Supporting Statement 1660-0070 11162015

January 24, 2021

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660 - 0070

Title: National Fire Department Census

Form Number(s): FEMA Form 070-0-0-1

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.

Public Law 93-498 provides for the gathering and analyzing of data as deemed useful and applicable for fire departments. The National Fire Department Census evolved from recommendations of the Blue Ribbon Panel. In the spring of 1998, the Director of the Federal Emergency Management Agency (FEMA) convened a Blue Ribbon Panel of prominent members of the U.S. fire service to review the structure, mission, and purpose of the U.S. Fire Administration (USFA) and to make recommendations for the future of the Federal fire focus. The Blue Ribbon Panel noted the lack of a comprehensive list of fire departments and baseline data for the definition of the composition, capabilities, and activities of the nation's fire service. Their recommendation was for the USFA to develop a fire department census.

The action report requests the following: “Develop a fire service census that captures demographic information that will help clarify the perception issue and establish baselines and benchmarks for USFA activities, and identify and maintain the demographics of fire departments in the United States by conducting a fire services census.”

USFA receives many requests from fire service organizations and the public for information related to fire departments, including total number of departments, number of stations per department, population protected, and number of firefighters. Additionally, USFA maintains the census for the purpose of disseminating fire safety and prevention information to fire departments across the country.

2. Indicate how, by whom, and for what purpose the information is to be used. Except for a new collection, indicate the actual use the agency has made of the information received from the current collection. Provide a detailed description of: how the information will be shared, if applicable, and for what programmatic purpose.

The USFA is working to identify all fire departments in the United States to develop a database that includes information related to their demographics, capabilities, and activities. The database is used by the USFA to guide programmatic decisions and to provide the Fire Service and the public with information about fire departments. Additionally, USFA maintains the census database for disseminating critical fire safety and prevention information to departments. The Critical Infrastructure Protection (CIP) program uses the census for the purpose of distributing sensitive information to senior fire and EMS personnel.

A fire department database was developed and populated with the responses and made available to the public for online look-ups through the USFA Web site. The database contains fields included on the census form instrument with the exception of the name and contact information of the individual completing the form and the specialized services fields. Information collected to date (27,150 departments) is being used as described. The data are updated typically every five years based on current experience. Updates can be executed at any time online through the USFA Web site, or can be mailed, e-mailed or faxed via the paper-version questionnaire.

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.

Fire department personnel are able to complete the census form online through the USFA Web site: http://www.usfa.dhs.gov/applications/census/. Fire department personnel can also complete the paper census form and fax, mail, or e-mail the completed form. Instructions for completing the form are provided online or included in the cover letter accompanying the paper form. For the initial responses, about 85 percent of the completed forms are submitted online. For periodic data updates, about 95-100 percent of the updates are submitted online.

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. 

A nationwide search for existing databases was conducted, and it was determined that existing databases were either well short of the estimated 30,000 fire departments (based on the National Fire Protection Association annual average estimate of fire departments), or they did not have the demographic information necessary for future sample surveys, which are not part of this effort. Existing mailing lists are combined and geocoded to avoid duplicate mailings in an effort to identify every fire department possible.

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.

By not conducting the fire department census, the Agency’s ability to conduct future fire loss surveys will be severely limited. The ability to assess current needs of the fire service based on services currently provided will also be limited. Additionally, without this collection of information, it would severely limit USFA’s ability to provide critical information to senior fire and EMS personnel.

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.

2. 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.

2. Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years.

2. 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.

2. Requiring the use of a statistical data classification that has not been reviewed and approved by OMB.

2. 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.

2. 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 [May 6, 2015, 80 FR 26071]. [No comments were received].

A 30-day Federal Register Notice inviting public comments was published on [July 27, 2015, 80 FR 44370]. No comments were received].

 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.

Several organizations were contacted to identify the type of information they collect about fire departments nationwide. These organizations were asked if they collected similar information and were also asked about the numbers of fire departments included in their databases. Organizations contacted included the National Fire Protection Association (NFPA), Insurance Services Office (ISO), State Fire Marshal’s Offices, as well as several commercial vendors that maintain fire department mailing lists.

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.

Consultation with fire department personnel from whom information is obtained is continuous. The census Web page includes a feedback form in which respondents can provide comments regarding the forms and clarity of instructions (https://apps.usfa.fema.gov/feedback/census.jsp). The majority of the comments received from respondents involve questions about how to obtain their FDID number. Information regarding how to obtain FDID numbers is included on the Register Online page and the census update letter.

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

FEMA does not provide payments or gifts to respondents in exchange for a benefit sought.

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

A Privacy Threshold Analysis (PTA) was submitted to the FEMA Privacy Office on 02/02/2015. The status is under review as of February 2015.

A Privacy Threshold Analysis (PTA) was approved on (insert date). A PIA for this collection (select: was or was not) determined to be needed and has been forwarded to the FEMA Privacy Office for review. 

The information will be kept private or anonymous to the extent allowable by law. There is no assurance of confidentiality provided to the respondents for the collection of this information.

11. Provide additional justification for any question of a sensitive nature (such as sexual behavior and attitudes, religious beliefs and other matters that are commonly considered private). This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

There are no questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The statement should:

 a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated 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.

The majority of the responses are from volunteer fire departments. In 2013, the NFPA estimated that about 85.2 percent of fire departments were volunteer departments and the remaining 14.8 percent of fire departments were considered career (or paid) departments.

It is anticipated that 2,850 fire departments (i.e., 2,850 x .148 = 422 career departments and 2,850 x .852 = 2,428 volunteer departments) will complete the initial National Fire Department Census registration using FEMA Form 070-0-0-1. Personnel from each fire department will complete the form once and each response will require .4167 hours (i.e., 25 minutes) to complete the form. The average burden per response of 25 minutes applies to both the completion of the paper form and the online form. The total annual hour burden for initial responses is 2,850 x .4167 = 1,188 hours.

Approximately 20 percent (5,430 departments) of the current census registrants are contacted by USFA on a rotating basis each year. Fire department personnel are asked to update the census record for the department. This results in each fire department being contacted by USFA about once every five years to supply census data updates. This ensures that USFA has the most up to date information as possible regarding the registered departments. With the establishment of the online census database, however, fire departments may provide USFA with data updates at any time.

Additionally, it is anticipated that 5,430 fire departments (i.e., 5,430 x .148 = 804 career departments and 5,430 x .852 = 4,626 volunteer departments) will provide updates to their current data each year. For the updates, fire departments do not need to re-complete the entire form since the data already exist online. The departments access the data online and then only need to change those items that need to be updated. Each updated response will require .1667 hours (i.e., 10 minutes). The total annual hour burden for the updated responses is 5,430 x .1667 hours = 905 hours.

The total annual hour burden for the initial responses and updated responses is 1,188 hours + 905 hours = 2,093 hours.

 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.

This request for approval does not cover more than one form.

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 Respondents	No. of Responses per Respondent	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 (Career)	National Fire Department Census/ FEMA Form 070-0-0-1	422	1	422	.4167	176	32.49	$5,718
State, Local, or Tribal (Volunteer)	National Fire Department Census / FEMA Form 070-0-0-	2,428	1	2,428	0.4167	1,012	0.00	$0
State, Local, or Tribal (Career)	National Fire Department Census / FEMA Form (Update)	804	1	804	.1667	134	32.49	$4,354
State, Local, or Tribal (Volunteer)	National Fire Department Census / FEMA Form (Update)	4,626	1	4,626	.1667	771	0.00	$0
Total		8,280		8,280		2,093		$10,072

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

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

Instruction for Wage-rate category multiplier: Take each non-loaded “Avg. Hourly Wage Rate” from the BLS website table and multiply that number by 1.4. For example, a non-loaded BLS table wage rate of $42.51 would be multiplied by 1.4, and the entry for the “Avg. Hourly Wage Rate” would be $59.51.

As previously noted in 12a, the majority of the responses will be from volunteer fire departments for which no direct labor costs will be incurred. Volunteer firefighters receive no compensation for their services. The minimal direct labor cost of a single firefighter or emergency service worker completing the census form only applies to those fire departments and emergency service agencies with career (or paid) firefighters. In 2013, the NFPA estimated that about 14.8 percent of fire departments were considered to be career departments.

According to the May 2013 National Occupational Employment and Wage Estimates, U.S. Department of Labor, Bureau of Labor Statistics (www.bls.gov), the wage rate category for firefighters is estimated to be on average, $23.21 (national mean hourly wage rate) x 1.4 (wage rate multiplier) = $32.49 per hour, therefore, the estimated burden hour cost to career State, Local, or Tribal firefighter respondents is estimated to be (422 x .4167 hours) = 176 hours x $32.49= $5,718 annually.

For the updates, fire departments do not need to re-complete the entire form. The data already exist online. The departments access the data online and then only need to change those items that need to be updated. Thus, the estimated burden hour cost to career State, Local, or Tribal firefighter respondents to provide census data updates is estimated to be (804 x .1667 hours) = 134 hours x $32.49= $4,354 annually.

Therefore, the total estimated burden hour cost to respondents (career firefighters) is estimated to be $5,718 + $4,354 = $10,072 annually.

13. Provide an estimate of the total annual cost burden to respondents or record-keepers resulting from the collection of information. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. (Do not include the cost of any hour burden shown in Items 12 and 14.)

There are no record keeping, capital, start-up, or maintenance costs associated with this information collection.

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.

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.

* Note: The “Salary Rate” includes a 1.4 multiplier to reflect a fully-loaded wage rate.

Contract costs include a contractor to redevelop and modify software ($11,000). The cost for staff salaries is $74,445 which includes one Federal employee at a GS-7, step 10 level (85 percent of the employee’s time is spent on the census project) to maintain the database and process paper forms and one employee at a GS-13, step 8 level (5 percent of the employee’s time is spent on the census project) to monitor database maintenance. Additional costs include printing and postage totaling $3,421. The total annual cost burden to the Federal Government is $88,866.

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 an 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.

Explain: There is a decrease of 249 burden hours from the current OMB inventory of 2,342. This difference is a negative adjustment as fewer fire departments are needed to complete the remaining census database. Since the National Fire Department Census is a one-time initial registration and this is a continuing collection, fewer fire departments (respondents) are needed to meet the objective of this collection which is to incorporate into the database all 30,000 fire departments nationwide. With the previous collection effort, about 91 percent of the desired respondents are already registered. The primary continued use of this form is to collect information from the remaining estimated 2,850 fire departments. Follow-up information is also provided from approximately 20 percent of previously registered departments each year on a rotating basis over a five-year period.

Additionally, there are no changes to the information being collected.

Explain: Based on the response to question 13, there is no annual cost burden to respondents. There are no record keeping, capital, start-up, or maintenance costs associated with this information collection. 

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

FEMA does not intend to employ the use of statistics or the publication, thereof, for this information collection.

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

FEMA will display the expiration date for OMB approval for this information collection.

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

FEMA does not intend to employ the use of statistics or the publication, thereof, for this information collection.

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