2018 Clean Fuel Cell Grant Program Supporting Statement FINAL

2018 Clean Fuel Cell Grant Program Supporting Statement FINAL.docx

Clean Fuels Grant Program

OMB: 2132-0573

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DEPARTMENT OF TRANSPORTATION

FEDERAL TRANSIT ADMINISTRATION


SUPPORTING STATEMENT

49 U.S.C. SECTION 5308 Clean Fuels Grant Program

OMB Control No. 2132- 0573


ABSTRACT

This supporting statement is associated with a request for an extension of a currently approved information collection.  The change in this collection reflects a reduction in burden on the public and federal government due to the Clean Fuels Grant Program being repealed by Congress under the Moving Ahead for Progress in the 21st Century Act (MAP-21).  As a result, the application stage and all information collected as part of this process in the program have been eliminated. Once all funds are fully expended and the reporting requirements expire, this information collection will be discontinued.


A. Justification


1. CIRCUMSTANCES THAT MAKE THE COLLECTION NECESSARY.


The Clean Fuels Grant Program had a two-fold purpose. First, the program was developed to assist nonattainment and maintenance areas in achieving or maintaining the National Ambient Air Quality Standards for ozone and carbon monoxide. Second, the program supported the development and deployment of clean fuel and advanced propulsion technologies for transit buses by providing funding for clean fuel vehicles and facilities.


The Section 5308 Clean Fuels Grant Program was originally initiated as a formula program under the Transportation Equity Act for the 21st Century (TEA-21) in June 1998. However, in 2005, Section 3010 of the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU), Pub. L. No. 109-59, 119 Stat. 1144, 1572 (2005), amended section 5308 of title 49 United States Code, commonly referred to as the Clean Fuels Grant Program, from a formula-based to a discretionary grant program.

On October 1, 2013, the Clean Fuels Grant program was repealed by Congress under the Moving Ahead for Progress in the 21st Century Act (MAP-21). Originally, the program had two reporting requirements by grant recipients; the application stage and the project management stage. Since being repealed, the program no longer announces grant funding opportunities, thus, eliminating the application stage. However, to meet federal program oversight responsibilities, FTA must continue to collect information under the program management stage until the period of availability expires; the funds are fully expended; the funds are rescinded by Congress; or the funds are otherwise reallocated.





2. HOW, BY WHOM, AND FOR WHAT PURPOSE THE INFORMATION IS TO BE

USED AND CONSEQUENCES IF THE INFORMATION IS NOT COLLECTED.


Since the application stage has been eliminated, the only information collected as

part of the Clean Fuels Grant Program occurs during the Project Management Stage During this stage, grant recipients are required to submit various reports electronically via FTA’s Transit Award Management System (TrAMS). However, not all grant recipients are required to submit every report.


All recipients shall maintain and report financial and operating information on a quarterly basis by submitting their Federal Financial Reports (FFRs) into TrAMS. However, only the recipients of financial assistance under 49 U.S.C. 5308 who purchased or leased hybrid electric, battery electric and fuel cell vehicles shall report semi-annually to FTA for the first three years of the useful life of the vehicle. In addition, recipients that purchased or leased clean diesel vehicles are not required to report information beyond FTA grant reporting requirements for capital projects. Below is a summary of each of the various reports and/or information collected.


  1. Federal Financial Reports (FFRs)/Quarterly: All grant recipients are required to submit FFRs. These quantitative reports provide a financial picture of project activity. The reports include information regarding obligations, payments, receipts, and other pertinent financial data required to ensure proper expenditure of federal funds.


  1. Milestone/Progress Reports (MPR)/Semiannually: These narrative reports define the level of activity for each project element during the reporting period. All significant events (e.g. delays, problems, milestone achievements, etc.) are reported to FTA. The reports greatly reduce the need for on-site visits by staff.


If this information is not collected, FTA could not ensure the proper expenditure of federal funds or assess the program effectiveness.



3. CONSIDERATION OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE BURDEN AND ANY TECHNICAL OR LEGAL OBSTACLES TO REDUCING BURDEN.


FTA’s Transit Award Management System (TrAMS) is an online program used by 100% of recipients to submit reporting requirements during the project management stage.


  1. 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.


The reports are project specific and the information is not available elsewhere.




  1. METHODS USED TO MINIMIZE BURDEN ON SMALL BUSINESSES OR OTHER SMALL ENTITIES.


The information collected does not involve small businesses.



  1. CONSEQUENCES TO FEDERAL PROGRAMS OR POLICY ACTIVITIES IF

INFORMATION WAS NOT COLLECTED OR COLLECTED LESS FREQUENTLY, AS WELL AS ANY TECHNICAL OR LEGAL OBSTACLES TO REDUCING THE BURDEN.


If the information was not collected during the project management stage, FTA would not be able to track expenditures for approved projects as federally required. Further reduction of reporting information would make it impossible to determine the reliability, benefits and costs of operations and performance of clean fuel technology buses and conduct trend analyses.


  1. SPECIAL CIRCUMSTANCES THAT REQUIRE THE COLLECTION TO BE

CONDUCTED IN A MANNER INCONSISTENT WITH 5 CFR 1320.6.


The information collected is consistent with the guidelines in 5 CFR 1320.6.


  1. EFFORTS TO CONSULT WITH PERSONS OUTSIDE THE AGENCY TO OBTAIN THEIR VIEWS.


A 60-day Federal Register notice was published on December 11, 2017 (82 FR 58072). One comment was received from this notice; however, it was posted five days after the comment period expired and the comment was outside the scope of the Paperwork Reduction Act and made no reference to the Clean Fuel Cell Grant Program or any reference to the Federal Transit Administration. A 30-day Federal Register notice was published on April 10, 2018 (83 FR 15453).



  1. EXPLAIN ANY DECISION TO PROVIDE ANY PAYMENT OR GIFT TO

RESPONDENTS, OTHER THAN REMUNERATION OF CONTRACTORS OR

GRANTEES.


No payment is made to respondents.


  1. DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED

RESPONDENTS.


There is no assurance of confidentiality regarding these submissions.


11. ADDITIONAL JUSTIFICATION FOR QUESTIONS OF A SENSITIVE NATURE.


None of the information is of a sensitive nature.

12. ESTIMATE OF THE HOUR BURDEN OF THE COLLECTION, AND ANNUALIZED

COST TO RESPONDENTS.


Estimated Annual Number of Respondents: 17

Estimated Total Annual Burden Hours: 168

Estimated Total Cost to Respondents: $6,523.44

Frequency: Semi-Annually


The estimated hourly and cost burden of the Clean Fuels Grant Program during the Project Management stage is presented below. The estimate is based on the review of the grantees internal documents in preparation of each of the required reports that are submitted into TrAMS by the grant recipient. FTA estimates that only (1) Business Operations Personnel/Cost Estimator will be involved in the preparation of the request. Although there is no new funding available for this program, there are currently a total of (17) respondents (transit agencies with open grants) that are required to continue reporting information under the project management stage. All (17) respondents must submit the FFR on a quarterly basis (17 x 4 = 68). However, only (8) respondents must submit a MPR on a semi-annual basis (8 x 2 = 16 reports) due to the type of vehicle purchased. Therefore, there are a total of 84 reports (68 + 16) reports submitted on an annual basis. If each report takes approximately 2 hours to complete, the total annual burden hours is 168 hours (84 x 2).

Report Requirements

# Total Respondents

#Total Submissions/Reports Annually

Burden hours per submission

Federal Financial Reports (FFR)

Submitted Quarterly


17



68

2


Milestones/Progress Reports (MPR)

Submitted Semi- Annually




8



16




2


Estimate of the cost to respondents:

Project Management Stage:

FTA estimates that the average salary of the respondent, typically a Business and Financial Operations Personnel/Cost Estimator (occupation code 13-1051 https://www.bls.gov/oes/current/oes131051.htm) has a median hourly wage of $38.83 (hourly salary is weighted with a 28% benefits adjustment) according to the Bureau of Labor Statistics.

It is estimated to take each respondent approximately (2) hours to prepare and submit the FFRs and/or MPRs at an average salary of $38.83 per hour or $77.66 per report. There is a total of 84 reports annually; therefore, the cost is estimated to be $6,523.44 ($77.66 per report x 84 reports).



13. ESTIMATE OF TOTAL ANNUAL COST BURDEN TO RESPONDENTS OR

RECORDKEEPERS RESULTING FROM THE COLLECTION OF INFORMATION

(NOT INCLUDING THE COST OF ANY HOUR BURDEN SHOWN IN ITEMS 12

AND 14.


There is no additional cost beyond that shown in items 12 and 14.


14. ESTIMATE OF THE ANNUALIZED COST TO THE FEDERAL GOVERNMENT.

The cost is calculated as follows:

Project Management Stage:


The average FTA employee reviewing program management reports (FFRs and MPRs) submitted into TrAMS by recipients is a GS-12 step 5 (average salary, $44.28 per hour (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2018/general-schedule/). It takes approximately 2 hours per report for review. There are 84 reports per year. Thus, the total annual hours spent reviewing reports is 168 hours (84 x 2).

The total cost to the federal government is $7,103.04 ($42.28 per hour x 168 hours).

  1. EXPLAIN REASONS FOR CHANGES IN BURDEN, INCLUDING THE NEED FOR

ANY INCREASES.


This information reflects a burden decrease because the Clean Fuels Grant Program was repealed by Congress under the Moving Ahead for Progress in the 21st Century Act (MAP-21). As a result, the application stage and all information collected as part of this process in the program has been eliminated. This resulted in a significant decrease because the large pool of grantees submitting the comprehensive applications is no longer applicable and the federal government no longer needs to conduct detailed reviews of each of the applications for selection of funding. Only those grantees that were previously awarded federal funding to purchase clean fuel vehicles under this program are required to provide information for the first three years of the useful life of the vehicle; and/or the funds are fully expended. Once the funds are fully expended this information collection will be discontinued.


  1. PLANS FOR TABULATION AND PUBLICATION FOR COLLECTIONS OF

INFORMATION WHOSE RESULTS WILL BE PUBLISHED.


FTA does not plan to publish the results of the information collected for statistical use.


  1. IF SEEKING APPROVAL NOT TO DISPLAY THE EXPIRATION DATE FOR OMB

APPROVAL, EXPLAIN THE REASONS.


There is no reason not to display the expiration date of OMB approval.


18. EXPLAIN ANY EXCEPTIONS TO THE CERTIFICATION STATEMENT

IDENTIFIED IN ITEM 19 OF OMB FORM 83-I.


No exceptions are stated.

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