0560-0177 Supporting Statement (4)

Supporting Statement, 0560-0177 Page 6

U.S. Department of Agriculture

Farm Service Agency

Kansas City Commodity Office

Supporting Statement

OMB Number 0560-0177

Web-Based Supply Chain System (WBSCM)

This submission is a revision of a currently approved information collection request (ICR). With this submission, FSA is changing the name of the collection from Offer Forms to Web-based Supply Chain System (WBSCM). In this submission, the burden hours will be reduced because the respondents will take less time to complete the data in the WBSCM.

The WBSCM is a new procurement system in development to replace the current following Commodity Operations Systems (COS) for several USDA agencies, and the United States Agency for International Development (USAID):

• Freight Bid Entry System (FBES-0560-0258),

• Long Term Contracting System (LTCS-0560-0249),

• Food Request Entry System (FARES-(0560-0225),

• Electronic Bid Entry System (EBES- 0560-0177), and

• Domestic Electronic Bid Entry System (DEBES- 0560-0177).

FSA is planning to do another 60-day notice to merge the burden hours from the above information collections into 0560-0177.

Justification

1. Circumstances making collection of information necessary:

The Agricultural Trade Development and Assistance Act of 1954, as amended, (for Title II, P.L. 480), Section 416(b) of the Agricultural Act of 1949, as amended--for Section 416(b), and Food for Progress Act of 1985, as amended--for Food for Progress, authorize the International Procurement Division to procure (IPD), sell, and transport agricultural commodities, and obtain discharge/delivery survey information. Contractors, vendors, and steamship companies submit competitive offers for agricultural commodities and services. This enables IPD to evaluate offers impartially, purchase or sell commodities, and obtain services to meet domestic and export program needs. Vendors are required to submit shipping logs, so IPD can trace shipments to meet vessel sailing dates. Commodities are delivered to foreign countries under the Food for Peace Program (Title II and III); Food for Progress Program, Section 416, through voluntary agencies, World Food Program, and the U.S. Agency for International Development. Port authorities submit their port capacity information for a given invitation covering a specific shipping period, thus allowing for competitive purchase of commodities for export food assistance programs. Warehouse operators/terminals must be inspected and approved for use by FSA to be considered qualified to provide space for handling and storage of commodities in regard to port/transload facility. Without this information collection, Commodity Credit Corporation (CCC) could not meet program requirements.

The Domestic Procurement Division issues solicitations to purchase or process commodities for food donation programs. Vendors respond by making electronic offers using Web Based Supply Chain Management (WBSCM) commodity offer forms. Dairy processors are given the opportunity to participate under the price support program. Bid offers are received from dairy processors to remove surplus bulk butter, cheese or milk from the marketplace. The Domestic Procurement Division uses the following Sections of Public Law to meet program needs:

32/6E National School Lunch Program / Child & Adult Care Feeding Program

311 Nutrition Program / Agencies on Aging

4A Needy Indian Families / Needy Families Living in US Trust Territories

17 Commodity Supplemental Food Program / Women, Infants, & Children

104 Emergency Food Assistance Program

110 Soup Kitchens / Food Banks

416 Charitable Institutions / Non-Profit Summer Camp for Children

32C Food Banks in High Need Areas / Disaster Feeding

The following acts authorize Commodity Management Division and International Procurement Division to prepare and issue announcements for the purchase of grain. The Procurement Form (KC-331) is authorized by the Agriculture Trade Developmental and Acquisition Act 1954 as amended, Public Law 480, Food for Progress Act 1985, 416-416(b) Agriculture Acts as amended. Vendors respond by making offers using the offer form. The Commodity Management Division and International Procurement Division also coordinate Ocean Freight bookings for bulk grain donation programs. Without this information collection, CCC could not meet program requirements.

2. How, by whom, and for what purpose is information used:

7 CFR, Chapter 14, Part 1485-Subchapter C

Form KC-334 (Discharge/Delivery Survey Summary) and Form KC-337 (Rate Schedule) (the forms will be obsolete and the data collection will be in WBSCM)

The vendors submit offers for agricultural commodities, bags and twine, and survey services to KCCO to meet export program needs. The price, product, quantity, and delivery point the vendor is offering are submitted to KCCO via this form. The information will change in response to each invitation, and it is not available from another source. It is necessary to collect the information recorded on the offer forms to determine the successful offeror(s) is under solicitation to purchase products and services for use in the following export programs: Public Law 480, Title II, and III; Food for Progress; and Section 416.

The Kansas City Commodity Office (KCCO) will collect the information electronically and/or by mail for the KC-334 form. This form is filled out by each survey company that KCCO has contracted to perform discharge surveys on the food aid cargo. They complete this form at each cargo discharge port and delivery location, by commodity, with the final forms sent as part of the survey report. (The preliminary data is sent usually by e-mail, after the shipment is completed.) The information on the form is a summary of the amount of cargo delivered versus manifested quantity, the amount and type of damage, etc. This information is used by KCCO/Contract Reconciliation Division, as a quick summary of losses for their claims filing purposes. The KC-337 provided along with proposal package in response to RFP is received by mail because a signature is required. The purpose of this form is to obtain rates that the survey companies charge to perform surveys, by country/region. The amount the survey companies charge, and other technical factors, are used by KCCO in determining which survey companies will be awarded the survey contracts. The information collected on these forms is not available from another source.

7 CFR, Subtitle B, Chapter 14, Part 1496.6 (The form will be not in WBSCM at this time.)

FSA collects information for the form KC-359 (Application for Port/Trans-Load Facility Approval) (The form will be not in WBSCM at this time.)electronically or by mail. This form is completed by warehouse/terminal/trans-load/port operators as requested by FSA. The information is used to verify port/terminal suitability for consideration in handling and storage of U.S. Department of Agriculture (USDA) food aid commodities and help with arrangements for conducting port inspections. The requesting party and port official, if applicable, must sign the application.

7 CFR, Chapter 14, 1496, Subchapter B and C

Form KC-331 (Bulk Grain Procurement Offer Form) (The form will be obsolete and these data collection will be in WBSCM) - KCCO usually receives this collection of information by fax. Contractors submit competitive offers (sealed bidding) for agricultural bulk grain commodities. KCCO uses the information collected to record, check and assess offers, as well as, assist contractors in submitting bid information in a timely, accurate, and uniform manner. These bulk grain commodities are purchased by KCCO to meet export donation program requirements. It is necessary to collect this information in order to evaluate offers impartially. The price, product, quantity, and delivery point the vendor is offering are submitted to KCCO via this form. The information collected on this offer form is not available from another source.

7 CFR, Chapter 14, Subchapter B - Commodity Purchases (The EBES will be obsolete and these data collection will be in WBSCM except for KC-327-RSCS only))

The Dairy and Domestic invitations are received electronically through WBSCM. These offer forms are used by vendors to submit competitive offers for agricultural processed commodities that are purchased by KCCO to meet domestic program needs. Price, product, quantity, and delivery point the vendor offers are submitted to KCCO via this system. Vendors complete a bid form on-line in WBSCM. Once the offers are received electronically, they are system date/time stamped, logged in, and secured within the system until bid opening time. It is necessary to collect the information in order to evaluate offers impartially. Some offers may be manually completed by the vendors. These vendors submit their offers via certified or overnight mail, or hand-deliver their offers. The bids are signed for, date/time stamped, logged in, and secured in a timed lock box. It is necessary to collect the information in order to evaluate offers impartially.

7 CFR, Chapter 14, Part 1430

KC-327-DELVSTAT (Delivery Status Report) (The form will be obsolete and the data collection will be in WBSCM)

This collection of information is received by fax or e-mail. This form is used by contractors to report their shipment status of products under contract. KCCO employees use the information collected, to notify state agencies of late shipments. It may also be used to consider the eligibility of contractors on future solicitations to bid.

7 CFR, Chapter 14, Part 1430

Dairy-6 Offer forms/Price Support Cancellation Request - (The form will not be in WBSCM at this time.)Usually this information collection is received by fax. Dairy6 vendors are allowed to submit their offers via email. The offer form is used by dairy processors to submit or cancel offers under the price support program. It is necessary to collect the information to give dairy processors the opportunity to participate under the price support program. The information collected on this offer form is not available from another source.

How to Submit Offers

(1) Offers, modifications, withdrawals, and cancellations shall be submitted by one of the following methods:

(a) Email with an electronic signature. Place in the subject line “Offer under ANNOUNCEMENT DAIRY 6 (Name of product stated as Butter, Cheese, or NDM);” By e-mail: [email protected].

(b) Facsimile (FAX) to (816) 926-6381. Place in the subject line “Offer under ANNOUNCEMENT DAIRY 6 (Name of product stated as Butter, Cheese, or NDM);”

(c) Express or regular mail, and/or hand delivered. Place the notation “Offer under ANNOUNCEMENT DAIRY 6 (Name of product stated as Butter, Cheese, or NDM),” in the lower-left corner of the envelope.

Form KC-366 (The form will be obsolete and the data collection will be in the WBSCM.) Vendors usually fax this Shipment Information Log to KCCO. The information collected is used by KCCO to determine what rail cars have been loaded in accordance with the vendors shipping schedules. Information received on this form is contract no., commodity, invitation no., contractor, millpoint, Notice to Deliver (N/D) no., quantity, U.S. port, rail car/container no., date shipped, complete route, units shipped, net/gross weight (lbs.), remarks, total units shipped and vendor signature. The information collected on the KC-366, informs KCCO of rail car shipment status from plant locations, to ensure that vendors are shipping their commodities in accordance with contract terms. The information collected on the KC-366 is not available from another source.

3. Use of information technology:

FSA is requesting for an approval for all the electronic submissions associated with WBSCM.

4. Efforts to identify duplication:

To the best of our knowledge, similar information is not collected by any other government office.

These collections are necessary to support the procurement, handling and storage of agricultural commodities for CCCs domestic and export food donation and assistance programs. The information required is available only from participants, and is not accessible by KCCO unless provided by participants from their private records.

5. Methods to minimize burden on small business or entities:

Since the information requested is readily available from participants’ records, these collections do not impose a special burden on small businesses or entities. WBSCM eases the burden on the small businesses cash flow, as the self-certification allows payment to the vendor more quickly.

6. Consequences if information collection were less frequent:

Information collection is required to procure, sell, handle, store, and transport agricultural commodities and services. Without this information, KCCO could not meet program requirements. Information collection is required to accept or cancel offers received from dairy processors at anytime to remove surplus bulk butter, cheese or milk from the marketplace. Contractors’ failure to notify KCCO about late shipments, may cause more disruption to the state distribution feed programs.

7. Special circumstances:

1. requiring respondents to report information to the agency more often than quarterly;

• Offers are submitted bi-monthly, quarterly, or annually, but are submitted more frequently in emergencies or to make up a deficiency from a regular purchase.

• Dairy6 offer forms are submitted by dairy processors as needed to remove bulk surplus products from the marketplace.

• KC-331 is submitted as needed to meet program requirements and emergencies.

• KC-366 is submitted upon shipping. If a vendor is shipping late, it is submitted daily.

• KC-337 is submitted annually, except for emergencies, which require a 45-day response

• KC-334 is submitted upon completion of shipment that requires a KCCO contracted surveyor.

2. requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it; KCCO issues a solicitation, requiring competitive offers usually within 7-13 days, depending on program needs.

3. requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years; No

4. in connection with a statistical survey that is not designated to produce valid and reliable results that can be generalized to the universe of study; No

5. requiring the use of statistical data classification that has not been reviewed and approved by OMB; Bid price analysis requires statistical data classification.

6. includes a pledge of confidentiality that is not supported by authority established in statue or regulation, that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; No

7. requiring respondents to submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information’s confidentiality to the extent permitted by law; No

8. Federal Register Notice, summarization of comments and consultation with persons outside the agency:

A Federal Register Notice, with a 60-day comment period regarding this information collection requested was published on December 2, 2009, (74 FR 63116). No comments were received.

Consultation outside the agency on the agreements covered under this clearance package include:

• Cargill, Jon Kamka, PO Box 5602, Minneapolis, MN,

• ConAgra Food Ingredients, Jason Hines, Eleven ConAgra Drive, 221 South Fairmont, Omaha, NE,

• Robert Prescott, Port of Savannah, PO Box 2406, Savannah, GA

9. Decision to provide any payment or gift to respondents:

There are no plans to provide any payment or gifts to respondents.

10. Confidentiality provided to respondents:

Confidential business-related information is collected. Some vendors provide us with their home phone number, which is used when business related problems arise after normal business hours. All data collected is handled according to KCCO procedures in accordance with the Privacy Act and the Freedom of Information Act.

11. Questions of a sensitive nature:

No sensitive information is collected.

12. Estimates of Burden:

See the attached FSA-85-1.

Reporting Burden: 829 respondents will submit 9,921 reports annually that average approximately 15-30 minutes per response. The total reporting burden is 1066 hours.

The estimated cost to the public is $ 24,955. This figure represents 1,066 burden hours x $23.41.

13. Total annual cost burden to respondents or record keepers:

There are no capital/start-up costs associated with this information collection request.

14. Estimates of annualized cost to the Federal government:

The estimated annual cost to the Federal government is $13,110. Cost for producing and distribution is estimated at $2,543.91. Employee wages for producing the forms/applications is estimated at $10,567.07.

15. Reasons for changes in burden:

The program change decreases by - 2,339 burden hours. The burden hours previously approved were 3,405, and the current burden hours are 1,066. 

The number of responses went from 10,492 to 9,921 a reduction of -561 and the number of respondent decreased from 949 to 829 a reduction of -120.

The reasons are due to the new WBSCM – making forms KC-366, KC-331, KC-327 DELVSTAT, KC-144, Export Offer Forms, KC-334, KC-337 and KC-327-kcpbagsdeclr obsolete, and reducing data collection time; paper vs. electronically (WBSCM) in this information collection. 

16. Tabulation, analysis and publication plans:

Purchase and sale contractor award information is available on the Internet, bulletin board, and in the statistical overview pamphlet.

17. Reason display of expiration date of OMB approval is inappropriate:

The agency is seeking approval to not display the OMB expiration date on the forms associated with this information collection because the forms are being replaced by the WBSCM.

18. Exceptions to 83-1 certification statement:

There are no exceptions to OMB-83-1 certification statement.

19. How is this information collection related to the Customer Service Center? Will this

information be part of their one stop shopping?

This information collection is not related to the USDA Customer Service Center. Our customers are contractors, vendors, steamship companies, warehouse operators, and voluntary agencies. Our customers have direct contact with KCCO and via WBSCM.