1024-0018 Ssa.12.03.2018

Supporting Statement A for

Paperwork Reduction Act Submission

Nomination of Properties for Listing in the

National Register of Historic Places, 36 CFR 60 and 63

OMB Control Number 1024-0018

Terms of Clearance: None.

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

The National Historic Preservation Act of 1966 (16 USC 470 ), as amended, authorizes the Secretary of the Interior to maintain a National Register of Historic Places as a list of the Nation's historic, architectural, and archeological resources worthy of preservation. Nominations to the National Register (NR) are made by Federal agencies (FPO), State Historic Preservation Officers (SHPO), territories, the District of Columbia, and Tribal Historic Preservation Officers (THPO) as required by the law and 36 CFR Part 60. These officials are responsible for documenting the nominated properties to the satisfaction of the Secretary. The 1980 amendments to the Act allow for the nomination of properties by local governments or individuals in cases where there is no approved State program. The National Register of Historic Places Registration Form (NPS Form 10-900), the National Register of Historic Plates Registration Continuation Sheet (NPS Form 10-900-a), and the National Register of Historic Places Multiple Property Documentation Form (MPS) (NPS Form 10-900-b) are completed by individuals, SHPOs, FPOs, THPOs, or other nominating organizations. The SHPOs, FPOs, and THPOs then forward these forms to the National Park Service (NPS) for nomination to the National Register. As per 36 CFR 60, NPS does not process nominations received directly from the public. The forms are also completed by Federal agencies seeking a determination of eligibility for listing as required by the law and 36 CFR 63. The forms collect only information that is necessary to conform to the requirements of the National Historic Preservation Act and the Federal regulations that implement that 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. Be specific. If this collection is a form or a questionnaire, every question needs to be justified.

The NPS uses the information provided on NPS Forms 10-900, 10-900-a, and 10-900-b to evaluate the eligibility of properties and approve them for inclusion in the National Register. Registration and multiple property documentation forms are evaluated by the National Register staff before listing and are reviewed after listing during periodic program reviews. NPS review and approval of forms is based on 1) the sufficiency of information provided in the forms and supporting documentation, such as photographs and maps that accompany the forms, and 2) the eligibility of the property when evaluated according to the National Register criteria. Much of the information requested on the form corresponds to data fields in the National Register computerized database, the National Register Information System (NRIS). The NRIS provides a readily accessible, online source of information about the National Register and the properties it contains. Information on the registration and multiple property forms is routinely used by States, Federal agencies, Indian tribes, and others in applying the Federal protections and rehabilitation incentives afforded properties listed in the National Register. The information is used for heritage education and interpretation to provide a tangible understanding of our common heritage. Historic context information in multiple property documentation forms also assists States and others in planning for the identification, evaluation, and protection of historic resources. We have not made any changes to the forms. We collect the following information:

National Register of Historic Places Registration Form (NPS Form10-900)

A. Name of Property: This block identifies the specific property being registered in the National Register according to the various names by which the property has been known. Although the historic name is generally considered the official name of the property, the inclusion of other names provides an appropriate means of differentiating one property from other similarly named properties already listed in the National Register. It also assists the public and other users who may know the property by these other names.

B. Location: This block identifies the geographic location of the property by street number, street, city, county, state, and ZIP code. The "not for publication" item is used primarily for resources, such as archeological sites, which would be adversely affected by amateur excavation or vandalism by the general public if the location were disclosed. In accordance with the National Historic Preservation Act, the National Register is allowed to withhold information on specific locations of properties which might be adversely affected by the release of such information. The item "vicinity" is used to help locate properties outside of incorporated political jurisdictions.

C. State/Federal Agency or Tribal Certification: The signature of the State, Federal, or tribal certifying official certifies that the documentation provided on the form meets the National Register documentation standards and that its submission meets the professional and procedural requirements set forth in the regulations. This statement clarifies the accountability of the State, Federal, or tribal official for the content and submission of the form, in keeping with the intent of the National Historic Preservation Act. It also provides for clear statements of the opinion of the certifying official and any commenting officials, as outlined in the regulations, on whether or not the property meets the National Register criteria. The item for the level at which the certifying official has considered the significance of the property indicates the contextual level at which evaluation of the property has taken place, that is, locally, statewide, or nationally.

D. National Park Service Certification: NPS completes this to record the nature and dates of actions taken regarding the registration of the property in the National Register.

E. Classification: This block is used to classify the property by ownership of the property, type of property, and the number and nature of resources comprising it. Since some resources within a property, such as a district, may have been previously listed, that number is also requested. The name of a related multiple property listing provides a useful cross-reference to the multiple property file, if applicable. This block provides useful information that quickly provides essential facts that relate the property to specific provisions of the National Register program as outlined in the regulations.

F. Function or use: This block requests information on the current and historic functions or uses of the property. The block is completed from a list of categories that correspond to those entered in the NRIS.

G. Description: The narrative description of the physical appearance and condition of a property requested in this block is important in making an accurate assessment of the significance and integrity of the property being registered. The items for Architectural Classification and for Materials are completed from lists of categories corresponding to those entered in the NRIS. They provide quick reference to the physical aspects of the property that relate to its integrity, significance, and need for specific preservation treatments.

H. Statement of Significance: The narrative statement of significance is based on documentary research of the property and the specific assessment of how the property qualifies for listing in the National Register. Applicable National Register criteria and criteria considerations (exceptions) quickly link the property to the qualifying National Register criteria as specified in the regulations. Areas of Significance, Period of Significance, Significant Dates, Cultural Affiliation, Significant Person, and Architect/Builder provide easy reference to the specific facts, dates, and associations that underscore the property's historic importance and relate it to the National Register criteria. All items directly correspond to data elements and categories included in the NRIS.

I. Major Bibliographic References: This block lists the sources from which the documentation given on the form was compiled and the assessment of the property's significance was made. This information is necessary to verify information given in the Description and Significance blocks. This block also requests indication of 1) any previous documentation on file in the NPS, and 2) the location of additional documentation. This cross-referencing proves useful to tie documentation sources and administrative processes together regarding how the property has been evaluated and for what purposes previously.

J. Geographical Data: This block provides information on the acreage, UTM or latitude/longitude references, and boundaries for the property being registered. Acreage, given to the nearest acre, specifies the size of the property being registered. Locational references provide for one method for recording the geographical location of the property. The verbal boundary description specifies exactly what land is included and defines its legal boundaries for purposes of listing in the National Register. The block also requests a concise explanation or justification of how the boundaries and acreage were selected. Information in this block is essential for identifying exactly what property is being registered and for ensuring that the boundaries and acreage selected are appropriate to the property's historic significance. Many free online mapping programs (Google Earth, Bing maps, ArcGIS Explorer) now provide users with the ability to produce property maps that are accurate and cost-effective for use with National Register nominations.

K. Form Prepared by: This block identifies the name, organization, address, and phone number of the person(s) directly responsible for compiling the information. This information enables the National Register staff to contact the person directly, if necessary, after consultation with the SHPO, FPO, or THPO.

National Register of Historic Places Continuation Sheet (NPS Form 10-900-a).

This form is used to complete items from forms 10-900 and 10-900-b for which additional space is needed: it is actually just a blank page with a National Register of Historic Places header. The continuation sheet is used when additional space is needed for historic photographs, drawings, and documents that supplement the historical information requested.

National Register of Historic Places Multiple Property Documentation Form (MPS) (Form 10-900-b).

This form is also used to document properties for inclusion in the National Register. This form is used in conjunction with NPS Forms 10-900 and 10-900-a. The MPS cover form efficiently provides, in a single document, the contextual information necessary for the evaluation of many historic resources related through geography and/or theme. Because the registration forms for related individual properties do not restate this information—it is required to relate the individual property to the historic context information recorded in the multiple property documentation cover form—their recordation is substantially facilitated and the time to accomplish it significantly expedited. Furthermore, the evaluation of newly surveyed or discovered resources also will be expedited when they can be related to existing historic context documentation contained in extant MPS cover forms. All historic contexts approved for MPS nominations to the National Register nationwide are available online to further facilitate and expedite the identification, evaluation and registration of additional similar properties.

A. Name of Multiple Property Listing: This block identifies the multiple property submission and provides an easy reference by which to link individual properties related to the form. The name is based on common physical characteristics, on historical events or persons to which the group relates, or architectural or archeological types which describe the properties.

B. Associated Historic Contexts: This block lists the historic contexts or an organizational format that groups the information about the related properties. The titles of the historic contexts include the unifying theme, period of significance, and geographical area. The block is used to list the themes with which the properties included in the MPS submission are associated.

C. Form Prepared By: This block identifies the name, organization, address, and phone number of the person(s) directly responsible for compiling the documentation. This information enables the National Register staff to contact that person directly, if necessary, after consultation with the SHPO, FPO, or THPO.

D. Certification: The signature of the State, Federal, or tribal certifying official certifies that the documentation provided on the form meets the National Register documentation standards and that its submission meets the professional and procedural requirements set forth in the regulations. The statement clarifies the accountability of the State, Federal, or tribal official for the content and submission of the form, in keeping with the intent of the 1980 amendments to the National Historic Preservation Act.

E. Statement of Historic Contexts: This block includes a discussion of the themes on which contexts listed in block B are based. Each context is related to significant patterns of American history, architecture, archeology, engineering, and culture. It is discussed in terms of the historic development of the locality, state, or nation, and in terms of the general areas of significance for which properties related to the group may be listed.

F. Associated Property Types: In this block, all of the variety of property types representing the contexts discussed in block E are listed. Property types link the ideas incorporated in the theoretical historic context with actual historic properties that illustrate the underlying themes. For each property type given, this section will include: a description of the physical characteristics or common associations with events or persons that define the property type; a statement of how the property type is significant to the areas outlined in the historic context; and the registration requirements, (what features or characteristics individual properties must retain in order to convey the significance of the property type and thus be eligible for inclusion in the National Register) based on an analysis of the data collected on the property type. This section will be a tool in identifying and evaluating resources for nomination to the National Register.

G. Geographical Data: This block describes the geographic limitations of the area where properties included within the multiple property submission exist. The information is essentially a list of towns, cities, counties, parts of counties, multiple counties, areas of states, regions, or multiple states where the resources are located.

H. Summary of Identification and Evaluation Methods: This block explains the methods used to identify and analyze property types and determine the requirements for listing. The summary of methods assists the NPS in evaluating and verifying the information given in blocks E and F.

I. Major Bibliographic References: This block lists major bibliographic references, surveys, and study units used to document the property types and historic contexts. This information is necessary to verify the statements made in blocks E and F.

3. 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 and specifically how this collection meets GPEA requirements.

Currently, the forms are submitted either on paper or electronically on disk, with the required accompanying maps and photographs. Forms are completed using a Word template (found online at http://www.nps.gov/history/nr/publications/forms.htm). Photographs are also submitted as digital prints and on disk. We are working with staff in the Department of the Interior to include the forms in the Department’s Enterprise Forms System. Once included the forms will be completed online and electronically submitted

4. 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.

There is no duplication and the agency does collect any similar information support this function. No other agency is responsible for collecting this information. Each property is unique and individually assessed to determine if it meets the criteria of the National Register.

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

The collection of information does not significantly affect small entities. We have carefully analyzed the collection requirements to ensure that the information requested is the minimum necessary. To minimize respondent burden, we provide examples of approved nominations, guidance to complete a NR nomination and historic contexts to further facilitate the identification, evaluation, and registration of similar properties.

6. 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.

If this information is not collected, it would not be possible to maintain the National Register list and administer the required federal programs (e.g., Advisory Council for Historic Preservation review and comment, federal historic preservation tax incentives, federal project planning, and preservation grant programs). We only collect information the on occasion when there are submissions for properties to be included in the National Register.

7. 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;

* requiring respondents to submit proprietary trade secrets, 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.

There are no special circumstances that require the collection of this information in a manner inconsistence with OMB guidelines.

8. 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 in response to the PRA statement associated with the collection over the past three years, 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 recordkeeping, 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 three years — even if the collection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

On April 24, 2018, we published in the Federal Register (83 FR 17841) a notice of our intent to request that OMB approve the collection of information associated with nominations of properties for inclusion in the National Register of Historic properties. We solicited public comments for 60 days, ending June 25, 2018. We did not receive any comments related to this request.

In addition to the 60 day FRN, we solicited feedback from nine SHPO National Register Coordinators (see Table 8.1) that have extensive experience in completing the subject forms as part of their job responsibilities. We asked them to provide comments on the following:

• whether or not the collection of information is necessary, including whether or not the information will have practical utility; whether there are any questions they felt were unnecessary.

• the accuracy of our estimate of the burden for this collection of information;

• ways to enhance the quality, utility, and clarity of the information to be collected; and

• ways to minimize the burden of the collection of information on respondents.

Table 8.1. Consultation with representatives outside the agecy

SHPO National Register Coordinators
NY SHPO Wisconsin SHPO Arkansas SHPO Indiana SHPO Montana SHPO	Ohio SHPO Oregon SHPO Tennessee SHPO Texas SHPO

We did not receive any written comments. However, during the routine course of business, we conduct follow-up phone calls to clarify information on recently received forms. During the 60-day comment period, the representatives listed below were asked to provide feedback (for this purpose) during the calls.

• Three of the individuals stated that the time to complete the forms varies depending upon the level of detail they needed.

• One person said that more than half of his time was spent visiting sites to compile the information (e.g., photographs, maps, etc.) required to accompany the forms

• All of the respondents agreed that the process is very necessary to protect historic buildings, sites, structures, districts or objects.

• One respondent felt that the forms should be automated to allow electronic submission and communication. They expressed the need to end consultation letters and signatures for notices approved for publication especially when electronic communications are more efficient.

No changes to burden were made based on the feedback received.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

We do not provide payments or gifts to respondents.

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

The Secretary of the Interior is required by law to withhold from disclosure to the public information about the location, character, or ownership of a historic resource if such disclosure might cause a significant invasion of privacy, risk, or harm to the historic resources or impede the use of a traditional religious site by practitioners. The only information collected that could be considered confidential in nature is the location of specific properties, their traditional cultural use, and the informants, such as tribal elders, who may testify in the nomination documentation to their cultural importance. Although this information is reported on the form, and necessary to establish precisely which property is listed, the NPS maintains the confidentiality of certain specific information in order to protect properties. This is particularly the case with many archeological sites and certain properties that are subject to vandalism. It is also the case with places used in traditional cultural practices. Section 304 of the National Historic Preservation Act, as amended, establishes this authority.

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

We do not ask questions of a sensitive nature. Sometimes, the information that documents the historic significance of a property may be considered sensitive information. For example, in the case of historic places that are still used for traditional cultural practices, the location of the property, the identity of its specific users, and the informants, such as tribal elders who may testify to the cultural importance of these properties, are kept confidential so as not to interfere with traditional uses.

12. Provide estimates of the hour burden of the collection of information. The statement should:

* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here.

We estimate 2,564 annual responses totaling 226,672 annual burden hours. The annual dollar value for the burden hours is estimated to be $24,575,502 (rounded).

The estimated burden for each form is listed in the table below. The amount of research or information necessary to meet minimum federal requirements will vary based upon the length and breadth of each nomination. Because it is difficult to come up with precise burden estimates for completing the forms for every possible nomination preparation scenario we propose the following averages to provide reasonable estimates of the burdens to complete each form based on the type and complexity of the nomination, and the experience of the preparers listed in item 8 above.

We used the Bureau of Labor Statistics (BLS) News Release USDL-18-1499, September 18, 2018, Employer Costs for Employee Compensation—June 2018, to calculate the total annual burden.

• Individuals. Table 1 lists the hourly rate for all workers as $36.22, including benefits.

• Private Sector. Table 5 lists the hourly rate for all workers as $34.19, including benefits.

• Government. Table 3 lists the hourly rate for all workers as $49.23, including benefits.

Nominations prepared by consultants - We used an average consultant fee of $120 per hour as the hourly wage cost, including benefits.

Table 12.1. Total Annual Costs to Federal Government

Activity	Annual Number of Responses	Estimated Time per Response (hours)	Total Annual Burden Hours	Dollar Value of Burden Hour Including Benefits	Total Dollar Value of Annual Burden Hours*
Preparation and Submission of Nomination Forms (individuals) NPS Forms 10-900, 10-900-a, 10-900-b	90	250	22,500	$36.22	$814,950
Preparation and Submission of Nomination Forms (private sector) NPS Forms 10-900, 10-900-a, 10-900-b	5	250	1,250	$34.19	$42,738
Preparation and Submission of Nomination Forms (govt) NPS Forms 10-900, 10-900-a, 10-900-b	5	250	1,250	$49.23	$61,537
Review of Nomination Forms and Submission to NPS (govt)	1,282	6	7,692	$49.23	$378,677
National Register Nominations Prepared by Consultants (individuals) NPS Forms 10-900, 10-900-a	635	120	76,200	$120	$9,144,000
Existing Multiple Property Submission by Consultants NPS Forms 10-900, 10-900-a	75	100	7,500	$120	$900,000
Newly Proposed MPS Cover Document Prepared by Consultants NPS Forms 10-900-a, 10-900-b	36	280	10,080	$120	$1,209,600
New Nominations Prepared and Submitted by Consultants (individuals) NPS Forms 10-900, 10-900-a	1	150	150	$120	$18,000
National Register District Nominations Prepared by Consultants (govt) NPS Forms 10-900-a, 10-900-b	435	230	100,050	$120	$12,006,000
Total	2,564		226,672		$24,575,502

13. Provide an estimate of the total annual non-hour cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected in item 12.)

* The cost estimate 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. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information (including filing fees paid for form processing). Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

* If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

* Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

There are no non-hour cost burdens to respondents.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.

We estimate the annual cost to the government for this collection of information to average $615,884 (rounded).

Table 14.1 below shows the average weighted hourly rate of $66.82 for the Federal staff associated with this information collection. We used the Office of Personnel Management Salary Table 2018-DCB to determine the hourly rates and multiplied the hourly rate by 1.59 to account for benefits in accordance with News Release USDL-18-1499, September 18, 2018, Employer Costs for Employee Compensation—June 2018.

This figure includes the staff time to process and review nominations as well as to administer the information collection. It includes the cost of designing National Register publications and for publishing notification of pending nominations in the Federal Register (as required by public law). A weighted average cost per hour of $78.72 is calculated based on the following assumptions:

1. Total burden hours for logging in/data entry, technical review of historic resources: 1,282 (number of nominations & MPS Covers) x 2 hours = 2,564 hours.

2. Total burden hours for reviewing/evaluating/researching historic resources and nominating properties: 1,282 (number of nominations & MPS Covers) x 4 hours = 5,128 hours.

3. Total burden hours for publishing notices (pending/weekly/DOEs) in the Federal Register 52 (weekly notices) 2 hours = 104 hours.

4. Total annual, recurring cost 7,796 (hours) x $79 (rounded) = $615,884.

Table 14.1. Federal staff weighted hourly rate

Position	GS Level	Hourly Rate*	Hourly Rate incl. benefits (1.59)	Estimated percent of time spent on collection work	Weighted average
Historian (nomination processing)	11/5	$36.95	$58.75	20%	$11.75
Historian (skilled, technical	13/5	$52.66	$83.72	80%	$66.97
					$78.72
* https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2018/DCB_h.pdf

15. Explain the reasons for any program changes or adjustments in hour or cost burden.

There are no program changes.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

Historic names and addresses of properties pending consideration for listing in the National Register are included in the Federal Register weekly upon receipt of the applications by the NPS. This notice is necessary to allow for public comment as required by Federal regulations. A list of properties entered in the National Register is available from the NPS and online through the Internet. State, Federal, tribal, and local governments; libraries; historical societies; educators; scholars; and other individuals use the list as a record of properties as listed in the National Register.

17. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

Nominations prepared using NPS Forms 10-930, 10-930-a, and 10-930-b may be in the preparatory stage (e.g. research, writing and appropriate SHPO/FPO/THPO review) before it is formally submitted to NPS for evaluation. The OMB expiration date causes confusion when the form appears to be expired but the historical documentation related to the nomination remains valid. For this reason, we request not to display the expiration date on the forms.

18. Explain each exception to the topics of the certification statement identified in "Certification for Paperwork Reduction Act Submissions."

There are no exceptions to the certification statement.

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