Narrative of Changes

Changes to Collection OMB No. 1660-0072

The following questions have been updated since the last OMB Approval:

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.

Currently all grant applications for the PDM, RFC, SRL, and FMA programs are submitted via e-Grants.  The use of the e-Grants system by respondents allows for 100% of the information required to be submitted electronically.  The individual FEMA Forms can be accessed at http://www.fema.gov/help/forms.shtm. 

Respondents can access e-Grants through the Website https://portal.fema.gov/famsVuWeb/home.  New users may access the e-Grants system by selecting the new user button and then entering in the required information in order to be approved for a user name and password. Step-by-step directions to receive a user name and password for the e-Grants system is located on page 12 of the Grant Applicants Quick Reference Guide located on the FEMA.gov website at the following link: http://www.fema.gov/library/viewRecord.do?id=3266.



12. Provide estimates of the hour burden of the collection of information. The statement should:



 a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated for each collection instrument (separately list each instrument and describe information as requested). Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desired. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

The total number of respondents for all 4 programs is 56. Each of the programs uses the Benefit-Cost Determination, Environmental Review, and Project Narrative – Sub-grant Application. The FMA has a total of 448 responses and the total annual burden hour for this program is 4,088. The RFC has a total of 224 responses and the total annual burden hour for this program is 2,044. The SRL has a total of 1,232 responses and the total annual burden hour for this program is 10,276. The PDM has a total of 3,360 responses and the total annual burden hour for this program is 27,440.

The total for the Benefit-Cost Determination, it is estimated that 56 State Urban and Regional Planners will complete the form in support of the grant requests made. It is estimated that each response will require 5 hours to complete and will be completed 1,680 times a year among the 4 grant programs. The total annual hour burden for this information collection activity will be 56 x 30 = 1,680 x 5 hours = 8,400 hours.

The total for the Environmental Review, it is estimated that 56 State Urban and Regional Planners will complete the form in support of the grant requests made. It is estimated that each response will require 7.5 hours to complete and will be completed 1,680 times a year among the 4 grant programs. The total annual hour burden for this information collection activity will be 56 x 30 = 1,680 x 7.5 hours = 12,600 hours.

The total for the Project Narrative – Sub-grant Application, it is estimated that 56 State Urban and Regional Planners will complete the form in support of the grant requests made. It is estimated that each response will require 5 hours to complete and will be completed 1,904 times a year among the 4 grant program. The total annual hour burden for this information collection activity will be 56 x 34 = 1,904 x 12 hours = 22,848 hours.

 b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.

c. Provide an estimate of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. NOTE: The wage-rate category for each respondent must be multiplied by 1.4 and this total should be entered in the cell for “Avg. Hourly Wage Rate”. The cost to the respondents of contracting out or paying outside parties for information collection activities should not be included here. Instead this cost should be included in Item 13.

Estimated Annualized Burden Hours and Costs
Type of Respondent	Form Name / Form Number	No. of Respon-dents	No. of Respon-ses per Respon-dent	Total No. of Responses	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate	Total Annual Respondent Cost
	FMA
State, local or Tribal Government	Benefit-Cost Determination	56	2	112	5	560	$43.54	$24,382
State, local or Tribal Government	Environmental Review	56	2	112	7.5	840	$43.54	$36,574
State, local or Tribal Government	Project Narrative-Sub-grant Application	56	4	224	12	2688	$43.54	$117,036
Subtotal		56		448		4,088		$177,992
	RFC
State, local or Tribal Government	Benefit-Cost Determination	56	1	56	5	280	$43.54	$12,191
State, local or Tribal Government	Environmental Review	56	1	56	7.5	420	$43.54	$18,287
State, local or Tribal Government	Project Narrative-Sub-grant Application	56	2	112	12	1344	$43.54	$58,518
Subtotal		56		224		2,044		$88,996
	SRL
State, local or Tribal Government	Benefit-Cost Determination	56	7	392	5	1960	$43.54	$85,338
State, local or Tribal Government	Environmental Review	56	7	392	7.5	2940	$43.54	$128,008
State, local or Tribal Government	Project Narrative-Sub-grant Application	56	8	448	12	5376	$43.54	$234,071
Subtotal		56		1,232		10,276	$43.54	$447,417
	PDM
State, local or Tribal Government	Benefit-Cost Determination	56	20	1,120	5	5600	$43.54	$243,824
State, local or Tribal Government	Environmental Review	56	20	1,120	7.5	8400	$43.54	$365,736
State, local or Tribal Government	Project Narrative-Sub-grant Application	56	20	1,120	12	13,440	$43.54	$585,178
Total		56		3,360		27,440		$1,194,738

Note: The “Avg. Hourly Wage Rate” for each respondent includes a 1.4 multiplier to reflect a fully-loaded wage rate.

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

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for State Urban and Regional Planners is estimated to be ($31.10 x 1.4 =) $43.54 per hour including the wage rate multiplier, therefore, the estimated burden hour cost to respondents State Urban And Regional Planners is estimated to $1,909,143.00 annually.

Estimated Annualized Burden Hours and Costs
Type of Respondent	Form Name / Form Number	No. of Respon-dents	No. of Respon-ses per Respon-dent	Total No. of Responses	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate	Total Annual Respondent Cost
State, local or Tribal Government	Benefit-Cost Determination	56	30	1,680	5 hours	8,400	$43.54	$365,735
State, local or Tribal Government	Environmental Review	56	30	1,680	7.5 hours	12,600	$43.54	$548,605
State, local or Tribal Government	Project Narrative-Sub-grant Application	56	34	1,904	12 hours	22,848	$43.54	$994,803
Total		56		5,264		43,848		$1,909,143

Note: The “Avg. Hourly Wage Rate” for each respondent includes a 1.4 multiplier to reflect a fully-loaded wage rate.

14. Provide estimates of annualized cost to the federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing and support staff), and any other expense that would have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.



The total cost to FEMA is $6,240,801.20. Approximately 26 staff members with an estimated grade level of GS-13 review and make determinations for these grant programs.

Annual Cost to the Federal Government

Item	Cost ($)
Contract Costs [Describe] FEMA contracts the maintenance and enhancements to the eGrant data collection. The annual cost of this maintenance contract with IBM, Inc. is $3,000,000.00 for the sustainment/maintenance of the eGrants system. Total cost: $3,000,000.00	$3,000,000.00
Staff Salaries* [26 GS-13, step 1 employees spending approximately 100% of their time annually reviewing and making determinations for the grant programs]. 26 x $89,033.00 = $2,314,858.00 x 1.4 = $3,240,801.20	$3,240,801.20
Facilities [cost for renting, overhead, ect. for data collection activity]
Computer Hardware and Software [cost of equipment annual lifecycle]
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]
Travel
Printing [number of data collection instruments annually]
Postage [annual number of data collection instruments x postage]
Other
Total	$6,240,801.20

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

 15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I in a narrative form. Present the itemized changes in hour burden and cost burden according to program changes or adjustments in Table 5. Denote a program increase as a positive number, and a program decrease as a negative number.

A "Program increase" is an additional burden resulting from an federal government regulatory action or directive. (e.g., an increase in sample size or coverage, amount of information, reporting frequency, or expanded use of an existing form). This also includes previously in-use and unapproved information collections discovered during the ICB process, or during the fiscal year, which will be in use during the next fiscal year.

A "Program decrease", is a reduction in burden because of: (1) the discontinuation of an information collection; or (2) a change in an existing information collection by a Federal agency (e.g., the use of sampling (or smaller samples), a decrease in the amount of information requested (fewer questions), or a decrease in reporting frequency).

"Adjustment" denotes a change in burden hours due to factors over which the government has no control, such as population growth, or in factors which do not affect what information the government collects or changes in the methods used to estimate burden or correction of errors in burden estimates.

Explain: There are no changes to the annual hour burden and there has been no change to the information being collected.

Itemized Changes in Annual Cost Burden
Data collection Activity/Instrument	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New)	Difference
Benefit-Cost Determination				$222,852	$365,735	+$142,883
Environmental Review				$334,278	$548,605	+$214,327
Project Narrative-Sub-grant Application				$606,157.40	$994,803	+$388,645.60
Total(s)				$1,163,287.40	$1,909,143.00	+$745,855.60

Explain:

The adjustment increase in the annual cost burden results from the application of the 1.4 multiplier to the wages.