Supporting_Statement_1660-0118_12202013_OMB04022014_04232014

December 20, 2013

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660 - 0118

Title: Homeland Security Exercise and Evaluation Program (HSEEP) After Action Report (AAR) Improvement Plan (IP)

Form Number(s): FEMA Form 091-0

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.

The National Preparedness Goal (NPG) identifies the core capabilities necessary for preparedness and the National Preparedness System (NPS) guides activities that will enable the Nation to achieve the Goal. The System will allow the Nation to track the progress of our ability to build and improve the capabilities necessary to prevent, protect against, mitigate the effects of, respond to, and recover from those threats that pose the greatest risk to the security of the Nation.

Through the use of Homeland Security Exercise and Evaluation Program (HSEEP), exercise program managers can develop, execute, and evaluate exercises that address the priorities established by an organization’s leaders. These priorities are based on the NPG, strategy documents, threat and hazard identification/risk assessment processes, capability assessments, and the results from previous exercises and real-world events. These priorities guide the overall direction of a progressive exercise program, where individual exercises are anchored to a common set of priorities or objectives and build toward an increasing level of complexity over time. Accordingly, these priorities guide the design and development of individual exercises, as planners identify exercise objectives and align them to core capabilities for evaluation during the exercise. Exercise evaluation assesses the ability to meet exercise objectives and capabilities by documenting strengths, areas for improvement, core capability performance, and corrective actions in an After-Action Report/Improvement Plan (AAR/IP). Through improvement planning, organizations take the corrective actions needed to improve plans, build and sustain capabilities, and maintain readiness.

In this way, the use of HSEEP AAR/IPs—in line with the NPG and the NPS—supports efforts across the whole community that improve our national capacity to build, sustain, and deliver core capabilities.

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.

Homeland Security Exercise and Evaluation Program (HSEEP) After Action Report (AAR)/Improvement Plan (IP) – Improvement planning is the process by which the observations and recommendations recorded in the draft After-Action Report (AAR) are resolved through development of concrete corrective actions that are prioritized, tracked, and analyzed by program managers as part of a continuous Corrective Action Program (CAP). The information contained within this report identifies areas where expectations for preparedness are met, as well as areas where improvement is required. AAR/IP information can then be used to assist organizations in building various preparedness tools, such as the State Preparedness Report (SPR). SPRs are then made available to FEMA’s National Preparedness Assessment Division (NPAD) to improve capabilities, eliminate capability gaps and increase levels of preparedness for applicable Federal, State, tribal and local entities through the creation of a National Preparedness Report (NPR).

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.

The HSEEP AAR IP template can be downloaded from the HSEEP library on the Lessons Learned Information Sharing website at https://www.llis.dhs.gov/content/hseep-doctrine-and-templates in a Word document. The report is electronically completed and sent as an attachment via e-mail, or is directly mailed to FEMA in hardcopy format.

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.



The AAR/IP form exists as the single report for an exercise’s capability performance, participant feedback, and improvement planning. This information is not collected in any other 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.

The Homeland Security Exercise and Evaluation Program (HSEEP) After Action Report (AAR) Improvement Plan (IP) provides a standardized methodology and terminology for reporting on the results of preparedness exercises and provides assessments of the respondent’s capabilities so that strengths and areas for improvement are identified, corrected, and shared as appropriate to improve National Preparedness for all hazards. Without this information, such details would not be available for review, and the planning for real world events would be compromised. Put simply, AAR/IP data is required to assist in identifying shortfalls and planning for improvements.



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

The special circumstances contained in item 7(b) thru 7(h) of the supporting statement are not applicable to this information collection. See below for 7(a).

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

States complete five exercises a year under the Emergency Management Preparedness Grant Program. States complete an AAR/IP after exercises. Urban areas, which consist of one more local jurisdictions, normally also complete five exercises a year and complete form 091-0 after these exercises. Federal, local, and tribal entities usually respond fewer than five times a year.



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



(c) Requiring respondents to submit more than an original and two copies of any document.

(d) Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years.



(e) 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.

(f) Requiring the use of a statistical data classification that has not been reviewed and approved by OMB.

(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.



(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.



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 October 1, 2013, volume 78, number 190, Page 60301. There were no comments received for this collection of information.

A 30-day Federal Register Notice was published on December 12, 2013, volume 78, number 238, Page 75573. There were no comments received for this collection of information.

 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.

Consultations with other Federal Agencies, the National Council on Disability, and the National Advisory Council occur annually regarding the development, testing, and evaluation of the national preparedness goal and other plans and strategies. Several HSEEP working groups have been held with exercise and emergency management stakeholders across the Nation in order to provide recommendations for further development and revision of exercise evaluation and after-action reporting policy.

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.

Comments from representatives from whom the information is collected from are welcomed. A formal process for this to occur is the inclusion of the “Participant Feedback Summary” section within the report that allows the respondents to offer suggestions, critiques of exercise actions and other feedback. FEMA uses this information to better prepare for future exercises.

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

There is no offer of monetary or material value for this information collection.

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



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.

Respondents include State, Tribal and Local Governments or Federal Entities. First, states and territories who receive Homeland Security Grant Program Funding or Emergency Management Preparedness Grant funding participate in exercises and submit FEMA Form 091-0. FEMA has estimated that 56 states and territories submit five AARs (FEMA Form 091-0) per year.

Second, local governments who receive Urban Area Security Initiative funding participate in exercises and submit FEMA Form 091-0.   Urban Area Security Initiative funding is granted to entities called high-risk urban areas, which are selected from the 100 most populous metropolitan statistical areas in the United States and consist of one or more local jurisdictions.  Over the past three years, there has been an average of 29 high-risk urban areas who have received funding.  These high-risk urban areas submit FEMA Form 091-0 an estimated five times a year.

Third, there are additional local jurisdictions who do not receive UASI funding who submit a FEMA Form 091-0 once a year. Tribal governments also receive grant funding through the Tribal Homeland Security Grant Program and participate in exercises. However, few, if any, tribal governments have historically completed the form. In total, approximately 27 other local and tribal governments submit a FEMA Form 091-0 once a year.

In total, there are 112 (56 states +29 local government UASI recipients+27 other local jurisdictions and tribal governments) respondents that fit into the category of State, Tribal, or Local Governments. Of these, the average frequency of responses is approximately four times a year : (56 States*5 times a year +29 local government UASI recipients x 5 times a year + 27 other local and tribal governments*1 time year )/ 112 total respondents= 3.96. FEMA has rounded up to a frequency of 4. The total number burden hours for state, local and tribal governments is 112 State, Local or Tribal Governments x 4 responses per respondent per year x 40 hours = 17,920 hours.

Finally, an additional 63 Federal entities voluntarily respond to the request. Therefore, the burden estimate for these additional entities is 63 entities x 40 hours = 3,600 hours.

The total annual burden hours for this collection is estimated to be 20,440 total 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.

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	HSEEP/AAR/IP / FEMA Form 091-0	112	4	448	40	17,920	$38.14	$683,487.
Federal Government Entities		63	1	63	40	2520	$33.74	$85,025
Totals		175		511	40	20,440		$768,494.

• 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. The wage rate category for a Federal Government employee is estimated to be $33.74 including the 1.4 multiplier. The estimated total burden hour cost for this collection is estimated to $768,494 annually.

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:

There are no operation and maintenance, capital and start-up-cost to respondents for this collection of information.

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.

Annual Cost Burden to Respondents or Record-keepers

Data Collection Activity/Instrument	*Annual Capital Start-Up Cost (investments in overhead, equipment and other one-time expenditures)	*Annual Operations and Maintenance Cost (such as recordkeeping, technical/professional services, ect.)	Annual Non-Labor Cost (expenditures on training, travel and other resources)	Total Annual Cost to Respondents
	0	0	0	0
Total

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 $127,300 with 10% allocated to reviewing the After Action Reports, performing follow-up work as required and collating data. $127,300 x .10 = $12,730.	$12,730
Staff Salaries* 5 GS-13 , step 1 employees spending approximately 5% of time annually reviewing the data, making determinations of the outcomes, performing follow-up as necessary and assuring quality control of the process for this data collection [5 x 89,033 x 5% = 22,258 x 1.4 = $31,161]	$31,161
Facilities
Computer Hardware and Software
Equipment Maintenance
Travel
Printing
Postage
Other
Total	$43,891

* 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 a 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
HSEEP/AAR/IP/ FEMA Form 091-0				44,800	20,440	-24,360
Total(s)				44,800	20,440	-24,360

Explain: Reduction in hours is due to reassessment of AAR/IP completion time from 160 hours to 40 hours (-120) stemming from a simplified form and the use of electronic technology. The increase in the number of respondents is due to a more specific calculation of those who have historically submitted AAR/IP forms.

Itemized Changes in Annual Cost Burden (FEDERAL)
Data collection Activity/Instrument	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New)	Difference
HSEEP/AAR/IP/FEMA Form 091-0					$768,494	-$851,026
Total(s)					$768,494	-851,026

Explain: There is no program cost to respondents for this collection of information. The total burden hour cost has decreased from $1,619,520 to 768,494 due to decrease in the number of hours to complete the data collection instrument.

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.