Narrative of Changes

Narrative of Changes

The purpose of the Narrative of Changes is to clearly indicate changes to a collection since the previous approval.

Collection Title: FEMA Preparedness Grants: Port Security Grant Program (PSGP)

OMB Control No.: 1660-0114

Current Expiration Date: 1/31/2017

Collection Instruments: FEMA Form 089-5

There has been changes to the collection form:

FEMA Form 089-5 changed in format to reflect required content outlined in form instructions. The form was outdated containing lengthy, confusing instructions to a concise, easy to follow template that includes pre-selected answers such as drop-down boxes. See the Forms Revision Chart for FEMA Form 089-5 uploaded in ROCIS for the recent changes.

The following are the changes to the collection:

Supporting Statement:

Question 8a – Updated to reflect FRN publication information.

Question 10 – Updated to reflect current privacy information.

Question 12 – Updated to reflect the decrease in burden hours and updated the current wage rate. See table below.

Question 14 – Costs to the Federal Government updated.

State Table

Table A.12: 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 Government	PSGP Investment Justification / FEMA Form 089-5	84	2	224	15 hrs.	2,520	$58.90	$148,428.00
State Government	PSGP - Memorandum of Understanding (MOU) or Memorandum of Agreement (MOA)	4	1	4	2 hrs.	8	$58.90	$471.20
Total		88		228		2,528		$148,899.20

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

Local Table

Table A.12: 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
Local or Tribal Government	PSGP Investment Justification / FEMA Form 089-5	346	2	692	15 hrs.	10,380	$61.02	$633,388
Local or Tribal Government	PSGP - Memorandum of Understanding (MOU) or Memorandum of Agreement (MOA)	17	1	17	2 hrs.	34	$61.02	$2,075
Total		363		709		10,414		$635,463

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

Business or other for-profit Table

Table A.12: 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
Business or other for-profit	PSGP Investment Justification / FEMA Form 089-5	140	2	280	15 hrs.	4,200	$73.54	$308,868
Business or other for-profit	PSGP - Memorandum of Understanding (MOU) or Memorandum of Agreement (MOA)	6	1	6	2 hrs.	12	$73.54	$882.48
Total		146		286		4,212		$309,750.48
Grand Total		597		1,223		17,154		$1,094,112.60

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

Question 15 – See explanation below.

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
PSGP Investment Justification/ FEMA Form 089-5				17,360	17,154	-206
PSGP - Memorandum of Understanding (MOU) or Memorandum of Agreement (MOA)				54	54	0
Total(s)				17,414	17,154	-206

Explain:

There has been a decrease from the previous submission in the annual burden hours in this collection due to the revision of the PSGP Investment Justification and removal of SF-269 (replaced by SF-425). FEMA Form 089-5 has changed in format to reflect required content outlined in form instructions.

The burden and cost have increased due to an increased number of applicants and a more accurate account of form submission requirements since the last OMB review. The burden hours remain largely the same per applicant, however this update reflects a greater number of applicants (597). Additionally the forms required at the time of application are required of all applicants while the reporting forms are required only by grant recipients (296) during reporting. Additionally, of the grant recipients some forms are only required for certain types of projects (e.g. SF-424C for construction projects). The aggregate result of demonstrating those forms also required by applicants (not just grant recipients) greatly increases the number of burden hours and cost previously reported for most Standard Forms (SF), such as the SF-424 which is required by all applicants. Additionally, overall costs were impacted by increased wage rates.