1024-0277 NPS Christmas Music Program SSA 6.4.2019

SUPPORTING STATEMENT A

FOR PAPERWORK REDUCTION ACT SUBMISSION

NATIONAL CHRISTMAS TREE MUSIC PROGRAM APPLICATION

OMB Control Number 1024-0277

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.

National Park Service (NPS) is granted broad authority by the NPS Organic Act of 1916 (Organic Act) (54 U.S.C. 100101 et seq.; P.L. 113-287), to regulate the use of the park areas under its jurisdiction. Consistent with the Organic Act, as well as the Constitution's Establishment Clause, which mandates government neutrality and allows the placement of holiday secular and religious displays, the National Christmas Tree Music Program's holiday musical entertainment may include both holiday secular and religious music.

The NPS National Christmas Tree Music Program is responsible for collecting applications and selecting groups at random that will perform during the Program’s holiday festivities in President’s Park. Performance groups from schools, choirs, and dance studios apply to contribute their talents and enrich the already memorable experience for park visitors. While the majority of groups are local, we often have groups from across the country and even as far away as Australia perform. For many groups this experience is a significant aspect of their holiday tradition as friends and family come to support them and enjoy President’s Park. To ensure that all groups have a fair opportunity to perform, we collect applications and select groups at random based on their preferred performance dates.

The purpose of this collection is to ensure that any proposed music selection is consistent with the Establishment Clause, and presented in a prudent and objective manner as a traditional part of the culture and heritage of this annual holiday event,. All performances must be approved in advance by the NPS through the application process.

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.

Information collected used to select and schedule performers for the National Christmas Tree Music Program. Information is logistical in nature and is needed to help NPS staff schedule, plan, and publicize each performance. NPS Form 10-942 (“President’s Park National Christmas Tree Music Performance Application” requests the following information:

1. group name and location – needed to include in the printed program for the “Lighting of the National Christmas Tree Ceremony”;

2. name, email, and phone number – needed to contact the music group for additional information or to confirm selection in the music program;

3. preferred performance dates and times – needed to schedule groups based on their preferences and availability;

4. confirmation the musical group has read and understands the “Musical Entertainment Policy” on the application;

5. music selections and song list – needed to ensure group does not exceed 30-minute time limit for their performance;

6. equipment needs – needed to ensure the NPS is prepared to provide the necessary equipment for the group;

7. number of performers – musical groups have a limit of 100 performers due to the size of the stage; and

8. type of group (choir, etc.) – needed to ensure a variety of performers are scheduled at various times throughout the program.

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.

This information is collected using printable form returned by fax or scanned e-mail.

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.

This information is not available elsewhere or otherwise collected by the National Park Service or any other Federal or State agency. Once collected, no additional information is required from the applicant.

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

We estimate receiving responses from seventy-three (73) small entities. There are no additional impacts to small businesses because the completion of the application is in the course of regular business related activities.

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 collection is not conducted, this longstanding music program would be cancelled and the park would receive many negative comments from visitors and previous performers.

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; or

* 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 us to collect the information inconsistent 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 22, 2019, we published in the Federal Register (84 FR 16691) a Notice of our intent to request that OMB renew approval for this information collection. In that Notice, we solicited comments for 60 days, ending on June 21, 2019. We did not receive any comments in response to that notice.

In addition to this Notice, the following individuals outside the agency were contacted to obtain their view and provide comment on the information collection requirements

Table 8.1

Organization	Title
St. John’s Episcopal School	Choral Director
Washington Mennonite Chorus	Chorus Founder
Central Bucks High School-West	Director of Choral Activities
The Trinity Brass	Ensemble director
Cardinal Cloggers	Group director
Private Individual (not representing an organization)	none

We contacted six entities outside the agency, by email, to gather their views about the process we use to collect information for the Christmas Tree Program. Each entity was contacted twice and of those contacted only two responded. The two responses indicated that the information collected was appropriate and necessary and of the respondents provided comments related to the logistics of the music program. The comments supported the NPS’ current logistics practices so no action was necessary. Despite an additional attempt to solicit comments from the remaining individuals, no additional responses were 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.

We do not provide any assurance of confidentiality.

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.

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 receiving 75 applications annually, totaling 19 burden hours. We used the Bureau of Labor Statistics (BLS) News Release USDL-19-0449, March 2019, Employer Costs for Employee Compensation—December 2019, to calculate the total annual burden.

• We used Table 1 to calculate the hourly rate for all civilian workers (service providing) as $35.77, that included the multiplier for benefits.

• We used Table 6 to calculate the hourly rate for all private industry workers (leisure and hospitality) as $46.67, that included the multiplier for benefits.

Table 12.1. Estimated annualize hour burden

NPS Form 10-942, "National Christmas Tree Music Program Application"

ACTIVITY	TOTAL ANNUAL RESPONSES	COMPLETION TIME PER RESPONSE (MINUTES)	TOTAL ANNUAL BURDEN HOURS	HOURLY RATE INCL. BENEFITS	$ VALUE OF ANNUAL BURDEN HOURS*
Individuals	2	15	0.5	$35.77	$18
Private Sector (small businesses)	73	15	18.25	$46.67.	$853
Totals	75		19		$871

*Rounded

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 is no non-hour cost burden 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.

Time necessary to process each music application is approximately 10 minutes. No other operational expenses occur as a result of collecting this information. The total estimated cost to the Federal Government for processing applications is $347.25. We used the Office of Personnel Management Salary Table 2019-DCB. (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/19Tables/html/DCB_h.aspx) to calculate the hourly rate for this collection. To calculate benefits, we multiplied the hourly pay rate by 1.5 in accordance with Bureau of Labor Statistics news release USDL 19-0449.

	Hourly Pay Rate *	Hourly Rate with Benefits *	Average Minutes/ Application	Average Cost/ Application
Park Guide
GS-05/01	$18.19	$27.29	10	$4.63

Total Cost:

75 applications x $4.63 = $347.25

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.

These results will not be published.

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.

We will display the OMB control number and expiration date on the application form and via automated collection on the NPS webpage.

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.