Supporting Statement PART A NFIRS_1600-0069 02242016

09/30/2014

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660 - 0069

Title: National Fire Incident Reporting System (NFIRS) v5.0

Form Number(s): National Fire Incident Reporting System (NFIRS) v5.0

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 National Commission on Fire Prevention and Control conducted a comprehensive study of the Nation’s fire problem and recommended to Congress actions to mitigate the fire problem, reduce loss of life and property, and educate the public on fire protection and prevention. As a result of the study, Congress enacted Public Law 93-498, Federal Fire Prevention and Control Act of 1974, (hereinafter referred to as “the Act”) which establishes the U.S. Fire Administration to administer fire prevention and control programs, supplement existing programs of research, training, and education, and encourage new and improved programs and activities by State and local governments.

Section 9(a) of the Act authorizes the Administrator, U.S. Fire Administration (USFA), to operate directly or through contracts or grants, an integrated, comprehensive (method) to select, analyze, publish, and disseminate information related to prevention, occurrence, control, and results of fires of all types. The Act stipulates that a program be designed to (1) provide an accurate nationwide analysis of the fire problem, (2) identify major problem areas, (3) assist in setting priorities, (4) determine possible solutions to problems, and (5) monitor the progress of programs to reduce fire losses. The National Fire Incident Reporting System (NFIRS) was designed as the vehicle to gather and analyze the kind of information needed to administer the program, such as:

1. information on the frequency, causes, spread, and extinguishment of fires;

2. information on the number of injuries and deaths resulting from fires including the maximum available information on the specific causes and nature of such injuries and deaths, and information on property losses;

3. information on the occupational hazards faced by firefighters, including the causes of deaths and injuries arising directly and indirectly, from firefighting activities;

4. information on all types of firefighting activities including inspection practices;

5. technical information related to building construction, fire properties of materials, and similar information;

6. information on fire prevention and control laws, systems, methods, techniques, and administrative structures used in foreign nations;

7. information on the causes, behavior, and best method of control of other types of fire, including, but not limited to, forest fires, brush fires, fires underground, oil blow-out fires, and water-borne fires; and

8. such other information and data as is deemed useful and applicable.

Section 9(b) of the Act also authorizes the Administrator, USFA, to

1. develop standardized data reporting methods;

2. encourage and assist State, local, and other agencies, public and private, in developing and reporting information and;

3. make full use of existing data gathering and analysis organizations, both public and private.

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.

NFIRS was established in 1975 by the USFA as a cooperative effort of local, State, and Federal authorities to improve uniformity in fire incident reporting and to ensure that data is useable for fire protection planning and management.

The program provides a mechanism using standardized reporting methods to collect and analyze fire incident data at the Federal, State, and local levels. Data analysis helps local fire departments and States to focus on current problems, predict future problems in their communities, and measure whether their programs are working. It also enables the USFA to identify common trends in collected data which may be applicable to fire problems on a national scale.

Although modified over the years, NFIRS Version 4.1 did not keep pace with the changing needs and responsibilities of the Nation’s fire service. In the mid-1990’s local-level users, represented primarily by the National Fire Information Council (NFIC), formally requested that NFIRS be fully revised to better reflect the modern fire service and include data collection on things such as emergency medical services, hazardous materials response, and resource (apparatus) and personnel tracking. Version 5.0 was developed to provide greater flexibility at the local and State levels including being easily coded for specialized local uses and studies.

The USFA uses data from NFIRS to produce a wide variety of reports. In addition to FEMA, State and local governments as well as other federal agencies use NFIRS data. Specifically, NFIRS data is used:

1. at the local level, for setting priorities, targeting resources, and designing fire prevention and education programs specifically suited to the real fire problems of a community or State;

2. at the State level, to justify State budgets and has helped in the passage of important fire and arson related bills;

3. at the national level, to provide feedback reports to States and local fire departments that enable them to better manage and plan for fire protection and prevention programs, to produce the USFA’s report “Fire in the United States,” other reports where possible or when required, to share useful consumer protection information with private concerns and other government agencies, and to perform special studies.

NFIRS participants report fire incident data using standardized terminology and forms which are described in the NFIRS Handbook. Use of the NFIRS forms ensures that fires, other incidents, and casualties are described in a similar manner, making the information more consistent and meaningful. The forms also make it easier to keypunch the information for computer processing.

Local fire departments collect data using web-based online NFIRS software; optional vendor provided software; or the Data Entry Browser Interface. This feature provides for a totally web based data entry tool eliminating the need to download and install client software on the user's computer. Each form is checked for completeness and accuracy. Some fire departments enter their data into a fire department computer and then send a tape of their data to the State office. Other fire departments send forms directly to the State office. On the State level, the data is rechecked for quality control and entered into a computer.

Summaries of communities’ fire reports are produced periodically for each participating fire department. NFIRS participants have the option of entering and printing data about incidents other than fires. An electronic version of all the fire data is sent quarterly to the USFA where it is then added to the national fire database.

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.

NFIRS reporting is automated (http://www.nfirs.fema.gov/index.shtm ). Since 1999 when v5.0 was initiated, electronic reporting was aggressively encouraged as it lessened burden hours and made the resultant information more usable by a variety of information technologies and applications such as Geographic Information Systems (GIS). New states’ participation quickly gained with this new version. Currently, all 50 states and the District of Columbia participate in NFIRS. Moreover, USFA implementation of the Data Entry Browser Interface (http://www.nfirs.fema.gov/NFIRSWebTools/welcome.do) further simplified reporting and lessened complexity, cost, and the burden of reporting for especially smaller departments which generally have fewer resources available. Screen shots for the Data Entry Browser Interface (DEBI) are not available given it is a tab-driven interface with many thousands of resultant screens. URL to the nfirs.fema.gov site and the DEBI have been inserted.

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 duplicated 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.

The absence of NFIRS data would have a negative impact on a wide range of federal activities related to the reduction of the loss of life and property due to fire. While the obvious agency dependent on NFIRS data for program planning and evaluation is the United States Fire Administration, NFIRS data are central to the work of the other Federal Agencies such as the Consumer Product Safety Commission (CPSC), the National Highway Traffic Safety Administration (NHTSA), the Centers for Disease Control (CDC), and the Department of Defense (DoD). Timely reporting at all levels is critical to the ability of these agencies to respond to the national fire problem in a timely and effective manner.

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.



 (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.



3. 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.

The special circumstances contained in item 7 of the supporting statement are not applicable to this information collection.

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 October 10, 2014, Volume 79 FR  64610.  See attached copy of the published notice included in this package. Eight comments were received (see below a summary of comments and USFA response). The comments generally provided positive and constructive feedback regarding the information collected by NFIRS. The cost and hour burden of NFIRS to end users was briefly addressed in two instances, one indicating the cost/burden listed in the notice seem accurate, the other suggested user interface options for lessening time needed to report incidents. All comments received were provided to the NFIRS program office for their consideration.  The U.S. Fire Administration does not generally make changes to the system based on comments of one individual or one organization. There are many stakeholder groups that use the National Fire Incident Reporting System (NFIRS) and we reach out to each one of these groups for input prior to making changes that could impact all users. Due to the complexity and cost of many of the suggestions, those items would have to be deferred until funds were available. Each one of the comments that addresses a specific change is being cataloged for use along with other suggestions we receive during the year and previous years for an upcoming summit with the major fire service organizations as well as other users of the data. We will be reviewing each suggestion for improving the system which will be accomplished as resources permit.

Comment Submitted by Roy Rice

Written comments were received on Docket ID FEMA-2014-0031, renewal of the National Fire Incident Reporting System collection. These concerns address the user interface experience and performance options for one of the several software systems used by fire departments to enter incident reports:

1. Provide easier access to summaries (esp. yearly totals) for incident reports.

USFA is currently testing a new data warehouse which will offer more variety and flexibility for output reports. Rollout of the new system will begin in 2016.

2. Stagger codes such as incident type, action taken, property use, etc. from most used to least used to speed search of appropriate code or alphabetize.

Many constituents are concerned that the process described above will cause users to default to the more common codes rather than a more appropriate choice. USFA is looking at other improvements to the data entry process that would limit choices of codes based on the type of incident in order to streamline the data entry process.

3. Automatically list choice of previously used codes for entries such as city, state & zip to facilitate entry.

There are many options for reporting to NFIRS which include using software or web-based access provided by USFA, or third party commercial vendor programs. The USFA cannot control the user interface used by third party vendors, only the format of the data file which is sent to USFA. We are constantly looking at ways of streamlining and improving the user interface of the USFA software and will examine the suggestion above.

Comment Submitted by Catherine Kimar

Written comments were received on Docket ID FEMA-2014-0031, renewal of the National Fire Incident Reporting System collection.  These concerns address the user interface experience and performance options for one of the several software systems used by fire departments to enter incident reports:

1. Supports the NFIRS but is not satisfied with their choice of software/system/user interface and other issues not stipulated in the comment submitted.

There are many options for reporting to NFIRS which include using software or web-based access provided by USFA, and over 100 third party commercial vendor programs. The USFA cannot control the user interface used by third party vendors, only the format of the data file which is sent to USFA. The USFA is constantly looking for ways to improve the user interface for the data entry methods we provide. Specific examples of user problems with user interface are always encouraged.

2. Supports increasing users and data reported.

Twenty-three thousand fire departments in the United States out of an estimated 30,000 report voluntarily to the NFIRS System. USFA staff participate in outreach programs by visiting with students at the National Fire Academy as well as fire service conferences each year to educate and encourage participation in NFIRS.

3. Supports a program update to expedite reporting of information.

The NFIRS reporting infrastructure is set up to operate in a real time fashion. Because of the voluntary nature of the program the USFA cannot compel fire departments to report data in real time. Some departments wait until the end of the month or the end of a calendar year before submitting incidents.

Comment Submitted by Edward Mann

Written comments were received on Docket ID FEMA-2014-0031, renewal of the National Fire Incident Reporting System collection.  This concern addresses a change in reporting requirements for one particular data element:

1. Requires a user who provided automatic-aid or mutual aid to record the FDID Number, the state and the incident number for the company who they provided automatic aid or mutual aid to.

2. Unsure why the requirement is in place and doesn’t see that particular element of information is useful.

3. Stresses that from a practical manner he believes the system will become loaded with inaccurate data.

The requirements described above are in place because users and data analysts wanted the ability to capture all of the resources that were used at an incident, not just the resources provided by the department whose jurisdiction is where the incident occurred. Users requested this information in order to have a better understanding of the size and complexity of the incident for after action analysis and planning purposes. Additionally departments giving aid are responsible for reporting their own department’s casualties in NFIRS. The only way to provide a link to the incident a fire service casualty occurs at is to provide the FDID Number, the state and the incident number for the company who they provided automatic aid or mutual aid to.

Comment Submitted by Les Whalen

Written comments were received on Docket ID FEMA-2014-0031, renewal of the National Fire Incident Reporting System collection.  This concern addresses first responder availability in the USA for especially EMS calls during the daytime:

1. Would like to be able to track if a department misses a dispatched run due to no responder availability.

2. Indicates that in his department the lack of responder availability usually occurs during a response for EMS assist during the daytime and assumes it is a problem elsewhere within the USA.

Comments have been added to the list of suggested changes for consideration by our constituent groups.

Comment Submitted by Kenneth LaSala, International Association of Fire Chiefs

Written comments were received on Docket ID FEMA-2014-0031, renewal of the National Fire Incident Reporting System collection.  This responder’s organization represents a broad membership of fire officers in the USA and around the World. These concerns address the time taken for fire departments to report to their respective states, the states to USFA, then to final release of the data for use; the desire for a fire chief in one area to easily review incident information for another fire department elsewhere in the USA; suggests combining the NFIRS system with the newer National EMS Information System (NEMSIS) and the National Fire Operations Reporting System (N-FORS); and the user interface experience and performance options for the software systems used by fire departments to enter incident reports, access data real time, and more easily create user defined customized output reports:

1. The premise of NFIRS is as valid today as when the idea was conceived in the 1970s. There is tremendous value in having good data at the federal policy level with the ability to identify trends. The IAFC continues to support NFIRS.

Agree

2. NFIRS is managed by the U.S. Fire Administration. The estimate for annual burden in hours and the estimated cost to a local fire department listed in this notice seem accurate.

Agree

3. Would like NFIRS to provide an effective mechanism for local agencies to access their data and manipulate it to obtain information and produce reports, monitor trends in their areas, and compare data in their jurisdictions with similar jurisdictions around the country.

USFA is currently testing a new data warehouse which will offer more variety and flexibility for output reports. Rollout of the new system will begin in 2016.

4. Would like some state programs to allow local fire departments to enter data directly from their fire departments into NFIRS.

This is currently allowed unless a state has a specific requirement which does not allow reporting directly to USFA servers.

5. Would like NFIRS to be more user friendly and data to be available automatically in real time across the country.

The NFIRS reporting infrastructure is set up to operate in a real time fashion. Because NFIRS is voluntary the USFA cannot compel fire departments to report in a real time fashion. Specific examples of what the user feels is “user friendly” are always welcome.

6. NFIRS needs to update its data set, and forge links with other systems, such as the National Highway Traffic Safety Administration’s National EMS Information System (NEMSIS).

USFA always welcomes suggestions for updates to the system which we catalog for use when resources are available for system updates. Discussions were held with the operators of NEMSIS and it was learned that the data are rolled up in a summary fashion from the state to the Federal levels making it impossible to provide incident based links. Other methods are being explored.

7. The IAFC also believes that the U.S. Fire Administration immediately should begin to consolidate the National Fire Operations Reporting System (N-FORS) with NFIRS.

N-FORS is currently in beta testing and discussions with the developers are ongoing.

8. Overall, NFIRS plays an important role in the national fire and emergency response system. It is the only nationwide tool for collecting data about fire incidents, and provides a comprehensive data set for analysis.

Agree

9. The IAFC believes that the USFA can take concrete steps to preserve NFIRS’ current strengths, while transforming it into a better decision-making tool for local fire departments.

Agree

Comment Submitted by Michelle Mason Webber

Written comments were received on Docket ID FEMA-2014-0031, renewal of the National Fire Incident Reporting System collection. This concern addresses management tools for state NFIRS program managers and addition of a data element to better document training activities:

1. As new user of NFIRS, has found it to be simple in some respects (user manual is pretty straightforward), but difficult in others (gathering statistics beyond the NFIRS-provided report options).

NFIRS is a standard but some users require additional information beyond the standard. There is a special study feature available with USFA software and more robust methods for collection of additional data will be explored for future versions.

2. Suggest a specific data quality report to be available on the NFIRS report generation webpage.

USFA is currently testing a new data warehouse which will offer more variety and flexibility for output reports. Rollout of the new system will begin in 2016. The commenter was not specific about the type of data quality report but the data warehouse will contain a suite of data quality reports not previously available to participants.

3. Would like a new incident code in the Basic module that would allow fire departments to document training activities.

Comment has been added to the list of suggested changes for consideration by our constituent groups.

Comment Submitted by Cheryl Stephenson

Written comments were received on Docket ID FEMA-2014-0031, renewal of the National Fire Incident Reporting System collection. This concern addresses availability NFIRS training and suggests additional training options for local fire departments.

1. Has worked with NFIRS for six years and believes it to be extremely helpful in a variety of ways.

Agree

2. Indicates their only problem getting the suppression crew (responding firefighters) to better understand the need for reporting and to improve their performance in reporting of incidents.

USFA is currently working on a variety of methods for outreach to educate the fire service about the importance of reporting including NFIRSGrams (Short topical messages) and short video presentations.

3. Indicated much value in attending NFIRS training at the National Fire Academy in Maryland would “LOVE” to see local class options as an important tool for improving local reporting.

States have the option to select NFIRS classes for state deliveries.

Comment Submitted by Eric Ward

Written comments were received on Docket ID FEMA-2014-0031, renewal of the National Fire Incident Reporting System collection. This concern addresses suggestions for expanded required reporting; simplifying reporting; improving the USFA web page reporting interface:

1. States that NFIRS is a valuable tool but underutilized.

2. Suggests all agencies that deal with fires to report via NFIRS. Stipulates that currently most federal land management agencies report wildfires through other channels and not through NFIRS.

USFA works with federal wildland agencies and contributes NFIRS data where it is combined with wildland data for analysis and reporting.

3. Suggests simplifying of reporting while stating that “it's not that bad now, but every step to simplify will encourage a few more to report.”

Specific examples of what the user feels is “simplifying” are always welcome.

4. Suggests improvements for the USFA web page reporting interface in order to lessen the time it takes to report an incident.

Specific examples of what the user means by improvements to the web interface are always welcome.

  

A 30-day Federal Register Notice inviting public comments was published on February, 25, 2015, Volume 80 FR  10138.  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.

NFIRS Version 5.0

Numerous focus groups were consulted for the development of the NFIRS 5.0 system and forms. Participants included but were not limited to:

1. U.S. Census Bureau

2. Bureau of Standards

3. National Fire Protection Association

4. Consumer Product Safety Commission

5. State Fire Marshals

6. Local fire department officials

7. National Fire Information Council

8. U.S. Chemical Safety and Hazard Investigation Board

9. National Association of State Foresters

10. USDA Forest Service

11. Symposium on Medical Support for the Fire Service

12. National Wildland Coordinating Group

13. Bureau of Alcohol, Tobacco, and Firearms

n. National Highway Traffic Safety Commission

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.

Ongoing feedback regarding the information to be collected, the format for collection, and the supporting system is received from a wide range of end users, including the National Fire Information Council (NFIC) which is comprised of NFIRS Program Managers at the State and local level, via focus groups, work groups, general meetings, and the NFIRS Support Center (http://www.usfa.fema.gov/nfirs/support/).

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

There are no payments or gifts to respondents for this data collection.

10. Describe any assurance of confidentiality provided to respondents. Present the basis for the assurance in statute, regulation, or agency policy.

The information will be kept private or anonymous to the extent allowable by law. There is no assurance of confidentiality provided to the respondents. A PTA was approved on September 8^th, 2014 as part of the documentation for the NFIRS Authority to Operate (ATO) which was approved by the FEMA CIO and CISO.



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 required in this data collection.

 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.

NFIRS Version 5.0 Modules 1-12 (Electronic) - This is the electronic collection tool for reporting of fires which provides a mechanism using standardized reporting methods to collect and analyze fire incident and related data at the Federal, State, and local levels.  The average burden response is estimated to be .45 hours (27 minutes) and includes the time required to gather the information, read instructions and report the information.  There are 23,000 respondents who are fire departments, each reporting multiple incidents using their own staffing resources and operating protocols for doing so; fire officer, firefighter, office staff, and/or a combination of the above.

NFIRS Program Management Training – This is the resident six-day National Fire Academy (NFA) course for NFIRS program managers.  The average burden response is estimated to be 50 hours and includes the time required to attend classroom instruction at NFA.  There are 26 respondents who are fire officers, firefighters, office staff, and/or state and federal employees who act as NFIRS program managers for their individual organizational element (local, state, and federal).

NFIRS Program Management Orientation – This is a two-day introduction to NFIRS training course intended for field delivery and “State Weekend” instruction at NFA. The average burden response is estimated to be 16 hours and includes the time required to attend classroom instruction in order to complete the training.  There are 30 respondents who are fire officers, firefighters, office staff, and/or state and federal employees who act as NFIRS program managers for their individual organizational element (local, state, and federal).

NFIC Training Workshop – This is a two-day (NFA) resident workshop intended for state and metropolitan fire departments (i.e., departments protecting a population of 500,000 or more). NFIRS program managers to receive technical assistance and training through presentations and group discussion. The average burden response is estimated to be 16 hours for training session attendance. There are 100 respondents who are major metro and state/federal NFIRS program managers.

NFIRS CD/on-site Orientation – This is a CD-ROM based NFIRS Program Managers Tool-Kit. The average burden response is estimated to be 4 hours and includes relevant NFIRS information resources helpful to program managers as they manage fire reporting efforts for their organization. There are 200 respondents who are fire officers, firefighters, office staff, and/or state and federal employees who act as NFIRS program managers for their individual organizational element (local, state, and federal).

Introduction to NFIRS Distance Learning – This is an Internet-based NFIRS course providing an introduction and more in-depth learning opportunity regarding NFIRS for all personnel using any of the ten NFIRS modules. It is also a pre-requisite training for the six-day NFA resident NFIRS Program Management course. The average burden response is estimated to be 20 hours and includes the time required to read the instructions and complete the training.  There are 500 respondents who are fire officers, firefighters, office staff, and/or state and federal employees who use NFIRS or act as NFIRS program managers for their individual organizational element (local, state, and federal).

 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 ($)
State, Local, or Tribal Government	NFIRS Version 5.0 Modules 1-12 (Electronic)	23,000	1,303	29,969,000	27 min (0.45 hr)	13,486,050	$32.49	438,161,765
State, Local, or Tribal Government	NFIRS Program Management Training (Training)	26	1	26	50 hours	1,300	$32.49	42,237
State, Local, or Tribal Government	NFIRS Program Management Orientation (Training)	30	1	30	16 hours	480	$32.49	15,595
State, Local, or Tribal Government	NFIC Training  Workshop  (Training)	100	1	100	16 hours	1,600	$32.49	51,984
State, Local, or Tribal Government	NFIRS CD/on-site Orientation (Training)	200	1	200	4 hours	800	$32.49	25,992
State, Local, or Tribal Government	Introduction to NFIRS Distance Learning (Training)	500	1	500	20 hours	10,000	$32.49	324,900
Total		23,856		29,969,856		13,500,230		438,622,473

• Note: The “Avg. Hourly Wage Rate” for each respondent (firefighter @ $23.21) includes a 1.4 multiplier to reflect a fully-loaded wage rate ($32.49).

• “Type of Respondent” should be entered exactly as chosen in Question 3 of the OMB Form 83-I

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for a firefighter is estimated to be $32.49 per hour including the wage rate multiplier, therefore, the estimated burden hour cost to respondent fire departments (career and volunteer) is estimated to be $438,622,473 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:

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
NFIRS Version 5.0 Modules 1-12	$11,500,000	$2,415,000		$13,915,000
Total	$11,500,000	$2,415,000		$13,915,000

The total capital and start-up cost is based on the initial purchase of an average computer set-up estimated at $1,500 with a three-year life cycle resulting in the annual average cost of $500 per electronic system. As there are approximately 23,000 electronic systems supporting NFIRS 5.0, the total annualized start-up is estimated at $11,500,000. Using guidance from the FEMA Information Technology Services Directorate, the annual operation and maintenance is estimated at 7% of the purchase price; therefore O&M is estimated at $105 per electronic system per year (23,000 systems x $105/yr = $2,415,000 for Total Annual O&M.)

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 [NFIRS development and maintenance, NFIRS Help Center]	1,886,444
*Staff Salaries [3 GS 13 and 1 GS 14 employee spending approximately 100% of time annually] [(2 GS 13 Step 2 = $185,844) + (GS 13 Step 5 = $101,914 ) + (GS 14 Step 8 = $131,053)]	418,811
Facilities [cost for renting, overhead, etc. for data collection activity]
Computer Hardware and Software [cost of equipment annual lifecycle]	111,000
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	$2,416,255

* Note: The “Salary Rate” total 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 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
NFIRS Version 5.0 Modules 1-12 (Manual)				338,910	0	-338,910
NFIRS Version 5.0 Modules 1-12 (Electronic)				13,351,190	13,486,050	134,860
NFIRS Program Management Training (Training)				1,440	1,300	-140
NFIRS Program Management Orientation (Training)				960	480	-480
NFIC Training  Workshop  (Training)				1,600	1,600	0
NFIRS CD/on-site Orientation (Training)				800	800	0
Introduction to NFRIS Distance Learning (Training)			13,500,230	10,000	10,000	0
Total(s)				13,704,900	13,500,230	-204,670

Explain: The annual burden hours has decreased by 204,670 hours from the previous inventory due to discontinuation of use of NFIRS paper forms and a small decrease in the number of students receiving the NFIRS Program Management Training and Orientation.

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
NFIRS Version 5.0 Modules 1-12 (Electronic)				$13,775,850	$13,915,000	$139,150
Total(s)				$13,775,850	$13,915,000	$139,150

Explain: Per previous submission, costs reported come from question 13 of the supporting statement. Slight increase due to all NFIRS reporting now being electronic.



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.



The NFIRS is a voluntary system and is not based on a statistically selected sample. It is extensively used by local fire departments to track their incident responses and for data analysis to support fire department needs at the local level. NFIRS data alone are not used to generate national level estimates (no state or sub-state level estimates are derived). Instead, NFIRS data are scaled up to national estimates derived from the National Fire Protection Association’s (NFPA) annual Survey of Fire Departments for U.S. Fire Experience which are based on a stratified random sample. USFA uses the methodology outlined in “The National Estimates Approach to U.S. Fire Statistics” by Hall and Harwood: http://www.nfpa.org/assets/files/PDF/Research/Nationalestimates.pdf as a basis for determining fire estimates.

NFIRS data collection is an ongoing process. NFIRS Public Data Release (PDR) files are created for each calendar year of data collection. These files contain raw NFIRS data. These files are generally released late fall containing the previous calendar year’s data. USFA then releases residential building and nonresidential building fire loss estimates on an annual basis per the USFA Website. These estimates are based on the “National Estimates Methodology for Building Fires and Losses” - http://www.usfa.fema.gov/downloads/pdf/statistics/national_estimate_methodology.pdf. USFA publishes fire-related topical reports throughout the year based on the residential building and nonresidential building fire loss estimates.

In addition, the report “USFA Response to the OMB 2013 NFIRS Terms of Clearance - A System Review and Assessment of Data Quality” was prepared for this submission to assess and document the quality of the information from the National Fire Incident Reporting System (NFIRS) and the National Fire Protection Association (NFPA) and to make it more accessible and useable for NFIRS users. While the report successfully met the 2013 Terms of Clearance, it will now be modified for a more general fire department analyst audience and made available to users of the NFIRS data along with USFA’s “National Fire Incident Reporting System Version 5.0 Fire Data Analysis Guidelines and Issues” document already available at: https://www.usfa.fema.gov/downloads/pdf/nfirs/nfirs_data_analysis_guidelines_issues.pdf.

17. If seeking approval not to display the expiration date for OMB approval of the information collection, explain reasons that display would be inappropriate.

This collection does not seek approval to not display the expiration date for OMB approval.



18. Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

 This collection does not seek exception to “Certification for Paperwork Reduction Act Submissions”.

18