 properties other than the Demonstration Planning
Grant.

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Exhibit 2: Item-by-Item Justification of Survey – DPG Non-Recipients
Question(s)

Content and Reason for Inclusion

Section I:
Experience with
the Section 202
and DPG
Programs

The first section asks about key information on the sponsor organization’s
experience developing affordable housing including specific experience with
the Section 202 program. The survey will confirm the accuracy of HUD’s
administrative data on the number of Section 202 grants applied for and
obtained by the sponsor organization.
We will use results from these initial questions to determine if there are any
differences in processing time based on the previous housing development
experience of the sponsor.

Section II:
Property and
Sponsor
Characteristics of
Recipients

Sponsor and property characteristics that will be collected in this section
include data on the internal development capacity vs. the use of
development consultants or other outside contractors, the percent of
development cost funded by the Section 202 capital advance, other sources
of funding used for the development of the property, and access to
predevelopment funding.
The survey results will provide insight on property and sponsor
characteristics that cannot be determined by administrative data. We will
analyze what other sources of funding sponsors receive for the targeted
property and whether the sources can be used to pay predevelopment
costs. From this data, we will present differences in uses of contractors or
consultants and access to predevelopment funding between DPG recipients
and non-recipients.

Section III: DPG
Knowledge and
Application
Process

This section asks about the respondent organization’s knowledge of the
DPG program at the time the sponsor received the Section 202 award for
the target property. Respondents are asked whether, how and when HUD
field office staff provided information about the DPG to them. Respondents
are also asked about why their organization did not apply for the DPG and if
they would consider applying to the program for future Section 202
properties.
The responses to these questions will help HUD understand how sponsors
are learning about the DPG program, whether there are differences in
marketing among field offices, and why some sponsors do not apply for the
grant. Responses to these questions will help us determine if there are
differences in the marketing of the DPG program between DPG recipients
and non-recipients.
The survey responses in this section will also help us analyze differences in
the reasons sponsors did not apply for the DPG and determine whether
there are differences in location, field office, sponsor type, and sponsor
experience. We will analyze reasons why sponsors did not apply for the
DPG for the sponsor’s target property, including other access to
predevelopment funding or lack of knowledge of the DPG program, and
under what circumstances the sponsor would apply for future properties.

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Exhibit 2: Item-by-Item Justification of Survey – DPG Non-Recipients
Question(s)

Content and Reason for Inclusion

Section IV:
Factors Affecting
Time from Fund
Reservation to
Initial Closing

This section asks what factors, other than access to predevelopment
funding, contribute to the time it takes to process Section 202 grants from
fund reservation to initial closing. Non-recipients are asked about the impact
of certain state and local factors such as zoning, permitting, site
contamination, and litigation on processing time. Respondents are asked
about the impact of each factor on time between fund reservation and initial
closing for the target property.
From the survey responses, we will present views of non-recipients on the
effect of state and local factors on processing time. We will summarize the
percentage of sponsors who stated that each factor had either no impact,
minor impact, moderate impact, or significant impact on the organization’s
ability to reach initial closing within 18 months. Responses to these
questions will be compared to a similar question posed in the survey of
sponsors for the 2003 GAO study to compare differences in the effects of
certain factors from before and after the DPG program was introduced.
Respondents will also be asked in this section for any suggestions for HUD
to aid the timely processing of Section 202 properties or about the Section
202 program in general. We will present suggestions that sponsors may
have on what actions HUD could take to aid the timely processing of Section
202 properties other than the Demonstration Planning Grant.

A3

Use of Improved Technologies

The survey will be administered via telephone by trained interviewers. HUD’s contractor for
this study, Abt Associates, will use the online Checkbox Survey Software program to
administer and compile results for the semi-structured sponsor surveys. Checkbox Survey
Software is a flexible and easy to use online survey software tool for creating surveys and
questionnaires. The surveys will be created, managed, and analyzed on a web browser.
The survey instruments will be created with Checkbox’s Survey Editor. With the Survey
Editor, survey questions can be customized using several different types of programmed
survey questions including single answer, multiple choice, open text, rating scales, and
matrix questions. Checkbox Survey Software’s logic-based functionality allows surveys to
be personalized based on respondents’ responses. The software program also allows
interviewers to upload files to the surveys so that reference material for the specific
respondents will be available during survey administration.
Checkbox’s management interface, Survey Manager, will be used to organize and manage all
the survey responses. Surveys can be viewed by sponsor or field office name, interviewer,
creation date, and completion status.

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Checkbox allows data entry to be accomplished as the sponsor surveys are conducted. The
responses to questions will be collected within Checkbox’s response database and will be
extracted at the end of the data collection period.

A4

Efforts to Avoid Duplication

In designing the DPG recipient and non-recipient surveys, available administrative data on
Section 202 properties and DPG recipients was reviewed to ensure that the survey gathers
only information not available from other sources.
HUD tracks data on the Section 202 and DPG programs through several different databases
and spreadsheets:


Development Application Processing (DAP) System. The DAP system tracks
properties applying for funding provided by the Office of Housing’s programs. It
contains property-level information such as property size, funding amount, fiscal
funding year (FY), construction cost, and application and processing dates.



Integrated Real Estate Management System (iREMS). Additional propertylevel data elements are included in iREMS. These include property and program
characteristics such as building type, occupancy date, location, HUD field office,
and sponsor/owner information.



HUD Headquarters’ DPG Selection Spreadsheets. Properties awarded DPG
funding are identified in spreadsheets obtained from HUD Headquarters staff.
The spreadsheets contain property-level information such as property ID number,
DPG funding amount, funding FY, and sponsor/owner information.



Waivers information. Amendment waivers information for the Section 202
properties is available in Federal Register notices and quarterly reports provided
by HUD staff. The following information has been identified for each waiver
granted: the property ID number, type of amendment waiver (funding or
processing time), date of waiver granted, and reason for the waiver.

While HUD maintains databases and spreadsheets of basic information about grants made
under the Section 202 and DPG programs, the data does not include detailed property and
sponsor information such as other sources of development funding, use of consultants or
other outside contractors, and the housing development experience of the sponsor
organization. The available data does not include information on why sponsors do or do not
apply for the DPG or how the DPG program is marketed and administered by HUD field
offices. The surveys will also address sponsor opinions on whether receipt of a DPG
decreased the development delays in the delivery of Section 202 housing.

Abt Associates Inc.

Part A: OMB Paperwork Reduction Act Submission
for Telephone Survey of Section 202 Sponsors

A-13

Since there is no comparably detailed information on the program characteristics, processes,
and outcomes of HUD’s Section 202 DPG program, the sponsor DPG recipient and nonrecipient surveys will help fill this gap. The surveys will provide information on the
experiences and opinions of sponsors that may help identify program inefficiencies and guide
policy decisions.

A5

Involvement of Small Entities

No small businesses or other small entities are involved as respondents in the proposed data
collection effort. Respondents to this data collection are nonprofit sponsors of Section 202funded properties. Efforts have been made to minimize response burden on respondents
through careful design of the data collection strategy and efficient construction of the data
collection instrument. All data collection is voluntary.

A6

Consequences of Less Frequent Data Collection

Not applicable. This is a one-time data collection effort.

A7

Special Circumstances

The proposed data collection activities are consistent with the guidelines set forth in 5 CFR
1320.6 (Controlling Paperwork Burden on the Public—General Information Collection
Guidelines). There are no special circumstances that require deviation from these guidelines.

A8

Consultations Outside the Agency

In accordance with the Paperwork Reduction Act of 1995, HUD published on May 6, 2010 a
notice in the Federal Register announcing the agency’s intention to request an OMB review
of data collection activities for the Evaluation of the Section 202 Demonstration Planning
Grant program. The notice provided a 60-day period for public comments. The Federal
Register Notice is included as an appendix.
HUD’s contractor, Abt Associates, developed this data collection instrument in consultation
with staff from HUD. Representatives of HUD’s Office of Policy Development and
Research reviewed the instrument. In addition, five sponsor representatives who are not part
of the sponsor sample will review the survey instruments to ensure the correct terminology is
used and to test the flow of the survey including skip patterns. The sponsor representatives
include three DPG recipients and two non-recipients. Pre-testing of the survey instrument
will be completed in June 2010.

Abt Associates Inc.

Part A: OMB Paperwork Reduction Act Submission
for Telephone Survey of Section 202 Sponsors

A-14

A9

Payments to Respondents

There will be no payments to respondents. Respondents will be informed that their responses
are important to helping HUD learn more about the Section 202 and DPG programs.

A10 Arrangements and Assurances Regarding Confidentiality
None of the questions asked in the survey is considered sensitive. Therefore, for this study,
there is no need to arrange for confidentiality.

A11 Sensitive Questions
The survey does not contain any questions that are considered sensitive.

A12 Estimate of Annualized Burden Hours
Exhibit 3 provides information on the survey to be used in the study and the estimated time
to complete the data collection. Total burden for data collection for the study is estimated at
101 hours.
For the DPG recipient survey, the researchers will administer a one-time telephone survey to
70 sponsor staff. These interviews are expected to last 45 minutes. An additional 20 minutes
will be needed to compile material needed to complete the survey, for a total burden hour
estimate of 76 hours. For the non-recipient survey, the researchers will administer a one-time
telephone survey to 30 sponsor staff. The burden estimates for the non-recipient interviews
are 30 minutes for the telephone survey administration and 20 minutes to compile material
needed to complete the survey, for a total burden hour estimate of 25 hours.
Exhibit 3: Estimate of Burden Hours

Respondents

Number of
Respondents

Number responses
per respondent

Average burden/
response
(in hours)

Total burden
hours

DPG Recipients

70

1

1.08

76

Non-Recipients

30

1

0.83

25

100

100

Total

101

A13 Estimated Record Keeping and Reporting Cost Burden on
Respondents
There is no cost to respondents, other than the time required to respond to the survey.

Abt Associates Inc.

Part A: OMB Paperwork Reduction Act Submission
for Telephone Survey of Section 202 Sponsors

A-15

A14 Estimated Cost to the Federal Government
The total contracted cost to the federal government for the Telephone Survey of Section 202
Sponsors is $50,775. This includes $44,530 in labor (indirect costs and fee are included in
labor rates) and $6,245 in direct costs.

A15 Reasons for Changes in Burden
This submission to OMB is a new request for approval; there is no change in burden.

A16 Tabulation Plan, Statistical Analysis, and Study Schedule
Data collection is scheduled to begin in November 2010 assuming 16-week OMB review
period. The sponsor survey data collection period will run eight weeks, through December
31, 2010. The survey will be conducted by Abt Associates’ research staff who will
administer the survey and compile a database of survey responses for analysis purposes.
Each survey record will be assigned a unique identifier.
Data analysis of the sponsor survey responses will begin following completion of the data
collection period in January 2011. A draft report of the findings will be completed on March
11, 2011 with a final report submitted on April 22, 2011. The data documentation will be
submitted the following week on April 29, 2011.
The primary objective of this analysis will be to analyze the effectiveness of the
Demonstration Planning Grant program and whether the program helped reduce development
delays in the Section 202 Supportive Housing for the Elderly program. Analysis will
compare the outcomes and sponsor and property characteristics of DPG recipients and nonrecipients, as well as the opinions of sponsors on the DPG application and administrative
processes.
The analysis of survey results will include:


Additional Section 202 sponsor and property characteristics that are not available
from HUD administrative data sources.



Findings on the degree of awareness and knowledge that sponsors have about the
DPG program.



Whether there are any aspects of the DPG application process that deter
participation in the grant program or add to processing time from fund reservation
to initial closing.



Whether there are any aspects of the administration of the program that may add
to processing time between fund reservation and initial closing.

Abt Associates Inc.

Part A: OMB Paperwork Reduction Act Submission
for Telephone Survey of Section 202 Sponsors

A-16



Comparison of outcomes for properties for which the sponsors received a DPG to
those for properties that did not receive a DPG, including amendment waiver
requests, the sponsor’s ability to access other sources of funding, what other
sources of funding sponsors receive, and the ability to obtain outside development
consultants or contractors.



Opinions of sponsors that received DPGs on the effect the DPG had on
predevelopment processing time and the effect the DPG had on other factors that
affect processing time.



What issues, other than access to predevelopment funding, affect sponsors’ ability
to reach initial closing within the recommended 18 month timeframe.



Suggestions that sponsors may have on what actions HUD could take to aid the
timely processing of Section 202 properties other than the Demonstration
Planning Grant.

A17 Expiration Date Display Exemption
All data collection instruments will prominently display the expiration date for OMB
approval.

A18 Exceptions to Certification
This submission describing data collection requests no exceptions to the Certificate for
Paperwork Reduction Act (5 CFR 1320.9).

Abt Associates Inc.

Part A: OMB Paperwork Reduction Act Submission
for Telephone Survey of Section 202 Sponsors

A-17

Appendix: Federal Register Notice

Abt Associates Inc.

Part A: OMB Paperwork Reduction Act Submission
for Telephone Survey of Section 202 Sponsors

A-1

Federal Register / Vol. 75, No. 87 / Thursday, May 6, 2010 / Notices
control number 2528–0256.
Approximately 1,430 DHAP participants
responded to the baseline survey.
Respondents were contacted in JanuaryFebruary 2010 to update their contact
information under the same OMB
control number.
A 12-month follow-up survey of
respondents to the baseline survey is
planned for fall 2010 and is the subject
of this notice. The survey will collect
data on participants’ housing
employment, income, and savings/debt
outcomes approximately 12 to 15
months after they transitioned off DHAP
assistance. The survey also will ask
about participants’ experiences with the
alternative strategies employed by
participating public housing authorities
(PHAs) for providing case management
to help households with the recovery
process. The information collected
through these surveys will be
supplemented by administrative data on
participant characteristics and program
services (including rental assistance and
case management) collected during
program operation. The participant
survey will take approximately 40
minutes per respondent to complete.
Members of affected public: The data
collection effort for the DHAP IRT Study
initially involved a baseline survey
conducted under OMB control number
2528–0256. Approximately 1,430 DHAP
participants responded to the baseline
survey. Respondents were contacted in
January-February 2010 to update their
contact information under the same
OMB control number.
Estimation of the total number of
hours needed to prepare the information
collection, including the number of
respondents, frequency of response, and
hours of response: The researchers will
survey 1,430 participants in all; the
surveys are expected to last 40 minutes.
This constitutes a total burden hour
estimate of 958 burden hours.
Status of the proposed information
collection: Pending OMB approval.

mstockstill on DSKH9S0YB1PROD with NOTICES

Authority: Section 3506 of the Paperwork
Reduction Act of 1995, 44 U.S.C. Chapter 35,
as amended.
Dated: April 20, 2010.
Raphael W. Bostic,
Assistant Secretary for Policy Development
and Research, R .
[FR Doc. 2010–10687 Filed 5–5–10; 8:45 am]
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DEPARTMENT OF HOUSING AND
URBAN DEVELOPMENT
[Docket No. FR–5382–N–09]

Notice of Proposed Information
Collection for Public Comment: 202
Demonstration Planning Grant
Evaluation
AGENCY: Office of Policy Development
and Research, HUD.
ACTION: Notice.
SUMMARY: The proposed information
collection requirement described below
will be submitted to the Office of
Management and Budget (OMB) for
review, as required by the Paperwork
Reduction Act. The Department is
soliciting public comments on the
subject proposal.
DATES: Comments Due Date: July 6,
2010.

Interested persons are
invited to submit comments regarding
this proposal. Comments should refer to
the proposal by name and/or OMB
Control Number and should be sent to:
Ashaki Robinson Johns, Office of Policy
Development and Research, Department
of Housing and Urban Development,
451 7th Street, SW., Suite 8120,
Washington, DC 20410.
FOR FURTHER INFORMATION CONTACT:
Ashaki Robinson Johns (202) 402–7545,
(this is not a toll free number) for copies
of the proposed forms and other
available documents.
SUPPLEMENTARY INFORMATION: The
Department will submit the proposed
information collection to OMB for
review, as required by the Paperwork
Reduction Act of 1995 (44 U.S.C.
Chapter 35, as amended). This notice is
soliciting comments from members of
the public and affected agencies
concerning the proposed collection of
information to: (1) Evaluate whether the
proposed collection of information is
necessary for the proper performance of
the functions of the agency, including if
the information will have practical
utility; (2) Evaluate the accuracy of the
agency’s estimate of the burden of
proposed collection of information; (3)
Enhance the quality, utility, and clarity
of the information to be collected; and
(4) Minimize the burden of the
collection of information on those who
are to respond; including through the
use of appropriate automated collection
techniques or other forms of information
technology, e.g., permitting electronic
submission of responses.
Title of Proposal: Research Plan for an
Evaluation of the Section 202
Demonstration Planning Grant Program.
ADDRESSES:

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24963

Description of the need for
information and proposed use: The
Department is conducting, through a
contract to Abt Associates Inc. and its
subcontractor, VIVA Consulting LLC, a
study of the Section 202 Supportive
Housing for the Elderly Demonstration
Planning Grant Program. The Section
202 Supportive Housing for the Elderly
program provides capital advances and
operating funds to nonprofit
organizations (‘‘sponsors’’) to develop
affordable elderly housing. HUD’s goal
for Section 202 properties is for
sponsors to reach initial closing within
18 months of fund reservation.
However, a 2003 study of the Section
202 program by the Governmental
Accountability Office (GAO) found that
approximately 70 percent of Section 202
properties funded between 1998 and
2009 did not meet this goal and that
properties that did not meet the 18month timeline took an average of 29
months to reach initial closing. The
predevelopment delays were attributed
to a number of factors, including the
lack of predevelopment funding.
The Section 202 Demonstration
Planning Grant Program (DPG) was
created in 2004 to provide
predevelopment funding to Section 202
sponsors to reduce development delays
and increase the number of affordable
rental units made available each year for
low-income elderly households. This
evaluation will assess the awareness
and effectiveness of the program
through telephone surveys with project
sponsors. The key research question is
whether the DPG helps sponsors get
from Section 202 award to initial
closing on the project within 18 months,
HUD’s target duration for the
predevelopment period.
To collect the information necessary
for this study, the Department will
conduct a telephone survey of staff
members from a sample of sponsor
organizations. The surveys will be
conducted with both staff from sponsor
organizations that have received
Demonstration Planning Grants (‘‘DPG
recipients’’) and staff from sponsor
organizations that have received Section
202 funding between fiscal years 2004
and 2008 but have not received a
Demonstration Planning Grant (‘‘nonrecipients’’). Surveys will be conducted
with 70 DPG recipients and 30 nonrecipients. The samples will be selected
purposively to provide geographic
diversity by Census region and a range
of durations of predevelopment periods.
DPG recipients will be asked about
their knowledge of and experience with
the DPG program and how the DPG and
other factors influenced their ability to
reach initial closing within 18 months.

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24964

Federal Register / Vol. 75, No. 87 / Thursday, May 6, 2010 / Notices

Non-recipients will be asked about their
familiarity with the DPG program, the
reasons they did not apply for the
program, and the factors that
contributed to their ability to reach
initial closing within 18 months.
Members of Affected Public: The
telephone sponsor survey will affect
approximately 100 recipients of a

Section 202 Supportive Housing for the
Elderly grant.
Estimation of the total number of
hours needed to prepare the information
collection including number of
respondents, frequency of response, and
hours of response: For the DPG recipient
survey, the researchers will administer
a one-time telephone survey to 70
Number of
respondents

Respondents

Number responses per
respondent

Average burden/response
(in hours)

Total burden
hours

DPG Recipients ...............................................................................................
Non-recipients ..................................................................................................

70
30

1
1

1.0
0.5

70
15

Total ..........................................................................................................

100

100

........................

85

Status of the proposed information
collection: Pending OMB approval.

Dated: April 28, 2010.
Raphael W. Bostic,
Assistant Secretary for Policy Development
and Research.
[FR Doc. 2010–10689 Filed 5–5–10; 8:45 am]
BILLING CODE 4210–67–P

DEPARTMENT OF THE INTERIOR
Fish and Wildlife Service
[FWS-R4-R-2010-N091] [40137-1263-00000X]

Proposed Information Collection; OMB
Control Number 1018-NEW; Refuge
Daily Visitor Use Report and Check-In
Permit
AGENCY: Fish and Wildlife Service,
Interior.
ACTION: Notice; request for comments.
SUMMARY: We (Fish and Wildlife
Service) will ask the Office of
Management and Budget (OMB) to
approve the information collection (IC)
described below. As required by the
Paperwork Reduction Act of 1995 and
as part of our continuing efforts to
reduce paperwork and respondent
burden, we invite the general public and
other Federal agencies to take this
opportunity to comment on this IC. We
may not conduct or sponsor and a
person is not required to respond to a
collection of information unless it
displays a currently valid OMB control
number.
DATES: To ensure that we are able to
consider your comments on this IC, we
must receive them by July 6, 2010.

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Send your comments on the
IC to Hope Grey, Information Collection
Clearance Officer, Fish and Wildlife
Service, MS 222–ARLSQ, 4401 North
Fairfax Drive, Arlington, VA 22203
(mail); or [email protected] (e-mail).
FOR FURTHER INFORMATION CONTACT: To
request additional information about
this IC, contact Hope Grey by mail or email (see ADDRESSES) or by telephone
at (703) 358–2482.
SUPPLEMENTARY INFORMATION:
ADDRESSES:

Authority: Section 3506 of the Paperwork
Reduction Act of 1995, 44 U.S.C. Chapter 35,
as amended.

mstockstill on DSKH9S0YB1PROD with NOTICES

sponsor staff. These interviews are
expected to last 60 minutes for a total
burden hour estimate of 70 hours. For
the non-recipient survey, the
researchers will administer a one-time
telephone survey to 30 sponsor staff.
The non-recipient interviews are
expected to last 30 minutes for a total
burden hour estimate of 15 hours.

I. Abstract
The National Wildlife Refuge System
Administration Act of 1966 (16 U.S.C.
668dd-668ee), as amended by the
National Wildlife Refuge System
Improvement Act of 1997, and the
Refuge Recreation Act of 1962 (16
U.S.C. 460k-460k-4) govern the
administration and uses of national
wildlife refuges and wetland
management districts. We are
authorized to permit public uses on
lands of the National Wildlife Refuge
System, including hunting, fishing,
wildlife observation, wildlife
photography, and environmental
education and interpretation, and other
visitor uses when we find that the
activities are compatible and
appropriate with the purpose or
purposes for which the refuges were
established.
We collect information on hunters
and anglers and other visitors in order
to protect refuge resources and
administer and evaluate the success of
visitor programs. Because of high
demand and limited resources, we often
provide visitor opportunities by permit,
based on dates, locations, or type of
public use. We may not allow all
opportunities on all refuges and harvest
information differs on each refuge.
Therefore, we are proposing two forms
to collect this information. Not all

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refuges will use each form and some
refuges may collect the information in a
nonform format. We propose to collect:
• Information on the visitor (name,
address, and contact information).
• Whether or not hunters/anglers were
successful (number and type of harvest/
caught).
• Purpose of visit (hunting, fishing,
wildlife observation, wildlife
photography, auto touring, birding,
hiking, boating/canoeing, visitor center,
special event, environmental education
class, volunteering, other recreation).
• Date of visit.
This information will be a vital tool in
meeting refuge objectives and
maintaining quality visitor experiences.
The above information will help us:
• Administer and monitor visitor
programs and facilities on refuges.
• Distribute visitor permits to ensure
safety of visitors.
• Ensure a quality visitor experience.
• Minimize resource disturbance,
manage healthy game populations, and
ensure the protection of fish and
wildlife species.
• Assist in Statewide wildlife
management and enforcement and
develop reliable estimates of the number
of all game fish and wildlife.
• Determine facility and program
needs and budgets.
II. Data
OMB Control Number: 1018-XXXX.
Title: Refuge Daily Visitor Use Report
and Check-In Permit.
Service Form Number(s): 3-2405 and
3-2406.
Type of Request: Request for a new
OMB control number.
Affected Public: Visitors to national
wildlife refuges.
Respondent’s Obligation: Required to
obtain or retain a benefit.
Frequency of Collection: On occasion.

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06MYN1