Justification for Nonsubstantive Change

HPCA APPLICATION FORMS AND INSTRUCTIONS

Changes to the application form and instructions are minor and will not increase the public reporting burden.

We are not requesting any new information on the application form, except that we have revised the attestation above the applicant's signature on all parts of the form to include check boxes to clarify whether the signatory is the "owner" of the subject property as defined by program regulations and, if so, if the owner is the fee simple owner. The program regulations require that an applicant who is not the fee simple owner submit a statement from the actual fee simple owner that such entity is aware of the filing of the application and has no objections. This change to the application form eliminates the need to request this information separately from the applicant. 

The only other changes to the form involve simplifying the instruction language at the top of the form (Part 1, 2 and 3 applications) and modifying the language of one of the check boxes under the "NPS Official Use Only" section at the bottom of the Part 1 application. On the Amendment form, some additional wording to the instructions at the top of the form has been added for greater clarity and two additional check boxes have been added to Section 2 to make the form easier for the applicant to use.     

Almost all of the changes to the instructions involve additional explanation, simplified wording, expanded explanation of terminology, repeating wording in a few places for added emphasis, or reordering or moving information to a different part of the instructions. Additional information regarding ownership requirements and the ownership statement has been added related to the attestation boxes added to the application form; and for the two additional check boxes on the Amendment form.