JUSTIFICATION STATEMENT
EXPLAIN THE CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY.
The Federal Transit Administration (FTA) provides financial assistance to states, local governments, private nonprofit agencies, and public bodies through the 49 U.S.C. Section 5311 Program for transportation services in nonurbanized areas. The Rural Transit Assistance Program (RTAP), a subsection of Section 5311, provides for training, technical assistance and related activities to support rural public transportation. FTA provides transportation services designed to meet the needs of elderly persons and persons with disabilities through the Section 5310 Program.
The provisions of 49 U.S.C. Sections 5310 and 5311, 49 CFR Part 18, “Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments,” and 49 CFR Part 19, “Uniform Administrative Requirements for Grants and Cooperative Agreements with Institutions of Higher Education, Hospitals, and other Non-profit Organizations,” require that FTA review Section 5310 and Section 5311 applications for federal financial assistance. This review assesses eligibility and compliance with statutory and administrative requirements and provides a basis for monitoring approved projects to ensure timely and appropriate expenditure of federal funds by grant recipients. The applications must contain enough information to enable the agency to make the findings required by law and enforce program requirements.
Although differences exist in the administration of these two programs, the information collection under each program is structured to comply with legislative and administrative mandates. Generally, the reporting requirements are identical and are submitted by grantees in two stages: the application stage and the project management stage. Since both the Section 5310 and Section 5311 programs are administered by the states, application and reporting requirements to FTA have been streamlined and minimized as much as possible. For each program, the state submits a consolidated annual application on behalf of all the subrecipients within the state. The subrecipients do not submit any information directly to FTA, but are required by the state to file sufficient documentation to support the assurances and certifications the state must make on their behalf.
During the application stage, FTA must determine the applicant’s eligibility to receive program funds. FTA must know: (a) who the applicant is; (b) for what purpose the funds are requested; and (c) the amount of federal funds requested.
Project planning requirements should be complete and properly documented prior to submitting grant application.
A description of the application stage requirements, as included in the program circulars, follows:
The Project Budget identifies funds for project implementation. The applicant prepares the program budget, which identifies the local and federal shares that make up the project funding. The identification of the amounts of the local and federal shares is necessary for project approval.
The Program of Projects includes a list of subrecipients that will be funded, the total amount of funds for each subrecipient, and a description of the projects to be funded. Only certain categories of transit projects are eligible for funding, and the project description enables FTA to determine whether funding of the proposed project is permissible under the law. These project descriptions usually consist of a list of capital acquisitions planned, or the period of operating assistance, or type of service to be funded. The projects are listed in three categories: those which have already met all requirements and can be initiated as soon as approved, those which are expected to complete all requirements during the year, and a program reserve for unanticipated needs. Once the program of projects is approved, the state has considerable flexibility to make revisions without further FTA concurrence.
The Project Implementation Plan is a brief plan for implementation of the program of projects. The plan should include significant milestones such as vehicle procurements and agreements with subrecipients, an estimated schedule for encumbrance of funds, and an estimated completion date for the grant.
The State Management Plan describes the grantee’s policies and operating procedures in administering the programs. The submission of this information is on a one-time basis. The information enables FTA to ascertain that the grantee’s administration of the programs is consistent with federal policies without conducting repeated inspections and detailed supervision of each grantee’s procedures. Significant changes in program procedures are reflected in revisions to the State Management Plan.
Annual Certifications and Assurances certify compliance with all applicable related federal requirements. The annual notice, published in the Federal Register, provides the applicant with a single signature page on which the applicant and its attorney certify compliance with all certifications and assurances applicable to each grant for which the applicant wishes to apply in each fiscal year.
Public Hearings Notice, Certifications, and Transcripts. Section 5311 applicants and Section 5310 applicants, which include public bodies among their
subrecipients, are required to certify that a hearing was held or the opportunity for
a hearing was provided for each project for which an application was submitted. The transcripts for any such hearings held must be retained by the states and made available to FTA upon request.
Upon notice of approval of the program of projects, the grantee may begin implementation of project elements. The reporting requirements, listed below, are necessary to ensure proper and timely expenditure of federal funds within the scope of the approved program of projects. This requirement complies with 49 CFR Parts 18 and 19 and is contained in the above-referenced FTA circulars.
Financial Status Report. On an annual basis, the state should provide a financial
status report (SF 269a) for each active grant.
Annual Program Status Report. The information collected is essentially an update
of the program of projects for each active grant.
2. INDICATE HOW, BY WHOM, AND FOR WHAT PURPOSE THE
INFORMATION IS TO BE USED.
The information collected is used by the FTA to determine eligibility for grant
benefits and ensures compliance with federal requirements. The information is also
used by FTA for program management and evaluation. Without the information FTA
could not make the findings statutorily required in order to make grants under these
programs, nor could it administer the programs in accordance with congressional
intent.
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.
FTA’s Section 5310 and Section 5311 grant applications and project management reports are submitted electronically (100 percent) through the Transportation Electronic Award and Management (TEAM) System. This electronic system allows grantees to apply for funds, seamlessly receive information about their requests and provide overall project management. The TEAM system has a point-and-click capability, menus and selection choices designed to streamline the application process and significantly reduce the amount of information a user needs to input. It effectively elevates the management of the federal assistance application and
administration process to the users’desktop and reduces dependency on paper copies.
Since FTA last reported, some enhancements have been made to the TEAM system. Grantees can now attach documents as part of their TEAM application, allowing them
to include required information (such as programs or projects) that they may have readily available for other program purposes as an attachment, rather than transferring the data into appropriate TEAM fields. In addition, the TEAM system is now a web-based system, allowing our grantees greater accessibility to the system and ensuring fewer delays due to restrictions inherent in the former disk-based system.
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.
Through consultation with grantees, FTA has streamlined the information collection to eliminate duplication. Many requirements have been satisfied with one-time submissions that must be updated only when significant changes occur.
The information is project specific and is not available elsewhere. The statute specifically requires projects to be funded under Section 5311 and included in an annual state program of projects. It also directs the federal agency to make specific findings in order to approve funding. Whenever possible, one-time submissions have been substituted for repeated or potentially duplicative submissions.
5. IF THE COLLECTION OF INFORMATION IMPACTS SMALL BUSINESS OR
OTHER SMALL ENTITIES, DESCRIBE THE METHODS USED TO MINIMIZE
BURDEN.
The information collection does not involve small businesses.
6. DESCRIBE CONSEQUENCES TO FEDERAL PROGRAM OR POLICY
ACTIVITIES IF THE COLLECTION WERE CONDUCTED LESS
FREQUENTLY AS WELL AS ANY TECHNICAL OR LEGAL OBSTACLES
TO REDUCING BURDEN.
The information that is collected during the application stage must be collected
annually because grantees submit one annual grant during a fiscal year. Section 5311
and Section 5310 funds are apportioned to the states each fiscal year.
During the project management stage an annual financial report and an annual
program status report are submitted. These reports provide needed financial
information on the grant and a status of the program of projects.
The information collected during the application stage and the project management stage is required to ensure FTA’s compliance with the provisions of the Federal Transit Act and 49 CFR. If the information were collected less frequently than required during the application stage and the project management stage, it would inhibit FTA from determining the applicant’s eligibility for funding. Also, less frequent submissions would reduce the effectiveness of FTA’s monitoring responsibility required by 49 CFR Parts 18 and 19.
7. EXPLAIN ANY SPECIAL CIRCUMSTANCES THAT REQUIRE THE
COLLECTION TO BE CITED IN A MANNER INCONSISTENT WITH THE
GUIDELINES IN 5 CFR 1320.6.
The information collected is consistent with the guidelines in 5 CFR 1320.6.
AGENCY.
A 60-day Federal Register notice was published on May 21, 2010, (pages 68673 and
68674), soliciting comments prior to submission to the Office of Management and budget (OMB). No comments were received from that notice. A 30-day Federal Register notice was published on August 3, 2010, (pages 45694 and 45695).
A national meeting of state program managers is held every other summer to discuss program administration issues. Approximately 90 program managers attend these meetings, representing most of the states.
In preparing this report, several state grantees were consulted regarding the times it takes them to provide the information collected by FTA.
9. EXPLAIN ANY DECISION TO PROVIDE ANY PAYMENT OR GIFT TO
RESPONDENTS, OTHER THAN REMUNERATION OF CONTRACTORS OR
GRANTEES.
No payment or gift is made to respondents.
10. DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO
RESPONDENTS AND THE BASIS FOR ASSURANCE IN STATUTE,
REGULATION, OR AGENCY POLICY.
FTA gives no assurance of confidentiality since the information is not personal or
sensitive in nature. All information collected is certified to comply with the Freedom
of Information Act, the Privacy Act, and 49 CFR Parts 18 and 19.
11. PROVIDE ADDITIONAL JUSTIFICATION FOR ANY QUESTIONS OF
SENSITIVE NATURE.
No questions of a sensitive nature are involved.
12. PROVIDE ESTIMATES OF THE HOUR BURDEN OF THE COLLECTION OF
INFORMATION AND ANNUALIZED COST TO RESPONDENTS.
Annually, it is estimated to take 40 hours of application preparation and 49
hours of project management per 52 respondents (the trust territories of Guam,
America Samoa, and the Northern Marianas and the State of North Carolina) for
the Section 5310 Program).
Application Stage:
52 respondents x 40 hours = 2,080 hours
Completion of HHS’s SF 424 (grants.gov application form)
52 respondents x 1 hour = (52) hours
Total Application Stage = 2,080 hours
Project Management Stage:
52 respondents x 49 hours = 2,548 hours
Total Burden Hours for Section 5310 Program = 4,628 hours
(2,080 hours – application stage + 2,548 hours – project management stage)
The burden for both programs was estimated by contacting state program managers in
several states with programs of varying size and complexity. Their responses were
combined into an average of the typical state burden and hourly staff wage rate.
Annually, it is estimated to take 73 hours of application preparation and 55 hours of
project management per 55 respondents (50 states and 5 territories), for the Section
5311 Program.
Application Stage:
55 respondents x 73 hours = 4,015 hours
Completion of HHS’s SF 424 (grants.gov application form)
55 respondents x 1 hour = (55) hours
Total Application Stage = 4,015 hours
Project Management Stage:
55 respondents x 55 hours = 3,025 hours
Total Burden Hours for Section 5311 Program = 7,040 hours
(4,015 hours – application stage + 3,025 hours – project management stage)
Total Burden for Both Programs: Section 5310 4,628 hours
Section 5311 7,040 hours
Total 11,668 hours
The total number of burden hours associated with this request is 11,668 hours. A
total of 107 hours (52 for the 5310 Program and 55 for the 5311 Program) are
associated with the use of HHS’s Standard Form 424 (grants.gov application form),
as shown, and have been assigned to HHS’s information collection approval for their
Standard Form 424.
The estimated cost to the respondents is calculated as follows:
Section 5310 $30 per hour x 4,628 hours = $138,840
Total cost to respondents $350,040
13. PROVIDE AN ESTIMATE OF THE TOTAL ANNUAL COST BURDEN TO
RESPONDENTS OR RECORDKEEPERS RESULTING FROM THE
COLLECTION OF INFORMATION.
There are no additional costs beyond those shown in Items 12 and 14.
14. ESTIMATES OF ANNUALIZED COST TO THE FEDERAL GOVERNMENT
This cost is calculated as follows:
It takes approximately 17 hours to review each application at $32 per hour (GS-12/5)
from 107 respondents (49 states and 2 U.S. territories and the District of Columbia for
Section 5310 Program and 50 states and 5 U.S. territories for Section 5311 Program).
Therefore:
17 hours per respondent x $32 per hour = $544 x 107 respondents = $58,208
annually for both programs.
Project management activities annually take approximately 41 hours per respondent
at $32 per hour.
Therefore:
41 hours per respondent x $32 per hour = $1,312 x 55 respondents = $72,160
annually for both programs.
Application Review $58,208
Project Management $72,160
Total cost to federal government $130,368
15. EXPLAIN REASONS FOR ANY PROGRAM CHANGES OR ADJUSTMENTS
REPORTED IN ITEMS 13 OR 14 OR OMB FORM 83 – I.
The total number of burden hours associated with this request is 11,668 hours. A
burden reduction of 107 hours from the last approved collection reflects a correction,
appropriately accounting for burden associated with HHS's SF 424. These burden
hours have been reassigned to HHS, under HHS's information collection approval for
their SF 424.
16. PLANS FOR TABULATION AND PUBLICATION OF COLLECTION OF
INFORMATION WHOSE RESULTS WILL BE PUBLISHED.
There are no plans to publish the results of this information collection for statistical
use.
17. IF SEEKING APPROVAL NOT TO DISPLAY THE EXPIRATION DATE FOR
OMB APPROVAL, EXPLAIN THE REASONS.
There is no reason not to display the expiration date of OMB approval.
18. EXPLAIN ANY EXCEPTIONS TO THE CERTIFICATION STATEMENT
IDENTIFIED IN ITEM 19 OF OMB FORM 83-I.
No exceptions are stated.
| File Type | application/msword |
| File Title | JUSTIFICATION STATEMENT |
| Author | MasselinkS |
| Last Modified By | sylvia.marion |
| File Modified | 2010-12-16 |
| File Created | 2010-12-16 |