9000-0153-_Supporting_Statement 10.27.14

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

9000-0153, OMB Circular A-119

A. JUSTIFICATION.

1. Administrative requirements. This is a request for OMB approval of information collection requirements associated with a revision to the Federal Acquisition Regulation (FAR) that implements OMB Circular A-119, Federal Participation in the Development and Use of Voluntary Consensus Standards. The regulation will permit offerors to propose alternatives to Government-unique standards in response to Government solicitations. This submission will only apply when the agency issuing the solicitation used Government-unique standards instead of voluntary consensus standards and when the agency uses the transaction-based reporting method.

2. Uses of information. This information will be used by the Federal agencies to determine if voluntary consensus standards will satisfy the Government’s needs.

3. Consideration of information technology. We use improved information technology to the maximum extent practicable. Where both the Government agency and contractors are capable of electronic interchange, the contractors may submit this information collection requirement electronically.

4. Efforts to identify duplication. This requirement is being issued under the Federal Acquisition Regulation (FAR) which has been developed to standardize Federal procurement practices and eliminate unnecessary duplication.

5. If the collection of information impacts small businesses or other entities, describe methods used to minimize burden. The burden applied to small businesses is the minimum consistent with applicable laws, Executive orders, regulations, and prudent business practices.

6. Describe consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently. Collection of the information is needed to comply with OMB Circular A-119.

7. Special circumstances for collection. There are no special circumstances for collection. Collection is consistent with the guidelines in 5 CFR 1320.5.

8. Efforts to consult with persons outside the agency. Under the procedures established for development of the FAR, agency and public comments were solicited and each comment addressed before finalization of the text. A 60 day notice published in the Federal Register at 79 FR 38892, on July 9, 2014. No comments were received. A 30 day notice was published in the Federal Register at 79 FR 56800, on September 23, 2014. No comments were received.

9. Explanation of any decision to provide any payment or gift to respondents, other than remuneration of contractors or guarantees. Not applicable.

10. Describe assurance of confidentiality provided to respondents. Information related to individual firm’s offers become part of the contract file. Information contained in that file will be subject to review and release in accordance with the Freedom of Information Act.

11. Additional justification for questions of a sensitive nature. No sensitive questions are involved.

12 & 13. Estimated total annual public hour and cost burden. FAR Subparts 11.1 and 11.2 were revised and a solicitation provision was added at 52.211-7, Alternatives to Government-Unique Standards, to implement the requirements of the revised OMB circular. If an alternative standard is proposed, the offeror must furnish data and/or information regarding the alternative in sufficient detail for the Government to determine if it meets the Government’s requirements. We believe the burden for FAR 52.211-7 to be negative, as it is purely a permissive means for offerors to propose reducing regulatory burden on a given solicitation. There are other places A-119 has an effect, though we believe these to be positive. One is by enabling the single process initiative. Another is the general replacement of Mil standards with commercial standards, e.g., ISO 9000. Also, A-119 is the basis for the language in FAR 53.105, which reduces the chaos in data standards development. The whole purpose of A-119 was to reduce regulatory burden by promoting the use of industry standards in lieu of federal ones.

To the extent that data on the annual frequency of the use of voluntary consensus standards under FAR 52.211-7 is not available, we believe 100 is reasonable. As an aside, FAR part 45 recognizes the use of voluntary consensus standards in the management of Government property. However, in these cases there is no Government standard per se, with the voluntary consensus standard serving as the Government standard. Consequently, when under part 45 voluntary consensus standards are used, they are not an alternative to a Government standard under FAR 52.211-7. Time required to read and prepare information is estimated at 1 hour.

Estimated respondents/yr....................... 100

Responses annually............................. x 1

Total annual responses......................... 100 Estimated preparation time (hrs) per response.. x 1

Estimated total burden/hrs..................... 100

Average wages + overhead ($32.73/hr¹ + 36.25% OH²) x $45

Total cost to the public.......................$4,500

14. Estimated cost to the Government.

Time required for Governmentwide review is estimated at 8 hours.

Annual Reviewing Burden and Cost

Total annual responses ........................ 100

Review time/hrs ............................... x 8

Review time/yr ................................ 800

Average wages/hr + overhead ($32.73/hr + 36.25% OH) $45

Total Government cost ....................... $36,000

15. Explain reasons for program changes or adjustments reported in Item 13 or 14. This submission requests an extension of OMB approval of an information collection requirement in the FAR. The information collection requirement in the FAR remains unchanged.

16. Outline plans for published results of information collections. Results will not be tabulated or published.

17. Approval not to display expiration date. Not applicable.

18. Explanation of exception to certification statement. Not applicable.

B. Collections of Information Employing Statistical
Methods.

Statistical methods are not used in this information collection.

1 The cost of $32.73 per hour is based on a GS-12 Step 5 salary (Base GS Salary Table 2012).

2 The 36.25% fringe benefit rate is derived from OMB Memorandum M-08-13, dated March 11, 2008.