Paperwork Reduction Act Submission
Please read the instruction before completing this form. For additional forms or assistance in completing this form, contact your agency’s Paperwork Reduction Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 Seventeenth St. NW, Washington, DC 20503.
1. Agency/Subagency Originating Request: U.S. Department of Housing and Urban Development Public and Indian Housing
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2. OMB Control Number: a. 2577-0274
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b. None
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3. Type of information collection: (check one)
collection for which approval has expired
for which approval has expired
For b-f, note item A2 of Supporting Statement instructions. |
4. Type of review requested: (check one)
5. Small entities: Will this information collection have a significant economic impact on a substantial number of small entities? Yes No 6. Requested expiration date: a. Three years from approval date b. Other (specify)
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7. Title:
Energy and Performance Information Center (EPIC)
8. Agency form number(s): (if applicable)
9. Keywords:
Public Housing, Capital Fund, Budget, EEM, Energy Efficiency Measure, Energy Performance Contract, EPC, EPIC, Five Year Action Plan, Annual Statement, Physical Needs Assessment, Performance and Evaluation Report, Development
10. Abstract:
HUD created the Energy and Performance Information Center (EPIC) data system to manage reporting and oversight of the Public Housing Capital Fund Program, including submission and approval of Five-Year Action Plans, submission of Annual Statements/Budgets, and tracking implementation of Energy Efficiency Measures (EEMs) within Public Housing units.
11. Affected public: (mark primary with “P” and all others that apply with “X”) a. Individuals or households e. Farms b. Business or other for-profit f. Federal Government c. X Not-for-profit institutions g. P State, Local or Tribal Government |
12. Obligation to respond: (mark primary with “P” and all others that apply with “X”) a. X Voluntary b. P Required to obtain or retain benefits c. Mandatory |
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13. Annual reporting and recordkeeping hour burden: a. Number of respondents 2,950 b. Total annual responses 22,150 Percentage of these responses collected electronically 100% c. Total annual hours requested 40,695 d. Current OMB inventory 69,645 e. Difference (+,-) - 28,950 f. Explanation of difference: 1. Program change: -28,950 2. Adjustment: 0 |
14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) Do not include costs based on the hours in item 13. a. Total annualized capital/startup costs b. Total annual costs (O&M) c. Total annualized cost requested d. Current OMB inventory e. Difference f. Explanation of difference: 1. Program change: 2. Adjustment: |
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15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”) a. X Application for benefits e. X Program planning or management b. P Program evaluation f. Research c. General purpose statistics g. X Regulatory or compliance d. Audit |
16. Frequency of recordkeeping or reporting: (check all that apply) a. Recordkeeping b. Third party disclosure c. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biennially 8. Other (describe)
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17. Statistical methods: Does this information collection employ statistical methods? Yes No
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18. Agency contact: (person who can best answer questions regarding the content of this submission) Name: Robert Dalzell Phone: 202-402-4216
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19. Certification for Paperwork Reduction Act Submissions
On behalf of the U.S. Department of Housing and Urban Development, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9.
Note: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320/8(b)(3). appear at the end of the instructions. The certification is to be made with reference to those regulatory provisions as set forth in the instructions.
The following is a summary of the topics, regarding the proposed collections of information, that the certification covers:
It is necessary for the proper performance of agency functions;
It avoids unnecessary duplication;
It reduces burden on small entities;
It uses plain, coherent, and unambiguous terminology that is understandable to respondents;
Its implementation will be consistent and compatible with current reporting and recordkeeping practices;
It indicates the retention periods for recordkeeping requirements;
It informs respondents of the information called for under 5 CFR 1320.8(b)(3):
Why the information is being collected;
Use of the information;
Burden estimate;
Nature of response (voluntary, required for a benefit, or mandatory);
Nature and extent of confidentiality; and
Need to display currently valid OMB control number;
It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to collect (see note in item 19 of the instructions);
It uses effective and efficient statistical survey methodology; and
It makes appropriate use of information technology.
If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.
Signature of Program Official:
Susan A. Wilson, Acting Deputy Assistant Secretary Office of Public Housing Investments, PI
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Date: |
Supporting Statement for Paperwork Reduction Act Submissions
A. Justification:
Why is this information necessary?
Under Section 9 of the U.S. Housing Act of 1937 (1937 Act) and the regulations at 24 CFR 905, the Public Housing Capital Fund Program (Capital Fund Program or CFP) provides financial assistance to public housing agencies (PHAs) to make improvements to existing public housing. Eligible uses of capital funds include the development, financing, and modernization of Public Housing.
The Energy and Performance Information Center (EPIC) system provides a streamlined way for PHAs to fulfill their Capital Fund reporting requirements under 24 CFR 905.300. By regulation, PHAs are required to submit 1) a CFP 5-Year Action Plan describing the capital improvements necessary to ensure long-term physical and social viability of the PHA's public housing developments, and 2) a Capital Fund Budget for each year. PHAs submit this information electronically in EPIC.
This information collection in EPIC also enables HUD to fulfill its oversight responsibilities. Field Office staff review and approve 5-Year Action Plans (HUD-50075.2) to verify that all work activities are eligible items under the Capital Fund and to assess the level and type of environmental review required. Upon Annual Statement/Budget (HUD-50075.1) submission, HUD performs validation checks to full requirements to monitor statutory and regulatory restrictions on the funds, including limits on the percentage of funding that may be used for Administration, transferred to Operations, or used to undertake Management Improvements. HUD also uses the budget information to ensure that Housing Authorities participating in the Capital Fund Finance Program (CFFP) to leverage their limited capital funds are properly allocating funds for the debt service payments. For EPIC budget submissions found in compliance, HUD updates the Line of Credit Control System (LOCCS) in accordance with the funds spread in EPIC; this enables PHAs to draw down funds without requesting manual updates or revisions from HUD Field Offices. Lastly, HUD analyses PHA allocations of Capital Funds to report to Congress and interested stakeholders on spending patterns and to develop budgetary justifications.
In addition to collecting and using information in CFP Five-Year Action Plans and Budgets, several EPIC modules currently in use or in development collect additional key programmatic information or streamline PHA reporting.
Energy Efficiency Measures: The Core Activity/Energy module of EPIC collects information on Energy Efficiency Measures (EEMs) implemented with Capital Funds. HUD is in the process of analyzing this data along with data on utility costs to assess the pay-offs of implementing EEMs, which may enable HUD to provide technical assistance to PHAs interested in energy savings, with benefits for the agencies and the Department. HUD previously reported aggregated data toward HUD’s strategic goal on energy efficiency.
Physical Needs Assessments: This functionality will enable PHAs to download PIC data from EPIC in order to complete physical needs assessments. PHAs who wish to voluntarily submit their PNA data into EPIC may achieve time savings by drawing from items identified in the PNA to drop into their Five-Year Action Plan. Currently, PHA submission of PNA data to EPIC is strictly voluntary.
Energy Performance Contracts: Under 24 CFR 990.185, PHAs may qualify for conservation incentives when undertaking Energy Conservation Measures (ECMs) that are financed by an entity other than HUD through the use of an Energy Performance Contract (EPC). This allows PHAs the ability to privately finance energy improvements so that PHAs can use Capital Funds for other improvements. EPCs result in lower Operating costs for PHAs through reduced utility cost. The EPIC data system will collect information about the EPC process, including the energy efficiency improvements. The electronic submission process streamlines the former paper submission process and reduces the time for approval.
Public Housing Development: The EPIC data system will track development of public housing with Federal funds and through other means, including mixed-finance development, enabling more efficient review and submission of required development documents.
Replacement Housing Factor Plans: PHAs will be able to submit Replace Housing Factor fund plans, the mechanism by which PHAs may accumulate special funds received based on units removed from their inventory from year to year. This information is presently collected in hard copy at the field office level; the EPIC data system will automate and centralize this collection to streamline the process and improve transparency.
How is the data to be used?
As noted above, the information submitted in CFP Five-Year Action Plans is used by HUD to fulfill its oversight responsibilities. Field Office staff review and approve 5-Year Action Plans to verify that all work activities are eligible items under the Capital Fund and to assess the level and type of environmental review required. Upon budget submission, HUD performs validation checks to full requirements to monitor statutory and regulatory restrictions, including limits on the percentage of funding that may be used for Administration, transferred to Operations, or used to undertake Management Improvements. HUD also uses the budget information to ensure that Housing Authorities participating in the Capital Fund Finance Program (CFFP) to leverage their limited Capital funds are properly allocating funds for the debt service payments. For EPIC budget submissions found in compliance, HUD updates the LOCCS in accordance with the funds spread in EPIC; this enables PHAs to draw down funds without requesting manual updates or revisions from HUD Field Offices.
HUD analyzes PHA allocations of Capital Funds to report to Congress and interested stakeholders on spending patterns and to develop budgetary justifications. This analysis will become increasingly effective and detailed as PHAs currently submitting their 5-Year Action Plans and Budgets on paper transition to electronic submissions in EPIC in FY18 (see transition schedule below.) The Department will use the newly-collected data to get a real-time picture of the use of funding and the progress made toward meeting the considerable capital needs of the public housing inventory. The Department will gain a better understanding of the problem—both its nature and its scope—through the data collected in the EPIC data system. The electronic collection of the data formerly collected through paper Forms HUD-50075.1 and HUD-50075.2 will enable the Department to follow the money from grant to capital improvement and evaluate the successes of the program.
Moreover, the improved data collection around energy efficiency improvements will enable the Department to identify areas for increased savings in consumption. The EPC program enables grantees to leverage these savings into additional funding for meeting capital needs. The Department will be able to monitor the EPC process and document the energy savings realized through capital improvements implemented using EPIC financing. These data points, in conjunction with the PNA data and the energy audit data, will increase transparency in public housing and create a platform for evaluating performance and identifying efficiencies.
Data collected on public housing development will be used to ensure greater accuracy of present data and will be used to identify ways PHA grantees are using both federal and non-federal funding sources to meet the affordable housing needs of the American public.
Prior to the implementation of the EPIC system, PHAs used a paper process to submit Five-Year Action Plans and Budgets. (This information was previously collected in hard copy on Forms HUD-50075.1 and HUD-50075.2 under collection OMB control number 2577-0157.) The EPIC system provides for electronic submission and automates may aspects of this process.
The transition from a paper submission to an electronic submission of the Five-Year Action Plan and Annual Statement/Budget forms in the EPIC data system began in FY17 based on the grantee fiscal year end. For FY17, PHAs with 3/31 fiscal years ends and 6/30 fiscal year ends were required to transition to electronic submissions in EPIC. For FY18, all PHAs will be required to transition to electronic submission of the Five-Year Action Plan and Annual Statement/Budget in EPIC. In the future, PHAs may also submit Performance & Expenditure (P&E Reports) in EPIC.
Electronic submission in EPIC automates many steps in the planning and approval process. When completing these submissions in EPIC, many items pre-populate based on existing HUD system data. PHAs with an approved Five-Year Action Plan in EPIC can easily create their plan for the next reporting period by “copying forward” their current plan and making updates. Once HUD has approved a work item in the Five-Year Action Plan, it automatically retains its approved status, even if the PHA moves the item into a new plan or year. And, of particular significance, the system automates the budget revision process. Whereas HUD staff previously reviewed and approved budgets and then manually moved funds in LOCCS, HUD has automated the process of reviewing budgets and changing LOCCS accordingly.
HUD’s electronic collection of EEM information is also pre-populated with data to the greatest extent possible to minimize data entry. Once the initial report is created for a grant award, recipients also copy the file forward for editing in the next year.
The EPC and Public Housing Development modules also automate and streamline existing paper-based processes. For example, PHAs wishing to engage in an EPC will be able to submit many of the required documents electronically. Much of the rest of the process will be automated through the EPIC data system as well. Information on public housing development is collected piecemeal at the field office level in hard copy; the EPIC data system will automate and centralize this data collection. Finally, the RHF plan will be converted from a paper submission to the field office to an electronic submission, standardized and capable of aggregation, that will still be monitored by the field office for compliance.
4. Duplication of Information
This information is not being collected elsewhere. Some of the information to be collected through the EPIC data system is collected through paper submissions presently, but the EPIC data system’s electronic collection will completely replace the paper process.
Does the collection of information impact small businesses or other small entities?
Many of the recipients of PIH funds subject to this data collection are small PHAs. The impact is expected to be minimal.
Describe the consequences to Federal program or policy activities if the collection is not conducted or is conducted less frequently.
The regulations at 24 CFR 905.300 specify the frequency and timeline of submission of CFP Five-Year Action Plans and Annual Statements/Budgets.
If HUD’s review of Five-Year Action Plans were reduced or eliminated, PHAs would be at risk of having funds recaptured due to spending on ineligible purposes and failure to comply with environmental review requirements. If HUD eliminated compliance checks of budgets for compliance with statutory and regulatory spending limitations, PHAs and HUD would also face risk of audit findings and PHAs would see funds recaptured.
Misuse or inefficient use of federal funds would also deny these funds to their intended purpose and erode the public’s trust.
Without the information from Five-Year Plans, Budgets, and reporting on Energy Efficiency Measures, HUD would be limited in its ability to assess the use of capital funds, the needs of the inventory, and performance or progress toward reduced energy costs made by PHAs. However, the Department has reduced the frequency of reporting on EEMs from quarterly to annually in the previous revision to this information collection to provide relief to PHAs.
Finally, much of the information to be collected in the EPIC data system will enable grantees to realize benefits. For example, the EPC process, the RHF plan, and the development process require certain Department approvals under the United States Housing Act of 1937.
Explain any special circumstances that would cause an information to be collected in a manner:
requiring respondents to report information to the agency more than quarterly;
PHAs may submit budget revisions as needed when their plans for spending change, which may be in response to changing priorities or an emergency. Submitting a budget revision in EPIC enables HUD to update the spread of funds in LOCCS so that they can be drawn down by the PHA.
requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it;
Not Applicable
requiring respondents to submit more than an original and two copies of any document;
Not Applicable
requiring respondents to retain records other than health, medical, government contract, grant-in-aid, or tax records for more than three years;
Not Applicable
in connection with a statistical survey, that is not designed to produce valid and reliable results than can be generalized to the universe of the study;
Not Applicable
requiring the use of statistical data classification that has not been reviewed and approved by OMB;
Not Applicable
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
Not Applicable
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.
Not Applicable
8. Identify the date and page number of the Federal Register notice soliciting comments on the information.
This information collection was announced in the Federal Register, Volume 83; No. 76; Page 17424, on
April 19, 2018. The public was given until June 18, 2018, to submit comments on the proposed information collection. HUD received no public comments on this proposed collection.
9. Explain any payments or gifts to respondents, other than remuneration of contractors or grantees.
No payments or gifts to respondents are provided.
10. Describe any assurance of confidentiality provided to respondents.
Only summary level data will be made available to the public. The EPIC data system does not contain any personally identifiable information and does not involve the collection of any information covered by the Privacy Act. Information at the Grantee level is not sensitive.
11. Justify any questions of a sensitive nature, such as sexual, religious beliefs, and other matters that are commonly considered private.
The information collected does not contain questions of a sensitive nature.
12. Annual Reporting Burden
The EEM (“core activity”) data collection will cover 2,950 grantees with 11,800 active PIH grants and that will be reported in EPIC. Average time to complete the survey is 30 minutes. Respondents will be required to submit information under the core activity module annually. Each respondent will spend an additional 2.5 hours collecting the data required to complete the survey. The annual reporting burden hours are based on the requirement that each recipient submits a separate report for each active grant. The estimates for labor burden hours are upper limits and PIH anticipates that the actual labor burden will decrease somewhat as the grantee becomes more familiar with the EPIC data collection tool. Also, annual updates will likely require less labor than the initial submission.
The same universe of grantees will electronically submit the Forms HUD-50075.1 (the Annual Statement/Budget and Performance and Evaluation (P&E) Report) and HUD-50075.2 (the Capital Fund Program Five-Year Action Plan). The Department anticipates each “form,” separated by function in the EPIC data system, will require 2 hours to complete, as broken out in the table below. Data suggest approximately 8,500 open grants at any given point in time for which both the Annual Statement/Budget and P&E are required. PHAs are only required to update the Five-Year Action Plan every five years, but many PHAs do so more frequently (PHAs may elect whether to submit a fixed plan in 5-year intervals or a rolling plan annually and may change their election as desired.) The Department anticipates up to 2,000 responses per year through this module. The Department anticipates 30 submittals for EPC financings per year. The hourly burden associated with this process is much higher, but participation in the process is voluntary and at the PHA’s discretion.
The Department anticipates up to 60 new developments per year. These developments may contain varying numbers of units and correspondingly different levels of funding, both federal and non-federal. This process also demands a greater burden, but development is at the PHA’s discretion.
The Department anticipates approximately 60 PHAs per year will submit plans through the Mixed Finance Early Warning module. This module will allow a PHA to alert the Department of its intention to propose a mixed-finance transaction as well as various deadlines associated with the non-federal sources of financing so that the Department can provide technical assistance to the PHA in the planning process.
Pursuant to current regulations, in 2017 and prior years, the Department awarded Capital Funds as Replacement Housing Factor (“RHF”) grants based on units removed from the inventory to PHAs for up to 10 years. These RHF funds can be accumulated from years 1 to 5 pursuant to an approved RHF Plan. Awards in years 6 to 10 depend upon the PHA’s performance in using the funds from the former 5 years. These funds also can be accumulated pursuant to an approved RHF Plan. Accumulation is in the discretion of the PHA, however, given that funding per unit in any given year is insufficient to replace a single unit and that the time burden associated with creating a feasible plan is relatively low, many PHAs will choose to accumulate these funds. The Department anticipates approximately 50 plans per year with each requiring 30 minutes to prepare.
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Form/ Document |
No. of Respondents |
Frequency |
Total Responses |
Hours per Response |
Total Hours |
Cost per hour |
Total Cost |
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1 |
Core Activity |
2,950 |
1 |
2,950 |
3.0 |
8,850.00 |
$41 |
$362,850.00 |
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2 |
5yr plan |
2,000 |
1 |
2,000 |
2.0 |
4,000 |
$41 |
$164,000.00 |
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3 |
Annual Stmt budget |
8,500 |
1 |
8,500 |
1.0 |
8,500 |
$41 |
$348,500.00 |
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4 |
P&E |
8,500 |
1 |
8,500 |
1.0 |
8,500 |
$41 |
$348,500.00 |
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5 |
EPC
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30 |
1
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30
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120.0
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3,600
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$41 |
$147,600.00 |
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6 |
Public Housing Development |
60 |
1 |
60 |
120.0 |
7,200 |
$41 |
$295,200.00 |
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7 |
Mixed Finance Early Warning |
60 |
1 |
60 |
0.33 |
20 |
$41 |
$820.0 |
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8 |
RHF |
50 |
1 |
50 |
0.5 |
25 |
$41 |
$1,025.00 |
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Totals |
40,695 |
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PIH estimates that 40,695 hours of labor per year are required for this collection. Based on an estimated labor rate of $41.07 (GS-13 Step 5 equivalent) the annual labor cost is $1,668,495.00. Based on the Department’s experience, the projected labor burden should steadily decrease as the grantees become familiar with navigating the EPIC system and because submissions after the first reporting cycle for a grant will be an update to the initial submitted report and will require less labor to complete.
13. Additional Cost to Respondents
There are no additional costs to respondents other than what is reported in Item 12.
14. Annualized cost to the Federal Government
Estimated annualized cost for collection of information is $1,668,495. The assumed hourly cost figure of $41.07 is equivalent to the hourly (mid-range) salary of an experienced professional (i.e., a GS-13 Step 5 employee). The total estimated hours for the collection is 40,695 hours. The costs for this data collection are PIH project management and administration costs for individual grantees. The annualized cost is funded by the Federal government.
15. Explain any program changes or adjustments.
Revisions:
The number of annual Capital Fund grantees has been reduced from 3,150 to 2,950 mainly due Rental Assistance Demonstration (RAD) program conversions. RAD allows PHAs to convert their units from Public Housing units under an Annual Contribution Contract with Section 9 subsidy to project-based Section 8. This reduced hours from the collection 600 hours.
The energy conservation reporting was reduced from quarterly to annually. This reduced 28,350 hours from the collection.
16. If the information will be published, outline plans for tabulation and publication.
The data will be tabulated, summarized, and published in various internal and external reports (including annual performance reports), and press releases. The data may also be used by researchers to produce scholarly articles.
17. OMB Expiration Date
HUD is not seeking approval to avoid displaying the OMB expiration date.
18. Certification of Paperwork Reduction Act Submission
There is no exception to Item # 19 "Certification of Paperwork Reduction Act Submission.”
B. Collections of Information Employing Statistical Methods.
The collection of information does not employ statistical methods.
OMB 83-I 10/95
| File Type | application/msword |
| File Title | Paperwork Reduction Act Submission |
| Author | WAYNE EDDINS |
| Last Modified By | SYSTEM |
| File Modified | 2018-09-25 |
| File Created | 2018-09-25 |