Supporting Statement RCH11

Supporting Statement for Request of OMB Approval

Of the Low Income Home Energy Assistance Program

Residential Energy Assistance Challenge Program (REACH) Model Plan

June, 2011

A. Justification.

1. Circumstances Making the Collection of Information Necessary

The Low Income Home Energy Assistance Act (LIHEAP) was amended in l994 (P.L. 103-252) to include the Residential Energy Assistance Challenge Program (REACH). The authority to require applications for REACH funds is contained in Section 2607B(b)(1) of the LIHEAP statute, as amended, in which funds are available “…to States that submit qualifying plans…” and in 2607B(e), which provides elements of REACH plans. Since the first REACH grants were issued, the Office of Community Services administered the REACH Program through the Administration for Children and Families (ACF) competitive discretionary grants process.

However, the LIHEAP program is a block grant and block grant policy established that application and reporting requirements are to be kept to a minimum. Only those elements required by statute and only necessary information for grants issuance and oversight should be requested of LIHEAP grantees. REACH program funds are only available to LIHEAP grantees, and therefore, REACH application requirements should also be kept to a minimum.

The LIHEAP statute in Section 2605(H)(3) requires that a model plan be provided for LIHEAP applications. To be consistent with the model plan requirement for LIHEAP applications and to reduce application requirements, the REACH model plan was developed in the same format as the LIHEAP application (OMB approval 0970-0075).

2. Purpose and Use of the Information Collection

The Administration for Children and Families (ACF) intends to use information submitted on the REACH model plan to identify qualified REACH programs for grant issuance.

3. Use of Information Technology and Burden Reduction

By only requiring the elements necessary for a REACH application and keeping with LIHEAP block grant policy, ACF reduced the burden for applying for REACH funds. Grantees may submit their REACH applications electronically by e-mail or fax. Grantees have the option to use their own format.

4. Efforts to Identify Duplication and Use of Similar Information

There is no duplication of collection of this data during the fiscal year. The REACH Model Plan will be used as an annual application for funds, and grantees are required by statute to provide this information. There is no other requirement that States provide this

information to us in any other form.

5. Impact on Small Businesses or Other Small Entities

This data collection effort does not involve small businesses. Only States, tribes and insular area governments who are LIHEAP grantees may apply for funds.

6. Consequences of Collecting the Information Less Frequently

The LIHEAP statute provides that a portion of the annual LIHEAP appropriation will be set aside to fund REACH programs. The REACH Model Plan will ensure grantees provide all information necessary to receive REACH funds, and the Federal government will receive the necessary information to determine the best programs to fund.

7. Special Circumstances Relating to the Guidelines of 5 CFR 1320.5

No special circumstances require the form to be collected in a manner inconsistent with the guidelines in 5 CFR 1320.6.

8. Comments in Response to the Federal Register Notice and Efforts to Consult Outside the Agency

Notice of the request for OMB approval of the REACH Model Plan was published in the Federal Register and made available for review and comment on June 9, 2011, (Vol. 76 FR 33768). We posted a copy of the Federal Register notice on the LIHEAP website to request comments.

No comments were received by the end of the comment period.

9. Explanation of Any Payment or Gift to Respondents

There are no payments or gifts associated with this data collection effort.

10. Assurance of Confidentiality Provided to Respondents

There is no assurance of confidentiality that is applicable to this collection.

11. Justification for Sensitive Questions

There are no sensitive questions in this collection.

12. Estimates of Annualized Burden Hours and Costs

The total annual reporting burden for the States, the District of Columbia, and Tribes for this report is estimated to be 3672 hours. The estimated burden represents respondent time needed to review the form and its instructions, prepare responses, and submit the information. There will be 51 respondents submitting reports. We estimate the total average burden to be 72 hours per respondent, resulting in a total respondent burden of 3672 hours.

The breakdown in burden hours is as follows:

ANNUAL BURDEN ESTIMATES

REACH Model Plan

INSTRUMENT	NUMBER OF RESPONDENTS	NUMBER OF RESPONSES PER RESPONDENT	AVERAGE BURDEN HOURS PER RESPONSE	TOTAL BURDEN HOURS
REACH Model Plan	51	1	72	3672

Estimated Total Annual Burden Hours: 3672

The annualized cost to each of the States for responding to the report is estimated to be $1,915.20. This was calculated by multiplying the 51 respondents by $26.60, which is the estimated hourly rate of grantee LIHEAP staff involved in responding to the report. The cost for 51 respondents is $97,675.20

.

13. Estimates of Other Total Annual Cost Burden to Respondents and Record Keepers

There are also costs associated with or resulting from start-up. We estimate the cost burden to each respondent for start-up to be $700. There are no other monetary costs associated with this information collection. There are 51 respondents so the total cost is 35,700.

14. Annualized Cost to the Federal Government

The estimated Federal cost of this information collection totals to $8160 based on the following:

A GS-12 or GS-13 employee generally reviews each report and a GS 14 may also do a second review. A GS-15 employee generally makes final decisions when there are questions about the adequacy of information. At an average salary rate of $40 per hour, assuming four hours each for 51 applications, the Federal salary costs each year will be about $8160.

15. Explanation of Program Changes or Adjustments

There have been no program changes or adjustments since the last information collection approval of the REACH Model Plan. Grantees have the option to use another format.

16. Plans for Tabulation and Publication and Project Time Schedule

The REACH Model Plan and instructions will be published in an Action

Transmittal and distributed to LIHEAP grantees annually.

17. Reason(s) Display of OMB Expiration Date is Inappropriate

The OMB Clearance number and expiration date will be displayed on the form.

18. Exceptions to Certification for Paperwork Reduction Act Submission

There are no exceptions necessary for this data collection effort.

B. Collection of Information Employing Statistical Methods

This report does not employ statistical methods.

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