PLC Supporting Statement A ocio edits

Supporting Statement:
Public Lands Corps Participant Tracking Sheet

OMB Control Number 0596-New

This supporting statement provides additional information regarding the United States Department of Agriculture, Forest Service (FS) request for processing the proposed information collection, Public Lands Corps Participant Tracking Sheet. The numbered questions correspond to the order shown on the Office of Management and Budget (OMB) Form 83-1, Instructions for Completing OMB Form 83-I.

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.

The Public Lands Corps (PLC) is a work and education program involving the nation’s land management agencies, conservation and service corps, and environmental organizations that contribute to the rehabilitation, restoration, and repair of public lands resources and infrastructure. Public Lands Corps projects provide opportunities for community and national service, work experience, and training to young people who are unemployed or underemployed. Participants are students, recent graduates, and others with interest in natural and cultural resources careers. The law authorizing this program is 16 U.S.C. 1721-1726, Chapter 37—Public Lands Corps and Resource Assistants Program (Public Lands Corps Healthy Forests Restoration Act of 2005 [Pub. L. 109-154]) as amended in 1993, hereafter referred to as “the Act.”

PLC projects are conducted through partnerships with conservation corps and environmental organizations whose missions are to recruit and engage individuals interested in natural and cultural resources careers. Land Management Agencies codify agreements, partnerships or contracts with various government and non-government partner organizations, hereinafter referred to as Partners, to help recruit PLC participants and manage the pay and benefits, and other administrative requirements of the project including tracking hours, demographics, education, and performance outcomes of participants engaged on PLC projects.

Important objectives as defined in the Act designate that PLC projects:

• Offer meaningful, full-time, productive work or service experiences for either (1) team-based placement, consisting of participants between the ages of 16 and 30, inclusive, in a natural or cultural resource setting; or (2) individual placement consisting of individuals ages 17 and above.

• Provide participants with a combination of work experiences, basic and life skills, education, training, and support services; and

• Provide participants with the opportunity to develop citizenship values and skills through service to their community and the United States.

The PLC program is categorized into two types of opportunities for participants:

• After successful completion of a PLC project which includes 640 hours of work on a project that furthers the conservation, restoration, construction or rehabilitation of natural, cultural, historic, archaeological, recreational, or scenic resources, PLC members can acquire noncompetitive hiring eligibility for not more than two years from date of completion of their service (16 U.S.C. 1726).

• After successful completion of PLC Resource Assistants Program (PLC RAP) which includes 960 hours of rigorous, immersive work and learning experience that provides developmental and training opportunities for individuals interested in learning more about Forest Service careers, and allows for meaningful contribution to the agency’s mission and a minimum associate degree, PLC RAP members can acquire noncompetitive hiring eligibility for not more than two years from date of completion of their service (16 U.S.C. 1726).

PLC participants receive a certificate of eligibility confirming their status of two-year noncompetitive hiring eligibility upon completion of the PLC eligibility requirements identified above. The certificate of eligibility cannot be signed until it is confirmed and verified that the PLC participant had successfully completed all requirements.

This information collection request establishes policies and procedures for the implementation of the Public Lands Corps Participant Tracking Sheet (Attachment A) to ensure uniform collection of information regarding tracking and monitoring participant engagement in order to determine the completion of requirements for non-competitive hiring eligibility as defined in the Act.

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.

1. What information will be collected - reported or recorded? (If there are pieces of information that are especially burdensome in the collection, a specific explanation should be provided.)

The use of information collected by the Public Lands Corps Participant Tracking Sheet data, such as participant demographic information, and project information, will allow the Forest Service and other Federal Land Management Agencies, to monitor and track the effectiveness of Agency efforts to meet the intent of the Act, and engage under-represented populations in natural and cultural resource conservation, development and scientific research work, and education on public lands. The tracking form can be accessed and amended by the agency to add columns as needed. This information collection request will ensure that partners maintain a record of all Public Lands Corps agreements established with Federal Land Management Agencies, participant demographics and education, project information and work hours, project locations and dates, and status of noncompetitive eligibility certification.

Data collected through the Public Lands Corps Participant Tracking Sheet will allow the Forest Service and other Federal Land Management Agencies who sponsor Public Lands Corps

programs to support our collaborating Partners who manage eligible participants and their participation in PLC projects. In addition, this information collection will monitor and track the progress of participants enrolled in PLC programs and maintain a record of participant work hours, project locations and dates that PLC noncompetitive hiring status is conferred upon PLC participants.

A full list of the information collected for the Public Lands Corps Participant Tracking Sheet is outlined in Table 1. Information collected through the tracking sheet will monitor and track information related to participants enrolled in PLC projects.

Table 1. Information Collected

PUBLIC LANDS CORPS PARTICIPANT TRACKING SHEET
Item Collected	Use of information
Partner	Respondent will choose Partner from drop-down menu.
Submission Date	Identifies the date that the Partner completes and submits the tracking form.
Name, Title, Contact Information	Identifies the full name of the person(s) responsible for submitting the updated form to the FS or any other Federal Land Management Agency, as well as title and contact information.
Participant Information Tab
Last Name	PLC Participant legal last name.
First Name	PLC Participant legal first name.
Middle Initial	PLC Participant middle initial.
Permanent Residence ZIP code	PLC Participant Residence ZIP code as outlined in the Act.
Email Address	PLC Participant email address; participant contact information will permit Land Management Agencies to communicate with PLC participants about federal workforce, training and development opportunities.
Date of Birth	PLC Participant official date of birth; confirms that the participant meets the age eligibility requirements as outlined in the Act.
Gender	Identifies PLC Participant gender; participants can select: Male, Female, or Other identified gender. Monitors and tracks participant gender to track that Partners are recruiting diverse participants to meet inclusivity goals of underrepresented, unemployed and underemployed groups as outlined in the Act.
Ethnicity	Identifies PLC Participant ethnicity; Partners can select: Hispanic or Latino or Not Hispanic or Latino. Monitors and tracks participant ethnicity to track that Partners are recruiting diverse participants to meet inclusivity goals of underrepresented, unemployed and underemployed groups as outlined in the Act.
Race – 1, 2	Identifies PLC Participant Race; Partners can select: American Indian or Alaskan Native, Asian, Black or African American, White, Native Hawaiian, Other Pacific Islander. Monitors and tracks participant race to track that Partners are recruiting diverse participants to meet inclusivity goals of underrepresented, unemployed and underemployed groups as outlined in the Act.
Education Level Completed	Identifies PLC Participant student education level and graduate status; partners can select: Some High School; High School Diploma/GED; Some College; Associates Degree; BA/BS Degree; Graduate Degree. Monitors and tracks education completed to confirm that Partners are recruiting diverse participants to meet inclusivity goals of underrepresented, unemployed and underemployed groups as outlined in the Act. Also confirms that participants meet the education requirements for eligibility for some PLC projects as outlined in the Act.
College/University Name	Identifies the full name of the college or university if the participant has college experience as identified in the previous question. Monitors and tracks where participants attend higher education for potential targeted outreach for future PLC participants
Major	Identifies the college major of the PLC participant Monitors and tracks college majors of participants for potential targeted outreach for future PLC participants and that participants are have the background and eligibility for FS positions.
Military/Veteran Status	Identifies the military status of the PLC participant. Tracks that Partners are recruiting diverse participants to meet inclusivity goals of underrepresented, unemployed and underemployed groups as outlined in the Act.
Career Goals	Identifies career goals, shared by participant with the Partner, to help provide placement upon completion of the program.
Skills and Abilities	Identifies skill and abilities, shared by participant with the Partner, to help provide placement upon completion of the program.
Total Hours Worked	This confirms that the required number of hours have been completed to fulfill program requirements.
Full Name	This field auto-populates with the participant’s full name.
Project Information Tab
Partner Name	Allows for project and participants to be tracked by specific partners.
Agreement Number	Identifies the specific Agreement number that outlines the PLC.
Agreement Type	Identifies the specific Agreement type as designated by Grants and Agreements.
Deputy Area/Office	Identifies the specific Deputy area/office that oversees the PLC project; Partners can select: Business Operations, National Forest System, Office of Finance, Office of the Chief, Research & Development, State & Private Forestry.
FS Unit (Location)	Identifies the specific FS Unit and/or location of PLC project.
Start Date	Verifies the PLC participant start date; tracks when the participant started participation in the program.
End Date	Verifies the PLC participant end date; tracks when the participant completed participation in the program. Also confirms that the participants meets the eligibility requirements within the time frame as outlined in the Act.
Project Title	Identifies the particular project the participant is participating in.
FS Supervisor Last Name	FS Supervisor/Staff last name; identifies the Forest Service supervisor or staff representative responsible for managing the PLC participant’s work experience.
FS Supervisor First Name	FS Supervisor/Staff first name; identifies Forest Service supervisor or staff representative responsible for managing the PLC participant’s work experience.
FS Supervisor Email Address	Allows for communication with FS Supervisor.
Project Total Hours	Allows for tracking of total hours worked per project.
Narrative/Comments	Allows respondents to provide additional information, if desired.
Project Tracking Tab
First, Last Name	PLC Participant legal first and last name.
Remuneration	Identifies the type of remuneration a participant may receive.
Term of Service	Identifies the seasonal/academic calendar year of work.
Position Type	Identifies the role the participant had on the project.
Project Title	Identifies the particular project to which participants have contributed.
Project Description	Allows for a more detailed description of what the project entails.
Project Hours Worked	Tracks the hours the participant has worked on a particular project.
Certificate Status	Designates if the PLC participant has acquired the noncompetitive hiring authority certificate based on completing the eligibility requirements as outlined in the Act.
"Certificate Date of Completion"	Verifies the date that the certificate is signed.
Narrative/Comments	Allows respondents to provide additional information, if desired.

2. From whom will the information be collected? If there are different respondent categories (e.g., loan applicant versus a bank versus an appraiser), each should be described along with the type of collection activity that applies.

The Forest Service and other Federal Land Management agencies work collaboratively with government and non-government Partners through cooperative agreements, grants, and other official instruments to engage, manage and support participants throughout their participation in PLC projects. As part of these contracts and agreements, Partners are mandated and legally responsible for maintaining comprehensive documentation of PLC participant records as well as providing up-to-date information on PLC participants’ progress through reporting. Partners will be required to complete the Public Lands Corps Participant Tracking Sheet as part of that reporting requirement.

3. What will this information be used for - provide ALL uses?

This information collection request establishes policies and procedures for the implementation of the Public Lands Corps Participant Tracking Sheet. To assist the Federal government in ensuring that all qualified PLC participants receive a certificate of eligibility, all partners managing PLC projects will be requested to complete the Public Lands Corps Participant Tracking Sheet.

Data collected through the Public Lands Corps Participant Tracking Sheet will allow the Forest Service and other Federal Land Management Agencies who sponsor Public Lands Corps programs to support our collaborating Partners who manage eligible participants and their participation in PLC projects. In addition, this information collection will monitor the progress of participants enrolled in PLC programs and maintain a record of participant work hours, project locations and dates that PLC noncompetitive hiring status is conferred upon PLC participants.

For more information on specific data requested through the Public Lands Corps Participant Tracking Sheet, please see the explanations outlined in Table 1.

4. How will the information be collected (e.g., forms, non-forms, electronically, face-to-face, over the phone, over the Internet)? Does the respondent have multiple options for providing the information? If so, what are they?

The FS and other Federal Land Management Agencies will require that Partners electronically submit the Public Lands Corps Participant Tracking Sheet through secure email. Respondents will not have multiple options for providing the information. In the future, it is intended that Partners will be required to electronically submit tracking sheets through a Land Management Agency web-based project management system.

5. How frequently will the information be collected?

As part of contracts and agreements, Partners will be mandated and legally responsible for submitting the Public Lands Corps Participant Tracking Sheet on a quarterly basis.

6. Will the information be shared with any other organizations inside or outside USDA or the government?

Aggregate information could be shared with organizations and/or other land management agencies that support PLC initiatives. However, no specific, personally identifying information will be shared with other entities.

7. If this is an ongoing collection, how have the collection requirements changed over time?

This submission is a new information request and is not yet an ongoing collection. This submission does not include references to changes or adjustments.

2. 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.

The FS and other Federal Land Management agencies will require that Partners submit the Public Lands Corps Participant Tracking Sheet by electronic forms through secure email. In the future, it is intended that Partners will be required to electronically submit tracking sheets through a Land Management Agency web-based project management system.

Electronic submission of tracking sheets will result in great efficiency, timely reporting, verification of participant eligibility and completion of the program hours, and a reduced paperwork burden for Partners and FS Program Staff. In addition, electronic completion of the forms will allow Partners to easily access, update and modify documentation of PLC participant records as well as providing up-to-date information on PLC participants’ progress through reporting. Electronic reporting would eliminate the need to retype information on continuing participants.

2. 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.

Upon review of the FS’s programs of work, there are no other existing tracking forms suitable for PLC purposes. There is no other information collection in effect that would gather the same or similar information regarding PLC participants. Further, there is currently no information collected from Partners and/or other entities regarding participant records or progress as it relates to the PLC program or the noncompetitive hiring authority.

2. If the collection of information impacts small business or other entities, describe any methods used to minimize burden.

This information collection has little impact on small businesses or other entities. Smaller entities will have fewer participants to report, so the reporting burden should be commensurate with the organizational capacity. This tracking form is part of the effort to consolidate and streamline reporting and tracking to minimize burden.

2. Describe the consequence to 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 use of the Public Lands Corps Participant Tracking Sheet will ensure uniform collection of information regarding PLC participants to track and monitor that they meet the eligibility requirements and for the ability to track and monitor participation as described above.

If the FS is unable to collect data regarding PLC participants, it and other Federal Land Management Agencies would be unable to participate in a legally mandated program as outlined in the Act. Participating in the Act requires the constant ability to monitor and track the funding used to support PLC participants.

2. 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;

• Requiring respondents to prepare a writ­ten response to a collection of infor­ma­tion in fewer than 30 days after receipt of it;

• Requiring respondents to submit more than an original and two copies of any docu­ment;

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

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

• 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; or

• 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 request for collection of information is conducted in a manner consistent with the guidelines in Title 5 CFR 1320.6. There are no special circumstances related to this information collection.

2. 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.

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 record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported. 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.

The notice was published on 9/20/2017 in the Federal Register. The document citation is 82 FR 43932, and the notice appears on pages 43932-43933. It can be accessed electronically at: https://www.federalregister.gov/documents/2017/09/20/2017-20001/information-collection-public-lands-corps-participant-tracking-sheet.

One comment was received during the 60-day comment period. This comment, received 9/27/17, voiced a negative opinion on the PLC Tracking form, citing the expense of the program and a belief that it obscures the real cost of completing projects. A response was sent on 9/29/17, acknowledging receipt of the comment and sharing some background on the role of the PLC in local economies.

The FRN was shared with diverse stakeholders, including current and potential partners, and comments were solicited. We did not receive any public comments from this outreach.

2. Explain any decision to provide any payment or gift to respondents, other than re-enumeration of contractors or grantees.

Payments or gifts will not be made to respondents of this information collection.

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

The data collected for the PLC spreadsheet would fall under the Forest Service’ End-User Computer Environment (or EUCE) information system.  EUCE is an accredited system with a corresponding, signed and approved Privacy Impact Assessment (PIA).  The EUCE PIA is required by OMB Memorandum 03-22, which provides guidance for implementing the privacy provisions of the E-Government Act of 2002. The password protected file will be stored on a fully encrypted laptop, only being accessed by authorized Forest Service employees working as part of the administration of the Volunteer and Service program in the Forest Service’s Washington Office.

2. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or 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.

This tracking form request does not contain questions of a sensitive nature.

2. Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form.

The annual number of respondents was estimated as the current number of Partners supporting PLC projects; each would respond quarterly. The time per response was estimated by taking the average of the times it took for several Forest Service partners to individually complete the form. This estimated response time was multiplied by the estimated number of annual responses to result in the estimated total annual burden on respondents. The cost per hour used is the mean average hourly wage for Business Operation Specialists (https://www.bls.gov/oes/current/oes131199.htm), and was multiplied by the Estimated Annual Burden hours for an estimate of the total cost.

These numbers are shown in Table 2.

Table 2. Estimated burden hours and costs

A	B	C	D	E	F	G
Estimated Annual Number of Respondents	Estimated Annual Number of Responses per Respondent	Estimated Total Annual Responses (A x B)	Estimated Response Time (hours)	Estimated Annual Burden Hours (C x D)	Cost Per hour	Total Cost (E x F)
350	4	1,400	6	8,400	$47.15	$396,060

Record-keeping burden:

Partners are required to maintain records regarding PLC participants for a period of 3 (three) years after a participant receives a certificate of eligibility, signaling completion of a PLC project.

2. Provide estimates 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 estimates 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.

1. There are no non-hour costs.

2. There are no capital operation and maintenance costs.

2. Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

Estimates of annualized cost to the Federal government is totaled at $61,236 as demonstrated in Table 3. The method used is a calculation of the number of hours a comparable GS-9 Program Analyst would spend collecting and analyzing PLC participant data for PLC projects from Partners. Average GS-9 wage is $27.69 per hour; this figure is multiplied by the number of hours such analysts would need to compile and review PLC participant data over the course of a year.

To calculate approval and monitoring per applicant, the method used is a calculation of the number of hours a GS-13 Program Coordinator normally spends to review, analyze, and approve PLC participant data for PLC projects from Partners. Average GS-13 wage is $ 47.73 per hour; this figure is multiplied by the number of hours such analysts would need to complete the review of PLC participant data over the course of a year. Wages include 36.25% for benefits calculations.

No other expenses would have been incurred without the collection of information.

Table 3. Estimated cost to Government

(a) Description of the Collection Activity	(b) Forms Processing Time per Applicant	(c) Estimated Average Income per Hour of Processor	(d) Total Estimated Cost per Applicant (b) x (c)	(e) Applicants per year	(f) Subtotal (d) x (e)
Public Lands Corps Participant Tracking Sheet	35 minutes (.58 hour)	GS-09 $27.69/hour	$16.06	1400 (350 organizations submitting quarterly per year)	$22,484
Totals		----	----	----	$22,484

(a) Description of the Collection Activity	(g) Approval and Monitoring per applicant	(h) Estimated Average Income per hour of Supervisor	(i) Total Estimated Cost per Applicant (g) x (h)	(j) Applicants per year	(k) Subtotal (i) x (j)
Public Lands Corps Participant Tracking Sheet	35 minutes (.58 hour)	GS-13 $47.73/hour	$27.68	1400	$38,752
TOTALS		---	----	----	$38,752

(a) Description of the Collection Activity	(l) Sub-total Item f	(m) Sub-total Item k	(n) Total Estimated Cost
TOTALS	$22,484	$38,752	$61,236

2. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of OMB form 83-I.

This submission is a new information request and does not include program changes or adjustments.

2. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

Results of this information collection may be aggregated and released to the public through social media, briefing/white papers, and/or updates/newsletters to validate return on investment for Public Lands Corps programs and to inform policy regarding developing, implementing and managing Public Lands Corps programs. However, no specific personally identifying information will be published.

2. 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 valid OMB control number and expiration date will be displayed on all information collection instruments.

2. Explain each exception to the certification statement identified in item 19, "Certification Requirement for Paperwork Reduction Act."

There are no exceptions to the certification statement. The agency is able to certify that the collection of information encompassed by this request complies with 5 CFR 1320.

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