Supporting Statement OMB NO 1660-0016 05142014

February 27, 2013

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660 - 0016

Title: Revision to National Flood Insurance Program Maps: Application Forms for LOMRs and CLOMRs

Form Number(s): FEMA Form 086-0-27, 086-0-27A, 086-0-27B , 086-0-27C , 086-0-27D, and 086-0-27E

General Instructions

A Supporting Statement, including the text of the notice to the public required by 5 Code of Federal Regulations (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 Office of Management and Budget (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 Flood Insurance Program (NFIP) is authorized by 42 U.S.C. 4001 et seq. (Public Law 90-448 (1968) and expanded by Public Law 93-234 (1973)). The Department of Homeland Security’s Federal Emergency Management Agency (FEMA) administers the National Flood Insurance Program (NFIP) and maintains the maps that depict flood hazard information. In 44 CFR Part 65.3, communities are required to submit technical information concerning flood hazards and plans to avoid potential flood hazards when physical changes occur. In 44 CFR Part 65.4, communities are provided the right to submit technical information when inconsistencies on maps are identified. In order to revise the Base (l-percent annual chance) Flood Elevations (BFEs), Special Flood Hazard Areas (SFHAs), and floodways presented on the NFIP maps, a community must submit scientific or technical data demonstrating the need for a revision. The NFIP regulations cited in 44 CFR Part 65 outline the data that must be submitted for these requests. This collection serves to provide a standard format for the general information requirements outlined in the NFIP regulations, and helps establish an organized package of the data needed to revise NFIP maps. This collection helps to:

• Ensure all data required to process these requests is received with the initial submittal

• Ensure processing consistency among all requests

• Ensure that submitted data are presented in a manner that will increase processing efficiency

• Reduce the amount of time required to process requests

• Reduce processing costs

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.

The information collected on FEMA Forms 086-0-27, 086-0-27A, 086-0-27B, 086-0-27C, 086-0-27D, and 086-0-27E is used to determine if such data will result in the modification of BFEs, SFHA, or floodway. Once the information is collected, it is submitted to FEMA for review and is subsequently included on the NFIP maps. These maps are used by communities for compliance with floodplain management regulations, by lenders in determining the application of the mandatory flood insurance purchase requirements, and by insurance agents in determining actuarial flood insurance rates. Respondents can also contact a call center at 1-877-336-2627 for answers to any questions that might come up during the completion of the data collection instruments.

This collection uses a series of six forms, described below:

1. FEMA Form 086-0-27, Overview and Concurrence Form, provides the basic information regarding the revision request, and requires the signatures of the requester, community official, and a registered professional engineer. This form is required for all revision requests. This form describes the location and nature of the requested NFIP map change, and the data required to support the request.

2. FEMA Form 086-0-27A, Riverine Hydrology and Hydraulics Form, provides the basic information on the scope and methodology of hydrologic and hydraulic analyses that are prepared in support of the revision request. This form should be used for revision requests that involve new or revised hydrologic or hydraulic analyses of rivers, streams, ponds, or small lakes.

3. FEMA Form 086-0-27B. Riverine Structures Form, provides the basic information regarding hydraulic structures constructed in the stream channel or floodplain. This form should be used for revision requests that involve new or proposed channelization, bridges/culverts, dams, or levees/floodwalls.

4. FEMA Form 086-0-27C, Coastal Analysis Form, provides the basic information on the scope and methodology of the coastal analyses that are prepared in support of the revision request. This form should be used for any revision requests that involve new or revised coastal analyses.

5. FEMA Form 086-0-27D, Coastal Structures Form, provides the basic information regarding hydraulic structures constructed along the coast. This form should be used for revision requests that involve new or proposed levees/dikes, breakwaters, bulkheads, seawalls, and/or revetments located along the coast.

6. FEMA Form 086-0-27E, Alluvial Fan Flooding Form, provides the basic information for analyses of alluvial fans. This form should be used for revision requests involving alluvial fans.

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 forms are made available on the Internet and can be downloaded from the Web site. The forms can be found at the following Web site address: http://www.fema.gov/library/viewRecord.do?id=1493. The forms are available on the Internet for download in Microsoft Word and Adobe Acrobat format. Alternatively, the collection may be submitted to FEMA electronically via the Online LOMC Tool. All required data to support the request may be submitted using this tool.

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 duplicate 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 this information were not collected, the NFIP maps could not be revised as required by regulation to reflect current, existing flood hazards. Processing of these requests helps to improve the accuracy of FEMA map products, and the effectiveness of the NFIP. Accurate mapping allows FEMA to be more efficient with its promulgation of the all of the regulations covering the NFIP.

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

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

1. Requiring respondents to report information to the agency more

often than quarterly.



(b) Requiring respondents to prepare a written response to a

collection of information in fewer than 30 days after receipt of it.



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

copies of any document.



3. 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 December 23, 2013, volume 78, number 246, Page 77479. There were no comments received for this collection of information.

A 30-day Federal Register Notice inviting public comments was published on March 6, 2014, volume 79, number 44, Page 12701. 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.

FEMA conducts several workshops for community officials, engineers, surveyors, and developers every year on the details and requirements of this information request. Attendees use the opportunity to give comments and request clarifications of instructions.

(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’s Web site https://faq.fema.gov/app/ask2 includes an form, in which respondents can provide comments regarding the forms and clarity of instructions. The FEMA Mapping Information Exchange (FMIX) also provides a toll free number (1-877-336-2627) to answer questions and provide an opportunity for respondents to comment on the forms.

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 Impact Assessment (PIA), DHS/FEMA/PIA-028, was completed on April 30, 2013. The PIA is currently being reviewed by DHS. A System of Records Notice (SORN), titled “Letter of Map Amendment system, DHS/FEMA/NFIP/LOMA–1” was approved on February 16, 2006. The SORN is also currently undergoing review by DHS for updates.

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 a 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. 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.

FEMA Form 086-0-27- It is estimated that 1,100 forms will be received from State, local and Tribal governments for submission to FEMA. It will take approximately 15 minutes for civil Engineers to complete their potion of the form and 45 minutes for Engineers or Surveyors to complete their potion of the form for a total of 1 hour to complete the form and submit to FEMA. Therefore 1,100 responses x 1 hours to complete the form is estimated to be 1,100 total burden hours.

FEMA Form 086-0-27A – It is estimated that 1,100 forms will be received from State, local and Tribal governments for submission of the form to FEMA. It will take approximately 45 minutes for civil engineers to complete their portion of the form and 165 minutes for an Engineer or Surveyor to complete their potion of the form. The total burden estimate for completed the form is estimated to be 3.5 hours. Therefore 1,100 responses x 3.5 hours is estimated to be 3,850 total burden hours.

FEMA Form 086-0-27B - It is estimated that FEMA will receive 990 responses from State, local and Tribal Government for submission of this form to FEMA . 990 Engineers or Surveyors will complete their portion of the form and that it will take an average of 7 hours to complete the form. Therefore 900 responses x 700 is estimated to be 6,930 total burden hours.

FEMA Form 086-0-27C - It is estimated that FEMA will receive 110 responses from State, local and Tribal Government for submission of this form to FEMA. Engineers or Surveyors will complete their portion of the form, which is estimated to take 1 hour. Therefore 110 responses x 1 hour = 110 total burden hours.

FEMA Form 086-0-27D - It is estimated that FEMA will receive 110 responses form State, Local and Tribal Government for submission of this form to FEMA. Engineers or Surveyors will complete their portion of the form, which is estimated to take 1 hour. Therefore 110 responses x 1 hour = 110 total burden hours

FEMA Form 086-0-27E - It is estimated that FEMA will receive 110 responses from State, Local and tribal Government for submission of this form to FEMA. Engineers or Surveyors will complete their portion of the form, which is estimated to take 1 hour. Therefore 110 responses x 1 hour = 110 total burden hours.

2. 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. 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 Responses 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)	Form 086-0-27, Overview and Concurrence Form	1,100	1	1,100	1 hour	1,100	$56.85	$62,535.
State. Local or Tribal Government	Form 086-0-27A, Riverine Hydrology and Hydraulics Form	1,100	1	1,100	3.5 hour (210 minutes)	3,850	$56.85	$437,745.
Business or other for-profit	Form 086-0-27B, Riverine Structures Form	990	1	990	7 hour	6,930	$61.22	$424,255.
Business or other for-profit	Form 086-0-27C, Coastal Analysis Form	110	1	110	1 hour	110	$61.22	$6,734
Business or other for-profit	Form 086-0-27D, Coastal Structures Form	110	1	110	1 hour	110	$61.22	$6,734
Business or other for-profit	Form 086-0-27E, Alluvial Fan Flooding Form	110	1	110	1 hour	110	$61.22	$6,734
Total		3,520		3,520		12,210		$944,737.

The wage rate categories above reflect the application of the 1.4 multiplier

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for Local Government Civil Engineer is estimated to be 56.85 to include the 1.4 multiplier., Therefore, the estimated burden hour cost to respondents for a Local Government Civil Engineer is estimated to be 56.85 x 8,800 500,280. annually.

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for Engineer is estimated to be 61.22 to include the 1.4 wage rate multiplier. Therefore, the estimated burden hour cost to respondents for Engineer/Surveyors services is estimated to be 7,260 responses x 61.22 = $447,457. annually.

The total annual cost burden for this collection is estimated to be $944,737.

13. Provide an estimate of the total annual cost burden to respondents or record keepers 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.

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, etc.)	Annual Non-Labor Cost (expenditures on training, travel and other resources)	Total Annual Cost to Respondents
FEMA Form 086-0-27	0	$1,100,000	0	$1,100,000
FEMA Form 086-0-27A	0	$11,000,000	0	$11,000,000
FEMA Form 086-0-27B	0	$4,950,000	0	$4,950,000
FEMA Form 086-0-27C	0	$1,100,000	0	$1,100,000
FEMA Form 086-0-27D	0	$550,000	0	$550,000
FEMA Form 086-0-27E	0	$1,100,000	0	$1,100,000
Total	$0	$19,800,000	$0	$19,800,000

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

The cost to developers for an engineer’s or surveyor’s services is broken down above for each form. The engineer’s services include scoping, surveying cross-sections, developing hydrologic and hydraulic analysis, and preparing work maps and reports documenting the engineering analysis and results.

For FEMA Form 086-0-27, it is estimated that 1,100 Engineers or Surveyors will charge an average of $1,000 to research the information needed to complete this form. Therefore, the total annual cost for this form is estimated to be 1,100 X $1,000 = $1,100,000.

For FEMA Form 086-0-27A, it is estimated that 1,100 Engineers or Surveyors will charge an average of $10,000 to produce the technical data required to complete this form. However, this can vary greatly depending on the size of the revision area and complexity of the watercourse. Therefore, the total annual cost for this form is estimated to be 1,100 X $10,000 = $11,000,000.

For FEMA Form 086-0-27B, it is estimated that 990 Engineers or Surveyors will charge an average of $5,000 to produce the technical data required to complete this form. However, this can vary greatly depending on the size of the revision area and complexity of the watercourse. Therefore, the total annual cost for this form is estimated to be 990 X $5,000 = $4,950,000.

For FEMA Form 086-0-27C, it is estimated that 110 Engineers or Surveyors will charge an average of $10,000 to produce the technical data required to complete this form. Therefore, the total annual cost for this form is estimated to be 110 X $10,000 = $1,100,000.

For FEMA Form 086-0-27D, it is estimated that 110 Engineers or Surveyors will charge an average of $5,000 to produce the technical data required to complete this form. Therefore, the total annual cost for this form is estimated to be 110 X $5,000 = $550,000.

For FEMA Form 086-0-27E, it is estimated that 110 Engineers or Surveyors will charge an average of $10,000 to produce the technical data required to complete this form. Therefore, the total annual cost for this form is estimated to be 110 X $10,000 = $1,100,000.

The total annual cost burden to the respondents is estimated to be $1,100,000 + $11,000,000 + $4,950,000 + $1,100,00 + $550,000 + $1,100,000 = $19,800,000 annually.

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 [Description below.]	$18,500
Staff Salaries [1 GS12 Step 1 employee spending approximately 5% of time annually ($74,872 per year) time to the review, coordination, and approval of the final submission for MT-2 forms.] $74,872 x .05 =	$3,744
Facilities [cost for renting, overhead, etc. for data collection activity]	$0
Computer Hardware and Software [cost of equipment annual lifecycle]	$0
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]	$0
Travel	$0
Printing [32,500 MT-2 forms annually @ .6572 per]	$0
Postage [mailing 500 MT-2 forms as requested @.61 per]	$0
Other	0
Total	$22,244

The contractor costs are estimated to be $18,500. This cost includes call center staff responding to an average of 3,200 calls per year that pertain to this collection. Most of these calls are from respondents who require assistance with completing the forms and interpreting the instructions. Based on historical call center data, calls pertaining to the forms lasts an average of 6 minutes. Based on an average loaded rate of $50.00 per hour, the contractor costs for responding to these calls is $16,000. The contract costs associated with completing and submitting the required documents for this collection is estimated to be $2,500. This includes 50 hours and is based on an average loaded rate of $50.00 per hour.

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
Form 086-0-27, Overview and Concurrence Form				1,500	1,100	-400
Form 086-0-27A, Riverine Hydrology and Hydraulics Form				5,250	3,850	-1,400
Form 086-0-27B, Riverine Structures Form				1,500	6,930	-3,570
Form 086-0-27C, Coastal Analysis Form				150	110	-40
Form 086-0-27D, Coastal Structures Form				150	110	-40
Form 086-0-27E, Alluvial Fan Flooding Form				150	110	-40
Total(s)				17,700	12,210	-5,490

Explain:

For FEMA Forms 086-0-27, 086-0-27A and 086-0-27B, there is a reduction in the annual hour burden for each form due to less new developments being planned or built in areas where these forms would be required. Also, the last few years have shown a trend of decreasing respondents.

For FEMA Form 086-0-27, the current annual hour burden is 1,500 hours, the new hours burden is 1,100 for a decrease of 400 annual hour burden due to the decrease in the number of respondents.

For FEMA 086-0-27A, the current annual hour burden is 5,250 hours, the new hours burden is 3,850 for a decrease of 1,400 annual hour burden due to the decrease in the number of respondents.

For FEMA Form 086-0-27B, the current annual hour burden is 10,500 hours, the new hours burden is 6,930 for a decrease of 3,570 annual hour burden due to the decrease in the number of respondents.

For FEMA Forms 086-0-27C, 086-0-27D and 086-0-27E, the current annual hour burden is 150 hours, the new hours burden is 110 for a decrease of 40 hours for each form due to the decrease in the number of respondents.

All changes in burden responses and time are a result of agency estimate. There is no change to the information being collected. However, this is an increase to the annual cost burden. The increase is a result of capturing, by error, the annual wage rates in the previous submission. In the previous submission, the cost to respondents for services by a surveyors or engineers was not properly captured. This ICR has been updated to properly capture those fees. Thus showing a significant increase in the annual cost burden to respondents.

Itemized Change in Annual Cost Burden

Itemized Changes in Annual Cost Burden
Data collection Activity/Instrument	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New)	Difference
Form 086-0-27, Overview and Concurrence Form				$80,955	$62,539	-$18,416
Form 086-0-27A, Riverine Hydrology and Hydraulics Form				$253,147	$199,746	-$53,401
Form 086-0-27B, Riverine Structures Form				$489,825	$350,145	-$139,680
Form 086-0-27C, Coastal Analysis Form				$6,998	$5,558	-$1,440
Form 086-0-27D, Coastal Structures Form				$6,998	$5,558	-$1,440
Form 086-0-27E, Alluvial Fan Flooding Form				$6,998	$5,558	-$1,440
Total(s)				$844,921	$629,104	-$215,817

Explain:

For FEMA Forms 086-0-27, 086-0-27A and 086-0-27B, there is a decrease in the annual cost burden for each form due to less new developments being planned or built in areas where these forms would be required. Also, the last few years have shown a trend of decreasing respondents.

For FEMA Form 086-0-27, the current annual cost burden is $80,955; the new cost burden is $62,539 for a decrease of $18,416. This is due to a decrease in the number of respondents.

For FEMA Form 086-0-27A, the current annual cost burden is $253,147; the new cost burden is $199,746 for a decrease of $53,401. This is due to a decrease in the number of respondents.

For FEMA Form 086-0-27B, the current annual cost burden is $489,825; the new cost burden is $350,145 for a decrease of $139,680. This is due to a decrease in the number of respondents.

For each of the FEMA Forms 086-0-27C, 086-0-27D and 086-0-27E, the current annual cost burden is $6,998; the new cost burden is $5,558 for a decrease of $1,440 for each form. This is due to a decrease in the number of respondents.

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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