Supporting Statement (HSGP) (508)

February 21, 2014

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660 - 0125

Title: FEMA Preparedness Grants: Homeland Security Grant Program (HSGP)

Form Number(s): FEMA Form 089-1; FEMA Form 089-16; FEMA Form 089-20

General Instructions

A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When Item 17 or the OMB Form 83-I is checked “Yes”, Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

A. Justification

1. Explain the circumstances that make the collection of information necessary.

Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information. Provide a detailed description of the nature and source of the information to be collected.

 FEMA’s Homeland Security Grant Program (HSGP) is an important part of the Administration’s larger, coordinated effort— known as the Federal Investment Strategy— to strengthen homeland security preparedness. The HSGP implements objectives addressed in a series of post-9/11 laws, strategy documents, plans, and Homeland Security Presidential Directives (HSPDs). FEMA management requirements are incorporated into the FY 2009 HSGP and reflect changes mandated in the Homeland Security Act of 2002 (6 U.S.C. §101 et seq.), as amended by the Implementing Recommendations of the 9/11 Commission Act of 2007 (P.L. 110-053). Additional statutory requirements are outlined in the Department of Homeland Security Appropriations Act, 2013 (Public Law 113-6).

FEMA’s Operation Stonegarden (OPSG) Grant Program provides funding to designated localities to enhance cooperation and coordination between Federal, State, local, and tribal law enforcement agencies in a joint mission to secure the U.S. borders along routes of ingress from International borders to include travel corridors in States bordering Mexico and Canada, as well as States and territories with International water borders. The FY 2012 OPSG funds must be used to increase operational capabilities of Federal, State, local and tribal law enforcement, promoting a layered, coordinated approach to law enforcement within U.S. Border States and territories.

The Homeland Security Grant Program (HSGP) is a primary funding mechanism for building and sustaining national preparedness capabilities. HSGP is comprised of three separate grant programs:

• State Homeland Security Program (SHSP)

• Urban Areas Security Initiative (UASI)

• Operation Stonegarden (OPSG)

Together, these grants fund a range of preparedness activities, including planning, organization, equipment purchase, training, exercises, border security and management and administration costs. These programs have identical data collection requirements; however, Operation Stonegarden has two additional reporting forms.

*It is important to note that Operation Stonegarden was a stand-alone program in Fiscal Year 2009 and filed its own PRA filing in 2009. The grant program was merged into the Homeland Security Grant Program in Fiscal Year 2010.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. Provide a detailed description of: how the information will be shared, if applicable, and for what programmatic purpose.

FEMA Form 089-1, HSGP Investment Justification (SHSP and UASI) – Submitted with the application, this document provides narrative detail on proposed activities (Investments) that will be accomplished with HSGP funds. These “Investment Justifications” must demonstrate how proposed projects address gaps and deficiencies in current programs and capabilities and how grant funds will thereafter provide enhancements to overall homeland security preparedness.

Urban Area Working Group Overview/Structure, including Point-of-Contact – An overview of the Urban Area Working Group (UAWG) structure and a list of members and their associated jurisdictions are required. Urban Areas must identify one core point-of-contact (POC) since this POC will serve as the official representative of the Urban Area. Applicants have flexibility to use pre-existing information (e.g. organization charts) to meet this requirement. This information is due at the time of grant program application. The applicant develops this document internally. Due to the flexibility in reporting format, there is no single, prescribed way in which applicants provide this data.

UASI Governance Charter – The UASI governance charter must be on file with FEMA prior to a UASI drawing down on its grant funds. The charter formalizes standard procedures and organization in order to ensure sound project management practices related to membership, governance structure, voting rights, grants management and administrative responsibilities, and funding allocation methodologies. The applicant develops this document internally. Due to the flexibility in reporting format, there is no single, prescribed way in which applicants provide this data.

UASI Strategy – This applies for new Urban Areas only, of which there are no new UASIs for 2013. New UASIs must develop a strategy that identifies homeland security goals, objectives, and priorities of that Urban Area. The applicant develops this document internally. Due to the flexibility in reporting format, there is no single, prescribed way in which applicants provide this data.

UAWG Spending Consensus - State Administrative Agencies (SAAs) must be prepared to show DHS written documentation that verifies an Urban Area is in consensus related to how that Urban Area is distributing its UASI grant funds. The applicant develops this document internally. Due to the flexibility in reporting format, there is no single, prescribed way in which applicants provide this data.

Multi-year Training and Exercise Plan – All Urban Areas are required to develop a Multi-year Training and Exercise Plan and submit it to FEMA on an annual basis. The multi-year Training and Exercise Plan is part of the Homeland Security Exercise and Evaluation Program (HSEEP).  The link for the HSEEP is https://hseep.dhs.gov. This requirement is managed by FEMA’s National Preparedness Directorate (NPD). This requirement is supported by the Training and Exercise Plan Workshop User Handbook and the related statutory authority is Section 648(b)(2) of the Post-Katrina Emergency Management Reform Act of 2006 (6 U.S.C. §748(b)(2)).

Initial Strategy Implementation Plan (ISIP) – Through the ISIP, the State Administrative Agency (SAA) will report planned expenditures within 45 days of the newly awarded grants. The SAA is responsible for the submission of the ISIP report to FEMA. Submission of the ISIP satisfies the programmatic reporting requirements identified in the FEMA preparedness grant program guidance to ensure legal and prudent use of federal funds. All funds provided to the SAA through these grant programs must be accounted for and linked to one or more projects. This, in turn, must support specific goals and objectives in the State Homeland Security Strategy (SHSS) and where appropriate, the Urban Area Security Strategies (UASS) and Regional Transit Security Strategies. The ISIP data is submitted electronically in a FEMA-sponsored system, the Grants Reporting Tool (GRT). This collection activity is approved under OMB Control Number 1660-0117, which expires 11/30/2013.

Biannual Strategy Implementation Report (BSIR) – The BSIR serves as the reporting format for the Semiannual Progress Report, formerly known as the Categorical Assistance Progress Report (CAPR). The SAA/Direct Tribal Grantee (DTG) is responsible for providing FEMA with BSIR reports to account for grant funding. The BSIRs are due within 30 days of the end of the reporting periods (June 30 and December 31), for the life of the award. A close-out BSIR is due 120 days after the end date of the award period. The submission of a completed BSIR satisfies programmatic reporting requirements as outlined in the grant program guidance to ensure legal and prudent use of federal funds. All funds provided to the SAA through these grant programs must be accounted for and linked to one or more projects. This, in turn, must support specific goals and objectives in the State Homeland Security Strategy and where appropriate, the Urban Area Homeland Security Strategy, and Regional Transit Security Strategy, as detailed in the special conditions of the grant award. The BSIR data is submitted electronically in a FEMA-sponsored system, the Grants Reporting Tool (GRT). This collection activity is approved under OMB Control Number 1660-0117, which expires 11/30/2013.

Preparedness Comprehensive Assessment Support Tool (PrepCAST) formerly known as the National Incident Management System Compliance Assistance Support Tool (NIMSCAST) – PrepCAST facilitates and reports State, Territory, tribal and local jurisdictions’ compliance with the National Incident Management System (NIMS). PrepCAST allows incident management authorities and resource managers to assess their current capabilities as well as to determine what additional measures should be taken and what resources are needed to effectively implement the NIMS nationwide. The State Preparedness Report provides information on the readiness of states to respond to disaster situations. The capability based data in this report is used in conjunction with other data to create documents such as the National Preparedness Report. This collection activity is approved under OMB Control Number 1660-0087, which expires 4/30/2016.

FEMA Form 024-0-1, Environmental and Historic Preservation (EHP) Environmental Screening Form (ESF) - The Environmental and Historic Preservation Environmental Screening Form is a paper form used by FEMA’s Grant Programs Directorate (GPD) and is utilized when following the requirements for grant packages that utilize this instrument. This form should be attached to all project information sent to GPD for an Environmental and Historic Preservation (EHP) regulatory compliance review. This collection activity is approved under OMB Control Number 1660-0115, which expires 10/31/2013.

Homeland Security Exercise and Evaluation Program (HSEEP) After-Action Report (AAR) and Improvement Plan (IP) – The information contained within this report identifies areas where expectations for preparedness to respond to an emergency situation are met as well as areas where improvement is required. This information is used by the Secretary of Homeland Security and shared with heads of other Federal Departments including FEMA’s National Preparedness Directorate to allow for planning methods to increase levels of preparedness, establishing mechanisms for improved delivery of Federal preparedness assistance to State and local governments, and outlining actions to strengthen preparedness capabilities of Federal, State and local entities.

This initiative is managed by FEMA’s National Preparedness Directorate (NPD). Grant recipients must report on scheduled exercises and ensure that an HSEEP After-Action Report (AAR) and Improvement Plan (IP) are prepared for each exercise conducted with FEMA support. This information must be submitted to the FEMA within 60 days following completion of an exercise. There are two separate templates that support this data collection effort: (1) Discussion-Based Exercise template; 2) Operations-Based Exercise template. The link for the HSEEP is https://hseep.dhs.gov. This collection activity is approved under OMB Control Number 1660-0118, which expires 11/30/2013.

FEMA Form 089-16, OPSG Operations Order Report – This document is used by Customs & Border Patrol (CBP)/Border Protection (BP) Sector Headquarters, in coordination with local / tribal law enforcement agencies and the State SAA, to provide project budget and accompanying project description. The Operations Order includes budgets and operative spending plans in one year increments for the 24 month period of performance. Applicants provide this information in MS Word format at the time of application submission via grants.gov. The information from the Operations Orders is used by reviewers from FEMA, CBP/BP, and the State Administrative Agencies (SAAs) to evaluate applications and making funding decisions.

FEMA Form 089-20, OPSG Inventory of Operation Orders - FEMA will provide the SAA with an electronic template for the State to list the names of each jurisdictions applying for funding and the dollar amount being requested by each. This assists FEMA and CBP/BP to ensure that all Operations Orders have been submitted before the application deadline and provides an accounting of the funding amounts being requested.

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.

Grant applications are posted on the FEMA website at http://www.fema.gov/government/grant/index.shtm and are advertised in the Catalog of Federal Domestic Assistance (CFDA) for applicants. FEMA posts most of its grant application packages on www.grants.gov. This allows applicants to download the application package and complete it offline. After applicants have completed all required forms, they must electronically submit the package to FEMA through the ND Grants System located at https://portal.fema.gov. The data collection tools in this collection are either MS-Word documents or non-prescribed formats. The Urban Area Working Group (UWAG) Overview/Structure is submitted as an attachment in www.grants.gov. The UASI Governance Charter, UASI Strategy, UWAG Spending Consensus, a written letter submitted to DHS requesting tribal staff participation for overtime costs and fusion centers, and SAA documentation on how operational overtime UASI funds held by State would support urban area are completed in non-prescribed formats using electronic software, such as MS Word, and submitted as attachments.

Additionally, grant applicants must use the FEMA-sponsored Grants Reporting Tool (GRT) to submit data for their Investment Justification (IJ), Initial Strategy Implementation Plan (ISIP) and Biannual Strategy Implementation Report (BSIR). The GRT provides grantees the ability to electronically create and submit their IJs, ISIPs and BSIRs throughout the life of the grant. The GRT homepage is (https://www.reporting.odp.dhs.gov/ ). The GRT is used to capture FEMA’s annual award and biannual grant reporting data. The Department developed the GRT as a tool to streamline the reporting process for grantees. The module is user-friendly with a web-based format, thus reducing burden on the grantees by providing increased flexibility yet ensuring adherence to agency guidelines. The Grants Reporting Tool (GRT) collection activity is approved under OMB Control Number 1660-0117, which expires 11/30/2013.

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 above. 

This information is not collected in any form, and therefore is not duplicated elsewhere.

5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize.

This information collection does not have an impact on small businesses or other small entities.

6. Describe the consequence to Federal/FEMA program or policy activities if the collection of information is not conducted, or is conducted less frequently as well as any technical or legal obstacles to reducing burden.

If FEMA could not request and obtain this information, FEMA could not exercise comprehensive financial management and ensure the efficient and effective use of Federal funds. If FEMA was not able to receive information collected from grant recipients, the agency could not fulfill monitoring requirements.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

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

No data collection elements are required more often than quarterly. Most collection elements are only required once per year per grant application.

2. Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

There are no requirements for respondents to prepare a written response to this collection of information in fewer than 30 days after receipt of it.

2. Requiring respondents to submit more than an original and two

copies of any document.

There are no requirements for a respondent to submit more than an original and two copies of any document.

2. Requiring respondents to retain records, other than health,

medical, government contract, grant-in-aid, or tax records for more than three years.

Records must be retained for three years after close-out. If any litigation, claim, negotiation, audit, or other action involving the records has been started before the expiration of the three-year period, the records must be retained until completion of the action and resolution of all issues which arise from it, or until the end of the regular three-year period, whichever is later.

2. In connection with a statistical survey, that is not designed to

produce valid and reliable results that can be generalized to the universe of study.

There is no statistical survey involved with this data collection.

 (f) Requiring the use of a statistical data classification that has not

been reviewed and approved by OMB.

There is no use for statistical data classification in this data collection.

 (g) That includes a pledge of confidentiality that is not supported by authority established in statute 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.

There is no pledge of confidentiality that is not supported by authority established in statute or regulation for this data collection.

 (h) 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.

There are no requirements for respondents to submit proprietary trade secret or other confidential information for this data collection.

8. Federal Register Notice: 

 a. Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.

A 60-day Federal Register Notice inviting public comments was published on August 9, 2013, 78 FR 48697. No comments were received. See attached copy of the published notice included in this package.

A 30-day Federal Register Notice inviting public comments was published on November 18, 2013, 78 FR 69099. No comments were received. See attached copy of the published notice included in this package.

 b. Describe efforts to consult with persons outside the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and recordkeeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

FEMA meets with both the National Emergency Management Association (NEMA) and the National Governors Association (NGA) national associations that represent these entities, as well as individual grantees, through regular program-specific conferences and workshops.  Additionally, teleconferences and e-mail communications are also used. During the grant guidance development process in past years, FEMA meets and consults directly with grant recipients on a number of occasions to discuss the whole range of grant administration matters, including reporting requirements.

c. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

FEMA consults on a regular basis with Federal, State, local, tribal stakeholders on a variety of issues. These consultations involve discussions regarding the nature of information needed by FEMA to manage the grant programs. Partners offer comments and suggestions about their reporting practices. The most common area of concern is performance reporting, as most States are very familiar and comfortable with the grant administrative and financial reporting data elements that FEMA uses.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

FEMA does not provide payments or gifts to respondents in exchange for a benefit sought.

10. Describe any assurance of confidentiality provided to respondents. Present the basis for the assurance in statute, regulation, or agency policy.

A Privacy Threshold Analysis (PTA) was completed by FEMA and adjudicated by the DHS Privacy Office on September 23, 2013.

The Privacy Impact Assessment (PIA) is covered under the DHS/FEMA/PIA-013 - Grant Management Programs, approved by DHS on July 14, 2009 and the existing System of Records Notice (SORN), is DHS/FEMA-004 Grant Management Information Files 74 FR 39705 approved by DHS on August 7, 2009.

There are no assurances of confidentiality provided to the respondents for this information collection.

11. Provide additional justification for any question of a sensitive nature (such as sexual behavior and attitudes, religious beliefs and other matters that are commonly considered private). This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of sensitive nature.

 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 HSGP is an existing grant program that uses the forms outlined in this collection. The burden hour estimates shown on the following pages are based upon internal and external subject matter expertise. The burden estimated to collect the necessary information has estimated to be 333,502 total annual burden 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.

97.067 Homeland Security Grant Program (HSGP) – The HSGP is a primary funding mechanism for building and sustaining national preparedness capabilities. HSGP is comprised of three separate grant programs (SHSP, UASI, OPSG) which fund a range of preparedness activities, including planning, organization, equipment purchase, training, exercises, and management, border security and administration costs.

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
State, Local or Tribal Government	HSGP/SHSP/UASI Investment Justification, FEMA Form 089-1	56	1	56	1488.5 hrs.	83,356	$38.14	$3,179,197
State, Local or Tribal Government	Documentation from SAA on how operational overtime UASI funds held by State would support urban area	10	2	20	4 hrs.	80	$38.14	$3,051
State, Local or Tribal Government	Multi-year Training & Exercise Plan	56	1	56	42 hrs.	2,352	$38.14	$89,705
State, Local or Tribal Government	Urban Area Working Group Structure, including Points of Contact	62	2	124	1354 hrs.	167,896	$38.14	$6,403,553
State, Local or Tribal Government	UASI Governance Charter	33	2	66	250 hrs.	16,500	$38.14	$629,310
State, Local or Tribal Government	UASI Strategy	33	2	66	500 hrs.	33,000	$38.14	$1,258,620
State, Local or Tribal Government	UAWG spending consensus	33	2	66	80 hrs.	5,280	$38.14	$201,379
State, Local or Tribal Government	OPSG Operations Order / FEMA Form 089-16	39	1	39	570	22,230	$38.14	$847,852
State, Local or Tribal Government	OPSG Inventory of Operation Orders / FEMA Form 089-20	39	1	39	72	2,808	$38.14	$107,097
Total		322		532		333,502		$12,719,764

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

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for Local Representation is estimated to be $27.24 per hour including the wage rate multiplier of the 1.4 multiplier, the total wage rate is $38.14 for completing and submitting the FEMA grant information to FEMA for review and approval. Therefore, the estimated total burden hour cost to State and Local Representatives is estimated to be $12,719,764 annually.

	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
	Standard Forms
	State, Local or Tribal Government		Application for Federal Assistance / SF 424		56		1	56		0.75		71
	State, Local or Tribal Government		Budget Information - Non-Construction Programs / SF 424A		56		1	56		6		285
	State, Local or Tribal Government		Assurances - Non-Construction Programs / SF 424B		56		1	56		0.25		24
	State, Local or Tribal Government		Budget Information - Construction Programs / SF 424C		56		1	56		3		285
	State, Local or Tribal Government		Assurances - Construction Programs / SF 424D		56		1	56		0.25		24
	State, Local or Tribal Government		Disclosure of Lobbying Activities / SF LLL		56		1	56		0.167		16
	State, Local or Tribal Government		Direct Deposit Sign-Up Form / SF 1199A		56		1	56		0.167		16
	State, Local or Tribal Government		Federal Financial Report / SF 425		56		4	380		1.5		570
	State, Local or Tribal Government		Financial Status Report / Standard Form 269		56		4	380		0.5		190
	Total							760				1481
Other Departments/ Agencies Data Collection Activities
State, Local or Tribal Government		Initial Strategy Implementation Plan (ISIP) / No Form; FEMA OMB Number 1660-0117		56		1			56
State, Local or Tribal Government		Biannual Strategy Implementation Report (BSIR) / No Form; FEMA OMB Number 1660-0117		56		2			112
State, Local or Tribal Government		Preparedness Comprehensive Assessment Support Tool (PrepCAST) / No Form Number; FEMA OMB Number 1660-0087		56		1			56
State, Local or Tribal Government		EHP - Environmental Screening Form / FEMA Form 024-0-1; FEMA OMB Number 1660-0115		56		1			56
State, Local or Tribal Government		Homeland Security Exercise & Evaluation Program (HSEEP) After Action Report (AAR) and Improvement Plan (IP) / FEMA Form 091-0; FEMA OMB Number 1660-0118		56		1			56
Total									336

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. (Do not include the cost of any hour burden shown in Items 12 and 14.)

The cost estimates should be split into two components:

a. Operation and Maintenance and purchase of services component. These estimates should take into account cost associated with generating, maintaining, and disclosing or providing information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred.

b. Capital and Start-up-Cost should include, among other items, preparations for collecting information such as purchasing computers and software, monitoring sampling, drilling and testing equipment, and record storage facilities.

There are no record keeping, capital, start-up or maintenance costs associated with this information collection.

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.

Annual Cost to the Federal Government

Item	Cost ($)
Contract Costs [Describe]
Staff Salaries* [ 35_#_ of GS _13_ , step_1_ employees spending approximately __60__% of time annually ….(description)……… for this data collection] [show calculations for this here and erase this] 35 x $89,033 = 3,116,155 x 4,362,617 x .60 = $2,617,570	$2,617,570
Facilities [cost for renting, overhead, etc. 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	$2,617,570

* 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.

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
HSGP/SHSP/UASI Investment Justification, FEMA Form 089-1				83,356	83,356	0
Documentation from SAA on how operational overtime UASI funds held by State would support urban area				80	80	0
Multi-year Training & Exercise Plan				2,352	2,352	0
Urban Area Working Group Structure, including Points of Contact				167,896	167,896	0
UASI Governance Charter				16,500	16,500	0
UASI Strategy				33,000	33,000	0
UAWG spending consensus				5,280	5,280	0
OPSG Operations Order / FEMA Form 089-16		22,230	+22,230
OPSG Inventory of Operation Orders / FEMA Form 089-20		2,808	+2,808
Total(s)		25,038	+25,038	308,464	308,464	0

Explain:

From the last OMB approval, OMB Collection 1660-0119, FEMA Preparedness Grants: Operation Stonegarden (OPSG) Collection was a stand-alone program and had its own PRA collection. This program has since been merged into the FEMA Preparedness Grants: Homeland Security Grant Program (HSGP) collection under OMB Collection 1660-0125 and as a result the burden hours have increased from 308,464 hours to 333,502 hours.

In 2009, OPSG was no longer its own program, the grant program has been incorporated into the HSGP grant and the forms used for the OPSG program has been included in the collection’s submission which has resulted in an increase of average burden hours.

Itemized Changes in Annual Cost Burden

Explain:

There is no cost burden for this collection.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

FEMA does not intend to employ the use of statistics or the publication thereof for this information collection.

17. If seeking approval not to display the expiration date for OMB approval of the information collection, explain reasons that display would be inappropriate.

FEMA  will display the expiration date for OMB approval of this information collection.

18. Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

FEMA does not request an exception to the certification of this information collection.

B. Collections of Information Employing Statistical Methods.

There is no statistical methodology involved in this collection.

10