Supporting Statement for OMB Collection 1660-0029

March 20, 2014

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660 - 0029

Title: Approval and Coordination of Requirements to Use the NETC Extracurricular for Training Activities

Form Number(s): FEMA Form 119-17-1; FEMA Form119-17-2

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 Robert T. Stafford Disaster Relief and Emergency Assistance Act (Stafford Act), 42 U.S.C. 5121-5207, authorizes the President to establish a program of disaster preparedness that utilizes services of all appropriate agencies and includes training and exercises. Section 611 (42 U.S.C. 5196) directs that the Federal Emergency Management Agency (FEMA) may conduct training for the purpose of emergency preparedness. In response, FEMA established the National Emergency Training Center (NETC), located in Emmitsburg, Maryland. The NETC site has facilities and housing available for those participating in emergency preparedness training and a request for use of these areas must be made in advance of the need for such.

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 119-17-1, Request for Housing Accommodations – This form collects the information necessary so that NETC can coordinate housing for contract instructors and attendees of the conference/meeting scheduled.

FEMA Form 119-17-2, Request for Use of NETC Facilities – This form collects the information that is necessary to allow NETC to assign classrooms, schedule equipment, and other facility services.

The program office must write, email, or telephone a request to determine if housing is available. If housing is available, the program office must follow-up by completing FEMA Form 119-17-1, Request for Housing Accommodations. The form provides the names, purchase order number, gender, and disability status so that NETC can coordinate housing for contract instructors and attendees of the conference/meeting scheduled. The form also identifies if lodging fees need to be collected from the conference/training attendees.

The policy of USFA is to also accommodate other training activities on a space-available basis at the Emmitsburg campus. Special groups must write, email, or telephone a request to determine availability of the facilities. If space is available, the contact person for the special group must follow-up by completing FEMA Form 119-17-2, Request for Use of NETC Facilities.

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.

FEMA Form 119-17-1 is produced via an electronic micro-purchasing system, and the information is automatically downloaded into the admissions system, which is used to assign housing for contract instructors. Although the FEMA Forms 119-17-1 and 119-17-2 can be accessible online for completion by those who are employed by the Department of Homeland Security, Federal Emergency Management Agency, FEMA Form 119-17-1 and FEMA Form 119-7-2 are applied for internal processes as a part of the FEMA Facility Directive, Number FFD119-13, “Coordination of Special Groups and Visitors at the National Emergency Training Center.” Within the content of the directive, VI. Policy and Procedures, F. “A person or group wanting to use the facility must submit a written request to: Director, NETC MOSS, U.S. Fire Administration, 16825 South Seton Avenue, Emmitsburg, Maryland 21727. Upon request lodging, conference rooms, classrooms, and equipment are provided at Prevailing rates.” Then further on in the Directive it identifies the forms required for completed and return to the Director, NETC MOSS as follows - 3. “If approved, the requestor will be informed that FEMA Form 75-11 (former number for Form 119-17-2, Request for use of NETC Facilities, must be completed and returned within 1 week of FEMA’s cover letter date. If lodging at NETC is also requested, FEMA Form 75-10 (former number for Form 119-17-1), Request for Housing Accommodations, must be completed to include a listing of names of all individuals requiring lodging at NETC and this form must be returned at least 2 weeks prior to scheduled conference/activity/event. Both forms should be returned to the Director, NETC MOSS.” The FEMA Form 119-17-1 and FEMA Form 119-17-2 are forms prescribed within the Directive. In all cases of requests for lodging and/or use of the facilities, the point of contact who initiates, distributes, and receives the forms to be completed is from the Office of the Director of NETC MOSS and that point of contact offers the guidance for the return of the completed forms whether it is by the means of postal service, delivered via fax or scanned and sent by email attachment to the point of contact in the Office of the Director of NETC MOSS. The guidance for generation, completion and return of the FEMA Forms 119-17-1 and 119-17-2 is established by the point of contact in direct response to requestors and with this being the arrangement; there are no printed directions on either form for submission.

FEMA Form 119-17-1 and FEMA Form 119-17-2 are available online at http://on.fema.net/employee_tools/forms/Pages/fema_forms.aspx. The forms can be downloaded for use and returned via e-mail to [email protected]. Forms are also returned via fax to (301) 447-1052, and can be mailed to NETC, 16825 South Seton Avenue, Emmitsburg, MD 21727, as established upon communication with requestors and the point of contact from the office of the Director of NETC MOSS.

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. 

There is no duplication efforts involved with this data collection.

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.

There is no impact to small business or other small entities for this data collection.

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 information is collected when housing accommodations and training activities are conducted at NETC as authorized.

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.

There is no requirement for respondents to report this information more often than quarterly.

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

There is no requirement for respondents to prepare a written response fewer than 30 days after receipt of the collection.

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

copies of any document.

There is no requirement for respondents to submit more than 1 original 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.

There is no requirement for respondents to retain records for more than three years.

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 of statistical data classification involved with this 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 required 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 is no requirement to submit proprietary trade secret, or other confidential information that the agency cannot demonstrate procedures to protect.

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 November 1, 2013, 78 FR 65676. 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 February 24, 2014, 79 FR 10174. 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.

The purpose of FEMA Form 119-17-1 and FEMA Form 119-17-2 are only used to request housing and use the NETC for official business. Consultation with NETC staff and requestors is coordinated before submitting FEMA Form 119-17-1. To determine if housing is available, the requestor must write, email or telephone the facility to confirm space availability and follow-up with the request by submitting a FEMA Form 119-17-1. To assign classrooms, schedule equipment, and arrange for other services, requestors must follow-up by completing FEMA Form 119-17-2.

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.

Consultations take place on occasion as a check to determine that information collected is clear and accurate.

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

There is no decision to provide any payment or gift to respondents for this collection.

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 April 4, 2011.

This collection is covered by an existing Privacy Impact Assessment (PIA), DHS/FEMA/PIA-022 - Student Training/Exercise Application and Registration Records, approved by DHS on March 29, 2012 and an existing System of Records Notice (SORN), DHS/FEMA-011 Training and Exercise Program Records System of Records 76 FR 19107 approved by DHS on April 6, 2011.

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 is one question regarding special needs status included on FEMA form 75-10 to ensure adequate accommodations are provide for handicapped requestors.

 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.

 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
Individuals or households; Business or other for-profit; Not-for-profit institutions; Farms; State, local or Tribal Government	Request for Housing Accommodations / FEMA Form 119-17-1	60	1	60	.1 (6 minutes)	6	$30.81	$185.00
Individuals or households; Business or other for-profit; Not-for-profit institutions; Farms; State, local or Tribal Government	Request for Use of NETC Facilities / FEMA Form 119-17-2	60	1	60	.1 (6 minutes)	6	$30.81	$185.00
Total		60		120		12		$370.00

• 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 all occupations is estimated to be ($22.01 x 1.4=) $30.81 per hour including the wage rate multiplier, therefore, the estimated burden hour cost to respondents all occupations is estimated to be $370.00 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:

1. 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.

2. 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] There is no contract	$0
Staff Salaries* [ _#_ of GS __ , step__ employees spending approximately ____% of time annually ….(description)……… for this data collection] [show calculations for this here and erase this] 1 GS-09 step 1 employee spending approximately 15% of time annually processing FEMA Forms 119-17-1 and 119-17-2 for assignment of space. $51,630 x .15 x 1.4 = $10,843.	$10,843
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	$10,843

* 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
Request for Housing Accommodations / FEMA Form 119-17-1				6	6	0
Request for Use of NETC Facilities / FEMA Form 119-17-2				6	6	0
Total(s)				12	12	0

Explain:

There are no changes to the annual hour burden previously reported and there has been no change to the information being collected.

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.

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