20170925 DRCA Justification

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSIONS

 

A. Justification

A1.  Need for Information Collection

The purpose of this request is to seek approval for the CNCS Disaster Response Cooperative Agreement Application. Existing CNCS statutes require a formal agreement to be established between CNCS and grantees to allow for the reimbursement of grantee expenses incurred while supporting CNCS mission assigned activities.

In order to establish these formal agreements, CNCS will seek out interested programs and encourage them to apply for a Disaster Response Cooperative Agreement. The enclosed application will allow CNCS to ensure that interested programs meet the appropriate programmatic and fiscal requirements to successfully execute mission assigned activities. Additionally, the collected information will help CNCS best match the capabilities of the programs to the needs of the communities requesting assistance.

The Corporation plans to accept applications on a rolling basis, and approve them for a Cooperative Agreement on a pass/fail basis.

A2.  Indicate how, by whom, and for what purpose the information is to be used.

The information collected will be used to help CNCS more effectively utilize its deployable resources to meet the needs of disaster affected communities. A better understanding of the participating programs will allow CNCS to match the capabilities of the programs to the needs of the communities and will allow better asset mapping and resource typing. Additionally, the information collected will allow CNCS to conduct better outreach to interested programs by providing them with more information about CNCS disaster procedures, reimbursement requirements, reimbursable expenses covered by the agreement, and support services offered.

 

 A3.  Minimize Burden: Use of Improved Technology to Reduce Burden

The application, instructions and procedures will be provided in pdf format to all applicants. This file will be housed on the agency website. Applications can be submitted electronically via e-mail to CNCS.

A4.  Non-Duplication

There are no other sources of information by which CNCS can meet the purposes described in A2 (above).

 

A5.  Minimizing for economic burden for small businesses or other small entities.

This collection of information does not impact small businesses since they are not eligible to apply for a CNCS base grant. Economic burden to other small entities is limited to the cost of staff time to develop and submit the application. This is minimized to the degree possible by asking only for the information absolutely necessary to make responsible grant approval decisions, and by excluding information already provided in the grantee’s base grant application.

A6.  Consequences of the collection if not conducted, conducted less frequently, as well as any technical or legal obstacles to reducing burden.

 

The Corporation would be unable to fully utilize its programs effectively in times of disaster. The only information currently collected from Cooperative Agreement partners comes with the grantee’s SF-424 Application for Federal Assistance and their base grant. Since neither document provides information on disaster capabilities, number of participants available for disaster deployment, dates of availability or like information; CNCS will have to suspend efforts to map assets and inform partner organizations (including FEMA) of the assets CNCS can bring to bear on impacted communities. Additionally, CNCS runs the risk of deploying programs not suitable for specific disaster assignments, thereby endangering the service activity and possibly the deployed participants. Finally, CNCS will be constrained in meeting its obligations under the National Response Framework for supporting communities affected by disaster.

A7.  Special circumstances that would cause information collection to be collected in a manner requiring respondents to report more often than quarterly; report in fewer than 30 days after receipt of the request; submit more than an original and two copies; retain records for more than three years; and other ways specified in the Instructions focused on statistical methods, confidentially, and proprietary trade secrets.

There are no special circumstances that will require information to be collected in a manner that is not consistent with the requirements outlined above.

A8.  Provide copy and identify the date and page number of publication in the Federal Register of the Agency’s notice. Summarize comments received and actions taken in response to comments. Specifically address comments received on cost and hour burden.

The 60 day Notice soliciting comments was published on July 11, 2014 on pages 40070 -40072. No comments were received.

 

 A9.  Payment to Respondents

There are no payments or gifts to respondents

  

A10.  Assurance of Confidentiality and its basis in statute, regulation, or agency policy.

Information provided by respondents is subject to the Privacy Act and the instrument includes a Privacy Notice. The information requested is collected pursuant to 42 U.S.C 12592 and 12615 of the National and Community Service Act of 1990 as amended, and 42 U.S.C. 4953 of the Domestic Volunteer Service Act of 1973 as amended. Purposes and Uses - The information requested is collected for the purposes of reviewing applications for cooperative agreements. Routine Uses - Routine uses may include disclosure of the information to federal, state, or local agencies pursuant to lawfully authorized requests. In some programs, the information may also be provided to federal, state, and local law enforcement agencies to determine the existence of any prior criminal convictions. The information may also be provided to appropriate federal agencies and Department contractors that have a need to know the information for the purpose of assisting the Department’s efforts to respond to a suspected or confirmed breach of the security or confidentiality or information maintained in this system of records, and the information disclosed is relevant and unnecessary for the assistance. Effects of Nondisclosure - The information requested is mandatory in order to receive benefits.

A11.  Sensitive Questions

 

The information collection does not include questions of a sensitive nature.

 

A12. Hour burden of the collection

The total hour burden is estimated at 200 hours. The frequency of response will not be greater than once per year and should average 2 hours of effort per respondent for the full application submission. There is no estimated annual hour burden outside of the customary and usual business practices.

 

A13. Cost burden to the respondent

There is no cost to the respondent.

 

A14. Cost to Government

There are no additional costs to the Government.

A15. Reasons for program changes or adjustments in burden or cost.

Not applicable.

 

 A16.  Publication of results

The collection of information resulting from the grant competition will not be published.

 

A17.  Explain the reason for seeking approval to not display the expiration date for OMB approval of the information collection.

Not applicable.

 

 A18.  Exceptions to the certification statement

There are no exceptions to the certification statement in the submitted ROCIS form.

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