LFPP Supporting Statement 7-16-14

LFPP Supporting Statement 7-16-14.docx

Local Food Promotion Program

OMB: 0581-0287

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2014 SUPPORTING STATEMENT

for the Local Food Promotion Program (LFPP)


OMB No. 0581-0287

(Regular)


A. Justification.


  1. EXPLAIN THE CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY. IDENTIFY ANY LEGAL OR ADMINISTRATIVE REQUIREMENTS THAT NECESSITATE THE COLLECTION.


The Agricultural Marketing Service (AMS) is requesting approval for an information collection. A burden is being imposed on eligible entities that apply to and are awarded under the Local Food component of the “Farmers’ Market and Local Food Promotion Program (FMLFPP).” The Agriculture Act of 2014 (P.L. 113-79) (2014 Farm Bill) amended the Farmer-to-Consumer Direct Marketing Act of 1976 (7 U.S.C. 3005) by expanding and renaming the Farmers’ Market Promotion Program (FMPP) to FMLFPP.


Whereas the former FMPP only funded farmer-to-consumer direct marketing projects such as farmers markets, community supported agriculture programs, road-side stands, and agri-tourism, the amended program will now include funding opportunities for projects that develop, improve, and expand local and regional food business enterprises that process, distribute, aggregate or store locally or regionally produced food products.


Through fiscal years 2014-2018, the 2014 Farm Bill provides $30 million in funding for the FMLFPP. On an annual basis, approximately $15 million will be made available for farmer-to-consumer direct marketing projects under the FMPP component of FMLFPP, and approximately $15 million will be made available for local and regional food business enterprise projects under the Local Food Promotion Program (LFPP) component of FMLFPP. Eligible entities for grants under LFPP include: agricultural cooperatives, producer networks, producer associations, community supported agriculture networks, community supported agriculture associations, and other agricultural business entities (for-profit groups); nonprofit corporations; public benefit corporations; economic development corporations; regional farmers’ market authorities; and local and Tribal governments.


Direct marketing project applications will be facilitated under the current Office of Management and Budget (OMB) approved information collection for FMPP. Conversely, LFPP project applications that pertain to the development, improvement, or expansion of local and regional food business enterprises will need to be facilitated through an information collection.




  1. INDICATE HOW, BY WHOM, AND FOR WHAT PURPOSE THE INFORMATION IS TO BE USED. EXCEPT FOR NEW COLLECTION, INDICATE THE ACTUAL USE THE AGENCY HAS MADE OF THE INFORMATION RECEIVED FROM THE CURRENT COLLECTION.


Electronic and paper submissions from the applicant to AMS/USDA are not accepted. All forms must be submitted electronically via the Grants.gov website. The following are LFPP forms and information required during the LFPP application submission (pre-award), application review, and post-award processes:


Pre-Award

AMS requires LFPP grant applicants to complete and submit the following forms and information:

  1. Registration with the System of Award Management

The System of Award Management (SAM) (OMB 3090-0290) is the primary registrant database for the U.S. Federal Government. The SAM.gov system (www.sam.gov) is a combination of Federal procurement systems and the Catalog of Federal Domestic Assistance, and includes the Central Contractor Registration. The SAM.gov system collects, validates, stores, and disseminates data in support of agency acquisition missions, including Federal agency contracts, grants, cooperative agreements, and other forms of Federal assistance and assistance awards. Whether applying for assistance awards, contracts, grants, or other business opportunities, all entities are considered “registrants.” All eligible entities applying for assistance awards from the Federal government via Grants.gov, and (application) reviewers receiving a stipend under LFPP, are required to register with SAM.gov in order to be awarded or receive funds by the Federal government. The type of information requested by SAM.gov includes, but is not limited to:

a. General information, including organization DUNS number, Federal Tax Identification Number (TIN), location, employee numbers, and website address.

b. Corporate Information, including organization or business type and SBA-defined socioeconomic characteristics.

c. Financial Information, including financial institution, American Banking Association (ABA) routing number, account number, remittance address, lock box number, automated clearing house (ACH) information, and credit card information.

d. Point of Contact Information, including the primary and alternate points of contact and the electronic business, past performance, and government points of contact.

Registrants are required to complete the annual SAM.gov registration to provide information relevant to procurement and financial transactions. SAM.gov shares the data received from registrants with the Federal government. AMS uses this information in establishing its electronic (direct deposit) payment system. Note that the SAM.gov registration does not guarantee business with AMS/LFPP or any other Federal government agency.

  1. LFPP Request for Applications Announcement and Program Guidelines:

AMS publishes an announcement and guidance documentation which contains information regarding how to complete a grant application package, along with a public notice of funds. The LFPP Announcement and Program Guidelines will be revised annually, or as needed, and posted with the application announcement at www.Grants.gov and on the AMS website at www.ams.usda.gov/LFPP as soon as the Agency announces LFPP is accepting applications. While this document is not signed, applicants must read and utilize this document to prepare their application, review which items are allowable, and understand the terms and conditions of the grant award.

  1. Form SF-424, “Application for Federal Assistance,” (common form approved under OMB collection number 4040-0004) is required by all entities seeking Federal assistance. AMS will use the information to determine the entity’s eligibility for participation in the LFPP grant program. The form can be obtained electronically via the www.Grants.gov website during application submission.


  1. Form SF-424B, “Assurances – Non-Construction Programs,” (approved under OMB collection number 4040-0007) must be completed by applicants to assure the Federal government of the applicant’s legal authority to apply for Federal assistance. AMS will use the information to certify that grant participants are complying with applicable program regulations. The form can be obtained electronically via the www.Grants.gov website during application submission.


  1. LFPP Grant Narrative

Completed applications must include a project narrative. AMS will use the information prior to award (pre-award) to determine eligibility of applicants; and pre- and post-award, to evaluate goals, objectives, work plans, expected results, and budget for the project prior to and after project implementation. The submitted narrative must not exceed 12 typed single-spaced 8” x 11” pages and include the following information:

  1. Project Title. Must capture the primary focus of the project and match the title provided on the SF-424.

  2. Applicant/Organization Information. The applicant/organization name, contact name, mailing address, telephone and fax number, and the email address for the person(s) designated to answer questions about the application, financial information, and the proposed project budget.

  3. Primary Project Manager Information. The name, mailing address, telephone and fax number, and email address for the person(s) responsible for managing and/or overseeing the project.

  4. Grant Application Type. The type of application being submitted to LFPP; “Planning Grant” or “Implementation Grant.”

  5. Requested LFPP Funding and Matching Funds. The dollar amount requested from LFPP, and the amount of the matching funds.

  6. Entity Type and Eligibility Statement. The entity type, statement of qualification as an eligible entity, and any required documentation of eligibility.

  7. Priority Project Selection. Indication of LFPP Priority, i.e., whether or not the proposal serves or is being implemented in an area of concentrated poverty with limited access to fresh locally or regionally grown foods.

  8. Executive Summary. The proposal summary provides the project description, goals to be accomplished, expected outcomes, and the timeframe for completion.

  9. Background Statement. A description of the current conditions that justify the need of the project, and an explanation of why the condition will not be improved absent the project so that the need will remain unmet.

  10. Work Plan, Resources, and Timeline Requirements. A list of each planned activity, a timeline for completion, resources needed, and milestones for assessing progress for each activity.

  11. Expected Outcomes and Intended Beneficiaries. List of outcomes of the project and the intended beneficiaries of each outcome. Describe the method of quantifying the outcomes and demonstrate impact of the project.

  12. Budget Justification. After preparing the budget using the “LFPP Project Budget and Match Request” form, provide a written justification to explain how the items requested are reasonable and support the project’s purpose and goals.

  13. Project Planning or Implementation Areas. Information about the location(s) of where the project is being planned or implemented, including the street address, city, state, zip code, and maps.

Given that this program will be established for the first time, AMS may review and revise the form annually and will submit any changes to OMB for approval. The narrative form is available on the AMS website at www.ams.usda.gov/LFPP and at www.Grants.gov.


  1. LFPP Project Budget and Match and Budget Request

Each applicant must provide line-item details about the requested funds and required 25 percent match. Each budget request and match must:

      1. List each under the following categories: Personnel, Contractors, Travel, Equipment ($5,000 or more per unit), Supplies (includes equipment less than $5,000), Other, and Indirect Costs.

      2. Be itemized, listing separately each item, its costs, and use.

      3. Correlate to the purpose/goals of the project and demonstrate that the budget is reasonable and adequate for the proposed work.

      4. Be substantiated in a written budget justification that is included in the “LFPP Grant Narrative” form.

AMS may review and revise the form annually and will submit any changes to OMB for approval. The budget form is available on the AMS website at www.ams.usda.gov/LFPP and at www.Grants.gov.



  1. Written Proof of Eligibility

In addition to an explanation in the narrative of how the applicant/organization qualifies as an eligible entity, written proof must also be provided in the application package. This documentation may include, for example for a nonprofit, a copy of the organization’s letter of determination from the State or Internal Revenue Service indicating the date of incorporation as a nonprofit. Further details are provided in the “LFPP Announcement and Program Guidelines” on the AMS website at www.ams.usda.gov/LFPP and at www.Grants.gov.


  1. LFPP Verification Letter(s) of Matching Funds

Completed applications must include written verification of commitment from each third party who will contribute cash and/or in-kind matching non-Federal resources to the project. Further details are provided in the “LFPP Announcement and Program Guidelines” on the AMS website at www.ams.usda.gov/LFPP and at www.Grants.gov.

Application Review

AMS requests potential grant reviewers to read and complete the following form:


  1. LFPP Peer Reviewer Application and Qualifications

AMS utilizes this mandatory form for reviewers to complete and submit their personal or work qualifications and resume. Reviewers must have a general knowledge of local and regional food enterprises that includes, but is not limited to, the financing, establishing, and operational aspects of businesses enterprises that process, distribute, aggregate, and/or store locally or regionally produced food products. Reviewers will apply their knowledge and expertise in these areas to objectively assess applications and provide both a numeric score and written comments for each application. The form contains a checklist for potential reviewers to identify their employment and voluntary work experience. Boxes are provided for potential reviewers to indicate (a) their area of experience or expertise and (b) whether the person is a current or retired nonprofit, for-profit, or Federal/State government employee. The form is not signed, but submitted via email along with a copy of their resume. AMS may also request additional information or clarification from potential reviewers. The reviewer qualifications are used to determine whether a reviewer is qualified to serve as part of the grant review process. AMS will review and may revise the form annually. This form is available on the AMS website at www.ams.usda.gov/LFPP. This form is also used by the Farmers Market Promotion Program, and the burden for this form is included in this submission (see AMS-71).


AMS also requires anyone serving as a grant reviewer to comply with and sign the following:



  1. AMS-34, AMS Conflict-Of-Interest and Confidentiality Statement For Grant Reviewers

This mandatory form for reviewers to sign indicates compliance with the conflict of interest and confidentiality requirements. Regarding confidentiality, reviewers must agree not to copy, quote, or otherwise use or disclose to anyone, any information from any application. Reviewers must also agree with the conflict of interest requirements, which include that the reviewer does not have: a) a direct financial interest in the review outcome; or have direct and predictable financial interests in the outcome; b) indirect interests with the organization or personnel submitting an application under LFPP; or C) any relationship, such as a close personal friendship, that may affect the reviewers’ judgment or be seen as doing so by a reasonable person familiar with the relationship. Peer reviewers will not be eligible to serve as a reviewer if they are (a) employed by, volunteer for, or serve as a board member or other type of committee/team member for an organization that submitted an application that same year under LFPP; or (b) a proposed subcontractor or financial beneficiary in a budget from any organization submitting an application that same year under LFPP. This form will be made available on the AMS website at www.ams.usda.gov/LFPP.


Post-Award

Before grant funds are dispersed, applicants that are selected (awardees) must comply with the terms and conditions of the grant and sign the grant agreement, as detailed under the following two forms:


  1. LFPP Grant Program, General Terms and Conditions

This document is currently being developed. As such, this information collection includes a similar document, “FMPP General Terms and Conditions,” to serve as an example. This is a mandatory form for awardees indicating compliance with terms and conditions of the award and all Federal grant regulations and administrative requirements including 7 CFR parts 3015, 3016, 3018, 3019; and FAR 31.2. The document also includes awardee assurances and certifications with the incoming application submission; changes in project contacts, leaders, managers, and staff; cost principles; actions that need prior approval; performance monitoring; reporting requirements; and payment requirements. The LFPP Grant Program General Terms and Conditions does not require a signature and may be updated annually to reflect mandatory additions and other changes made by regulatory or Office of Management and Budget grant requirements. This form will be made available on the AMS website at www.ams.usda.gov/LFPP.


  1. Grant Agreement – Form AMS-33, United States Department of Agriculture, Agricultural Marketing Service, Agreement Face Sheet

The grant agreement includes a mandatory form for awardees to sign indicating compliance with the terms and conditions of the grant award, project work approved, and receipt of grant funding. The sheet includes the grant authority; funding dollar amount; awardee and Federal contact names, address, email addresses, and phone and fax numbers; agreement number; project title, objectives, and statement of work; project work beginning and ending dates; and awardee and AMS Transportation and Marketing Program’s Deputy Administrator’s signatures. Two (2) copies of this agreement are required with the awardee’s and the AMS Transportation and Marketing Program’s Deputy Administrator’s office signatures and dated for each grant. The grant agreement face sheet includes a document which outlines the award terms and conditions. By signing the agreement face sheet, applicants agree to adhere to the terms and conditions of the grant award. This completed form will be emailed by AMS to the award recipients.


Additionally, grant awardees must also complete the following forms for AMS:


13. Form SF-270, “Request for Advance and Reimbursement” (approved under OMB collection number 4040-0012) is required whenever the awardees request an advance or reimbursement of Federal grant funds. AMS expects that at least two (2) SF-270 forms will be submitted during the grant agreement period. For payment requests, the form must be completed with the awardee’s signature, scanned, and submitted to AMS by email. The form can be obtained electronically via the AMS website at www.ams.usda.gov/LFPP.


  1. Interim Performance Reports

The Interim Performance Report is written documentation required to notify AMS about the work activities and progress towards completing the awardee’s established project work plan goals, objectives, and timelines. AMS requires that the Interim Performance Report be submitted at the mid-point of the grant agreement period. Further details will be provided in the “FMPP General Terms and Conditions” on the AMS website at www.ams.usda.gov/LFPP.


  1. Final Performance Report

The Final Performance Report is a written description of the fulfillment of the project terms required by AMS within 90 days after the ending date of the grant agreement. This information is utilized as final documentation of completion of the work plan goals, objectives, and activities. Further details will be provided in the “FMPP General Terms and Conditions” on the AMS website at www.ams.usda.gov/LFPP.


  1. Form SF-425, “Federal Financial Report” (approved under OMB collection number 4040-0014) is required by AMS with each payment request. AMS expects that a minimum of two (2) or a maximum of seven (7) Federal Financial Reports will be submitted depending on the duration of the grant agreement period. Additionally, a final “Federal Financial Report” is to be completed once by the awardee(s) 90 days after the expiration date of the grant period. The form can be obtained electronically via the AMS website at www.ams.usda.gov/LFPP.

  1. Grant Recordkeeping

AMS requires that grant recipients maintain all records pertaining to the grant for a period of 3 years after the final status report has been submitted to AMS, in accordance with Federal recordkeeping regulations. This requirement is provided in 7 CFR § 3015.21 and 3015.22 and the “LFPP General Terms and Conditions,” which will be available at the AMS website at www.ams.usda.gov/LFPP.

  1. 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.


AMS is committed to compliance with the Government Paperwork Elimination Act that requires Government agencies in general to provide the public the option of submitting information or transacting business electronically to the maximum extent possible. With the exception of Form AMS-33 (#12 below), all of the LFPP forms and information can be accessed or will be made available electronically at the following websites:


  1. Registration with the System of Award Management – Applicants register at www.sam.gov.


  1. LFPP Announcement and Program Guidelines are posted with the application announcement at www.Grants.gov and on the AMS website at www.ams.usda.gov/LFPP when the Agency announces the grant.

  1. Form SF-424 can be obtained electronically via the Grants.gov website at www.Grants.gov during application submission.


  1. Form SF-424B can be obtained electronically via the Grants.gov website at www.Grants.gov during application submission.


  1. LFPP Grant Narrative is available on the AMS website at www.ams.usda.gov/LFPP and at www.Grants.gov.


  1. LFPP Project Budget and Match and Budget Request is available on the AMS website at www.ams.usda.gov/LFPP and at www.Grants.gov.


  1. Written Proof of Eligibility – Information on written proof of eligibility is available in the “LFPP Announcement and Program Guidelines” on the AMS website at www.ams.usda.gov/LFPP and at www.Grants.gov.


  1. LFPP Verification Letter(s) of Matching Funds – Information on the verification letter is provided in the “LFPP Announcement and Program Guidelines” on the AMS website at www.ams.usda.gov/LFPP and at www.Grants.gov.


  1. LFPP Grant Reviewer Qualifications will be made available on the AMS website at www.ams.usda.gov/LFPP.


  1. AMS-34, AMS Conflict-Of-Interest and Confidentiality Statement For Grant Reviewers will be made available on the AMS website at www.ams.usda.gov/LFPP.


  1. LFPP Grant Program, General Terms and Conditions will be made available on the AMS website at www.ams.usda.gov/LFPP.


  1. Grant Agreement – Form AMS-33, United States Department of Agriculture, Agricultural Marketing Service, Agreement Face Sheet – By signing the agreement face sheet, applicants agree to adhere to the term and conditions of the grant award. This completed form will be emailed by AMS to the award recipients.


13. Form SF-270 can be obtained electronically via the AMS website at www.ams.usda.gov/LFPP.


  1. Interim Performance Reports – Information on this report will be provided in the “FMPP General Terms and Conditions” on the AMS website at www.ams.usda.gov/LFPP.


  1. Final Performance Report – Information on this report will be provided in the “FMPP General Terms and Conditions” on the AMS website at www.ams.usda.gov/LFPP.


  1. Form SF-425 can be obtained electronically via the AMS website at www.ams.usda.gov/LFPP.


  1. Grant Recordkeeping requirements will be made available within the “LFPP General Terms and Conditions” at www.ams.usda.gov/LFPP.


Additionally, all applicable forms will be submitted electronically via the Grants.gov website at www.Grants.gov.


  1. DESCRIBE EFFORTS TO IDENTIFY DUPLICATION. SHOW SPECIFICALLY WHY ANY SIMILAR INFORMATION ALREADY AVAILABLE CANNOT BE USED OR MODIFIED FOR USE FOR THE PURPOSE(S) DESCRIBED IN ITEM 2 ABOVE.


This program will not be maintained by any other agency, therefore, the requested information will not be available from any other existing records.



  1. IF THE COLLECTION OF INFORMATION IMPACTS SMALL BUSINESSES OR OTHER SMALL ENTITIES (ITEMS 5 OF THE OMB FORM 83-I), DESCRIBE THE METHODS USED TO MINIMIZE BURDEN.


The Small Business Administration defines, in 13 CFR part 121, small agricultural service firms (small for-profit organizations) as those having annual receipts of no more than $7 million.  Given that this program will be established for the first time, there is not sufficient data to accurately assess the number of organizations that will apply and meet the definition of small agricultural service firms. However, it is expected given consultations with industry leaders that at least half of the local and regional food business enterprises eligible for funding under LFPP will have annual receipts of no more than $7 million. With the estimation of 1,500 respondents for this collection, we can roughly estimate that 750 (50 percent) of the respondents would be considered small agricultural businesses.


Burden is minimized by the fact that all applicants must apply via the Grants.gov website.  Providing for electronic submission of grant applications simplifies and lessens the burden on applicant’s resources because they will not need to duplicate and submit paper applications. 


  1. DESCRIBE THE CONSEQUENCE OF FEDERAL PROGRAM OR POLICY ACTIVITIES IF THE COLLECTION IS NOT CONDUCTED OR IS CONDUCTED LESS FREQUENTLY, AS WELL AS ANY TECHNICAL OR LEGAL OBSTACLES TO REDUCING BURDEN.


The Local Food Promotion Program’s purpose is to provide grants to eligible entities. Without the required information, AMS will not be able to review, award, reimburse, or monitor grants to eligible applicants.


  1. EXPLAIN ANY SPECIAL CIRCUMSTANCES THAT WOULD CAUSE AN INFORMATION COLLECTION TO BE CONDUCTED IN A MANNER:


  • REQUIRING RESPONDENTS TO REPORT INFORMATION TO THE AGENCY MORE OFTEN THAN QUARTERLY;


Respondents are not required to report information to AMS more often than quarterly. Respondents are required to report application information once. Awardees are required to provide an Interim Performance Report at the mid-point of the grant agreement period, a Final Performance Report within 90 days after the ending date of the grant agreement, and a Federal Financial Report with each payment request in accordance with AMS requirements, which are in accordance with regulations.


  • REQUIRING RESPONDENTS TO PREPARE A WRITTEN RESPONSE TO A COLLECTION OF INFORMATION IN FEWER THAN 30 DAYS AFTER RECEIPT OF IT;


There are no plans to require applicants to prepare a written response to a collection of information in fewer than 30 days after AMS receives it. During the application review process if an email address has been provided by the applicant, AMS will email a notification of receipt of their application. Reporting requirements for the project (performance) implementation and financial (funds usage and cash on hand) status are submitted; no follow-up is required by the awardee unless AMS requires additional clarification.


  • REQUIRING RESPONDENTS TO SUBMIT MORE THAN AN ORIGINAL AND TWO COPIES OF ANY DOCUMENT;


Respondents are not required to submit more than an original Grants.gov application documents. Only one electronic emailed copy of the performance and financial reports are required.


  • REQUIRING RESPONDENTS TO RETAIN RECORDS, OTHER THAN HEALTH, MEDICAL, GOVERNMENT CONTRACT, GRANT-IN-AID, OR TAX RECORDS FOR MORE THAN 3 YEARS;


Respondents are not required to retain any records for more than 3 years.


  • 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;


The information collected will not be utilized in connection with a statistical survey.


  • REQUIRING THE USE OF A STATISTICAL DATA CLASSIFICATION THAT HAS NOT BEEN REVIEWED AND APPROVED BY OMB;


There is no requirement for a statistical data classification.


  • THAT INCLUDES A PLEDGE OF CONFIDENTIALITY THAT IS NOT SUPPORTED BY AUTHORITY ESTABLISHED IN STATUE 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; OR


No confidential information is collected.


  • 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.


Respondents are not required to submit proprietary trade secrets or other confidential information.


  1. IF APPLICABLE, PROVIDE A COPY AND IDENTIFY THE DATE AND PAGE NUMBER OF PUBLICATION IN THE FEDERAL REGISTER OF THE AGENCY’S NOTICE, REQUIRED BY 5 CFR 1320.8(d), 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.


On March 20, 2014, AMS published in the Federal Register a Notice of Emergency Approval of New Information Collection for Local Food Promotion Program (page 15560). On March 28, 2014, the emergency request for approval was granted through an OMB Notice of Action, and was assigned the OMB No. 0581-0287.


One comment was received, essentially suggesting that tax payer dollars should not be spent on farmers markets because products sold at the markets are more expensive than those sold at larger grocery store chains. The individual suggested that the money be used instead to pay off debt and reduce Federal taxes. By posting this Notice in the Federal Register, AMS was announcing and inviting comments only on the information collection and associated burden for the FMLFPP. The agency is not inviting comments on the legality/use of Federal dollars for farmers markets. The Agriculture Act of 2014 (P.L. 113-79) (2014 Farm Bill) has already been authorized by Congress and therefore AMS has no authority to determine how taxpayer dollars are spent. AMS will carry out the regulation and grant funding as planned.

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.


Representatives from different food systems stakeholders groups (e.g., producer groups, distributors, buyers, service providers) have been consulted on the new Local Food Promotion component of the Farmers’ Market and Local Food Promotion Program (FMLFPP) to identify and understand challenges and concerns of starting or expanding local and regional food business enterprises. Also, once the LFPP grant program is established, AMS will solicit comments from awardees and peer reviewers to ensure that form instructions are clear and concise, and that forms can be easily accessed and used without difficulty.


CONSULTATION WITH REPRESENTATIVES OF THOSE FROM WHOM INFORMATION IS TO BE OBTAINED OR THOSE WHO MUST COMPILE RECORDS SHOULD OCCUR AT LEAST ONCE EVERY 3 YEARS – EVEN IF THE COLLECTION OF INFORMATION ACTIVITY IS THE SAME AS IN PRIOR PERIODS. THERE MAY BE CIRCUMSTANCES THAT MAY PRECLUDE CONSULTATION IN A SPECIFIC SITUATION. THESE CIRCUMSTANCES SHOULD BE EXPLAINED.


Given that this program will be established for the first time, points of contact have not been established yet to provide input on the forms to be used by the LFPP grant program. That said, the forms that will be used by LFPP are similar in content and format to the forms used by the FMPP grant program, and with similar burden hours. FMPP forms were developed and revised based on consultation with stakeholders at grant writing conferences and workshops, industry meetings, peer reviewer meetings, and other program outreach activities associated with administering the agency’s farmers market program.


  1. EXPLAIN ANY DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS, OTHER THAN REMUNERATION OF CONTRACTORS OR GRANTEES.


No payments or gifts are provided to respondents, other than remuneration of grantees.


  1. DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO RESPONDENTS AND THE BASIS FOR THE ASSURANCE IN STATUTE, REGULATION, OR AGENCY POLICY.


The Local Food Promotion Program does not request confidential information from respondents and therefore provides no assurances related to confidentiality.


  1. PROVIDE ADDITIONAL JUSTIFICATION FOR ANY QUESTIONS OF A SENSITIVE NATURE, SUCH AS SEXUAL BEHAVIOR AND ATTITUDES, RELIGIOUS BELIEFS, AND OTHER MATTERS THAT 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.


Questions of a sensitive nature are not found in this information collection.


  1. PROVIDE ESTIMATES OF THE HOUR BURDEN OF THE COLLECTION OF INFORMATION.


THE STATEMENT SHOULD:

  • 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 DESIRABLE. IF THE HOUR BURDEN ON RESPONDENTS IS EXPECTED TO VARY WIDELY BECAUSE OF DIFFERENCE 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.



  • 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.


See attached AMS-71, Summary of Information Collection.


  • PROVIDE ESTIMATES OF ANNUALIZED COST TO RESPONDENTS FOR THE HOUR BURDENS FOR COLLECTIONS OF INFORMATION, IDENTIFYING AND USING APPROPRIATE WAGE RATE CATEGORIES.

The 1,500 respondents’ estimated annual cost in providing information to LFPP is $781,270. This total has been estimated by multiplying 34,987.50 total burden hours (see AMS-71) by $22.33, which is the mean hourly wage for all occupations (cross industry, private, state, and local employees – occupation code 00-0000). This mean hourly wage was obtained from the U.S. Department of Labor’s Bureau of Labor Statistics’ publication, “May 2013 National Occupational Employment and Wage Estimates, United States,” which can be found at the following website: http://www.bls.gov/oes/current/oes_nat.htm


  1. PROVIDE AN ESTIMATE OF THE TOTAL ANNUAL COST BURDEN TO RESPONDENTS OR RECORD-KEEPERS RESULTING FROM THE

COLLECTION OF INFORMATION. (DO NOT INCLUDE THE COST OF

ANY HOUR BURDEN SHOWN IN ITEMS 12 AND 14).


  • THE COST ESTIMATE SHOULD BE SPLIT INTO TWO COMPONENTS: (a) A TOTAL CAPITAL AND START-UP-COST COMPONENT (ANNUALIZED OVER ITS EXPECTED USEFUL LIFE); AND (b) A TOTAL OPERATION AND MAINTENANCE AND PURCHASE OF SERVICES COMPONENT. THE ESTIMATES SHOULD TAKE INTO ACCOUNT COSTS ASSOCIATED WITH GENERATING, MAINTAINING AND DISCLOSING OR PROVIDING THE 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. CAPITAL AND START-UP COSTS INCLUDE, AMONG OTHER ITEMS, PREPARATIONS FOR COLLECTING INFORMATION SUCH AS PURCHASING COMPUTERS AND SOFTWARE, MONITORING, SAMPLING, DRILLING AND TESTING EQUIPMENT; AND RECORD STORAGE FACILITIES.


  • IF COST ESTIMATES ARE EXPECTED TO VARY WIDELY, AGENCIES SHOULD PRESENT RANGES OF COST BURDENS AND EXPLAIN THE REASONS FOR THE VARIANCE. THE COST OF PURCHASING OR CONTRACTING OUT INFORMATION COLLECTION SERVICES SHOULD BE A PART OF THIS COST BURDEN ESTIMATE. IN DEVELOPING COST BURDEN ESTIMATES, AGENCIES MAY CONSULT WITH A SAMPLE OF RESPONDENTS (FEWER THAN 10), UTILIZE THE 60-DAY PRE-OMB SUBMISSION PUBLIC COMMENT PROCESS AND USE EXISTING ECONOMIC OR REGULATORY IMPACT ANALYSIS ASSOCIATED WITH THE RULEMAKING CONTAINING THE INFORMATION COLLECTION, AS APPROPRIATE.


  • GENERALLY, ESTIMATES SHOULD NOT INCLUDE PURCHASES OF EQUIPMENT OR SERVICE, OR PORTIONS THEREOF, MADE: (1) PRIOR TO OCTOBER 1, 1995, (2) TO ACHIEVE REGULATORY COMPLIANCE WITH REQUIREMENTS NOT ASSOCIATED WITH THE INFORMATION COLLECTION, (3) FOR REASONS OTHER THAN TO PROVIDE INFORMATION OR KEEPING RECORDS FOR THE GOVERNMENT, OR (4) AS PART OF CUSTOMARY AND USUAL BUSINESS OR PRIVATE PRACTICES.


There are no capital/start-up or ongoing operation/maintenance costs associated with this information collection.


  1. 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, OPERATION EXPENSES (SUCH AS EQUIPMENT, OVERHEAD, PRINTING, AND SUPPORT STAFF), AND ANY OTHER EXPENSE THAT WOULD NOT HAVE BEEN INCURRED WITHOUT THIS COLLECTION OF INFORMATION. AGENCIES ALSO MAY AGGREGATE COST ESTIMATES FROM ITEMS 12, 13, AND 14 IN A SINGLE TABLE.


There are no additional costs associated with this information collection.  The Federal government’s estimated annual cost for providing oversight and assistance for this information collection is estimated at $406,513.  A breakdown of the annual oversight costs is the following:


Salaries/Benefits/FERS Contributions/Awards                  $351,835

Travel                                                                                      $6,000

Contracts/Services/Training                                                    $6,635

Printing/Copying/Mailing/Postage                                          $4,275

Rent/Communication/Utilities/FTS                                         $3,268

OGC (Legal Services)                                                            $25,000

Supplies/Equipment                                                                 $9,500

TOTAL                                                                      $406,513         



  1. EXPLAIN ANY PROGRAM CHANGES OR ADJUSTMENTS REPORTED IN ITEMS 13 OR 14 OF THE OMB FORM 83-I.


Since the previous emergency information collection, we have increased the burden hours for both the Reviewer Qualification Form and the Review Conflict of Interest form. The forms will be used by both the Local Food Promotion Program and Farmers Market Promotion Program. Therefore, the number has doubled from 75 respondents in the emergency collection package to now 150 respondents in the current information collection. (Refer to the AMS-71.) Also, the overall decrease between the emergency collection and this information collection of -14,212 burden hours is due to recalculating the hours respondents spend on SAM.gov from 8 hours to 1 hour.


  1. 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.


The collected information will not be published.


  1. IF SEEKING APPROVAL TO NOT DISPLAY THE EXPIRATION DATE FOR OMB APPROVAL OF THE INFORMATION COLLECTION, EXPLAIN THE REASONS THAT DISPLAY WOULD BE INAPPROPRIATE.


The standard forms currently contain an OMB number and an expiration date.


  1. EXPLAIN EACH EXCEPTION TO THE CERTIFICATION STATEMENT IDENTIFIED IN ITEM 19, “CERTIFICATION FOR PAPERWORK REDUCTION ACT SUBMISSIONS,” OF OMB FORM 83-I.


The agency is able to certify compliance with all provisions under Item 19 of OMB Form 83-I.


  1. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS.


This information collection does not employ statistical methods.


File Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File TitleSUPPORTING STATEMENT
AuthorJohn Lund
File Modified0000-00-00
File Created2021-01-27

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