Narrative of Changes

Narrative of Changes from Last Submission, 9-11-2013.doc

Environmental and Historic Preservation Screening Form

Narrative of Changes

OMB: 1660-0115

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Narrative of Changes

The purpose of the Narrative of Changes is to clearly indicate changes to a collection since the previous approval.


Collection Title: Environmental and Historic Preservation Screening Form

OMB Control No.: 1660-0115

Current Expiration Date: October 31, 2013

Collection Instrument: FEMA Form 024-0-1


The following are the changes to FEMA Form 024-0-1:


The previously approved form was poorly formatted, poorly organized, and poorly designed. For example, the blocks which were meant for the applicants to input their responses were all over the document. Also, the previously approved collection had terribly inadequate instructions on how to complete the form.


The new form has been reformatted and streamlined to be more aesthetically pleasing and organized in such a way that it is more logical to the applicant. Also, the instructions have been expanded and include far better examples than in the previously approved collection. A Change Request Chart has been completed for FEMA Form 024-0-1 and is included in the package.


Supporting Statement:

Question 8a – Updated to reflect FRN publication information.

Question 10 – Updated to reflect current privacy information.

Question 12 – Number of respondents increased and the “Type of Respondents” has been adjusted to correct an error in the previously approved collection. See Question 15 for explanation of these changes.

Question 15 – Burden hour increase explained. The Type of Respondent adjustment also explained.



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

Environmental and Historic Preservation Screening Form / FEMA Form 024-0-1

2,800

1

2,800

8 hours

22,400

$42.10

$943,040

Not-for-Profit Institutions

Environmental and Historic Preservation Screening Form / FEMA Form 024-0-1

200

1

200

8 hours

1,600

$42.10

$67,360

Total

 

 3,000

 

3,000 

 

24,000 

 

$1,010,400 

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




Question 15 – See explanation below.


Itemized Changes in Annual Burden Hours

Data collection Activity/Instrument

Program Change (hours currently on OMB Inventory)

Program Change (New)

Difference

Adjustment (hours currently on OMB Inventory)

Adjustment (New)

Difference

Environmental and Historic Preservation Screening Form / FEMA Form 024-0-1




10,584

24,000

+13,416

Total(s)




10,584

24,000

+13,416


Explanation of the increased burden: The increase/adjustment is due to the fact that we have more respondents. As the Federal grantees become more familiar with EHP regulations and requirements, the grantees are more apt to comply with the regulations and requirements and submit the Screening Form in order for FEMA to conduct the EHP review. The previous declaration of burden was submitted before full implementation of the EHP review process and there was no history by which the submitters could estimate the number of respondents. Now, after three years’ experience, we are very comfortable in our estimation of 3,000 respondents.


Explanation of the adjustment in the type of respondents: In the previous submission for this collection, FEMA indicated that there were two types of respondents: 1) “State Local Tribal Governments” and 2) “Business or other for-profit” respondents. FEMA does not provide preparedness grants to businesses or other for-profit organizations. It is believed that that box was checked in error and the box that should have been checked is the “Not for Profit Institution” box. This document correctly reflects the types of respondents for this collection.


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