Form87_Suppt.Stmnt._Electric Updated_01-24-2020 -FINAL

2020
SUPPORTING STATEMENT
0572-0051
RUS Form 87, Request for Mail List Data
This package is being submitted under a regular clearance as a revision of a currently
approved information collection package. There was in increase in annual burden hour
costs due to an update to 2018 statistics.
A. Justification
1. Explain the circumstances that make the collection of information necessary.
The Rural Utilities Service (RUS), an agency of the United States Department of Agriculture
(USDA), Rural Development makes loans (direct and guaranteed) to finance electric and
telecommunications facilities in rural areas. The RUS Electric Program provides lending to
upgrade, expand, maintain, and replace the vast rural American electric infrastructure while
the Telecommunications Program makes loans to furnish and improve telecommunications
and services in rural areas. Both Electric and Telecommunications Programs loans are fully
amortized over a period approximately equal to the useful life of the facilities financed by the
loan, not to exceed 35 years and have a typical draw down on approved loan funds over a 3 to
5-year period. There are approximately 620 active electric borrowers and 365 active
telecommunications borrowers 1.
The Rural Utilities Service Administrator, acting on behalf of the United States Secretary of
Agriculture 2, is authorized and empowered by section 2a of the Rural Electrification Act of
1936, as amended (RE Act) to “make loans in the several States and Territories of the United
States for rural electrification and for the purpose of furnishing and improving electric and
telephone service in rural areas, as provided in this chapter, and for the purpose of assisting
electric borrowers to implement demand side management, energy conservation programs,
and on-grid and off-grid renewable energy systems.” In accordance with section 2b of the RE
Act, the Administrator may “make, or cause to be made, studies, investigations, and reports
regarding matters, including financial, technological, and regulatory matters, affecting the
condition and programs of electric, telecommunications, and economic development in rural
areas, and publish and disseminate information with respect to the matters.” The
Administrator signs the official mortgage and loan documents as the Mortgagee on behalf of
the Federal government, and thereby, attests to the feasibility and security of the loan. In
1

A borrower is labeled “active” if one of the following statements is true:
• Has unliquidated obligation amounts
• Has outstanding principal balance
• Has funds in their Cushion to Credit account

2

Delegated as authorized under 7 CFR, Title 7, Subtitle A, Part 2, Subpart A (§2.3)
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order to protect and ensure the Government’s security interest in loans, and in exercise of due
diligence as custodian and guardian of the Government’s interest, in accordance with section
4 for Electric loans and section 201 for Telecommunications loans of the RE act “Loans …
shall not be made unless the Administrator finds and certifies that in his judgment the
security therefore is reasonably adequate and such loan will be repaid within the time
agreed.”
The RUS Loan Agreement with the borrower (Article V, Affirmative Covenants) provides
that the borrower shall furnish to RUS “such other information regarding the condition,
financial or otherwise, or operations of the borrower as the Agency may, from time to time,
reasonably request.”
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.
Both the RUS Electric and Telecommunications programs utilize RUS Form 87 to obtain
names and addresses of the borrowers’ officers/board of directors (president, vice president,
treasurer, and secretary) and corporate officials (manager, attorney, and certified public
accounting firm) authorized to sign official documents and/or to make official representations
concerning borrower operations and management. RUS Form 87 is available in a fillable
Adobe format on the USDA eforms website at
http://forms.sc.egov.usda.gov/efcommon/eFileServices/eForms/RUS87.PDF. At membership
meetings, new board members may be elected, and/or new appointments may be made
concerning corporate officials. Borrowers are also required to submit information to RUS
throughout the year concerning other changes not due to the membership meeting. Electric
and Telecommunications programs borrowers submit the form to the Washington, DC office
and to General Field Representatives. RUS uses the information principally to assure that:
•

Accurate, current, and verifiable information is available to the agency for individual
borrowers as changes occur to a borrower’s board of directors and corporate officials;

•

Correspondence with borrowers is properly directed; and

•

Official documents submitted to the agency, such as loan applications and requests for
advance of loans funds, are signed by the appropriate officials.

The information collected is maintained in accordance with RUS Programs requirements.
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.

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RUS is committed to complying with the requirements of the E-Government Act, to promote
the use of the Internet and other information technologies to provide increased opportunities
for citizen access to Government information and services and for other purposes. RUS Form
87 is posted on the USDA eforms site, at the location cited in section 2 of this document, in
an Adobe PDF fillable format. Individuals may register 3 and obtain an eAuthentication
credential which will enable them to conduct electronic transactions with USDA and,
although customers cannot submit this particular form to the agency electronically, they can
take advantage of using the fillable form provided on the website.
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.
The information contained on the Form 87, Request for Mail List Data form, is specific to,
and available only from, each individual active borrower. The information provided is
collected by the borrower in the course of its business operations and reflects changes
resulting from elections held at annual cooperative membership meetings, retirements, new
appointments, reorganizations, changes in responsibilities, death, etc. As this information is
borrower specific, there is no duplication of information and the information would not be
available from another source.
5. If the collection of information impacts small businesses or other small entities (item
5 of OMB Form 83-1), describe any methods used to minimize burden.
Of the 365 respondents for telecommunications borrowers, 100 percent are small businesses
as they are within the standards established by the SBA for the industry. All but
approximately 10 percent of 620 electric borrowers meet the criteria for a small business.
RUS is conscious of the needs of small entities and has made every effort to ensure that the
burden on these small entities is the minimum necessary to effectively administer the agency
programs. RUS continually reviews the information collected to determine what reductions
are possible in order to minimize burden on each participant of agency’s programs and has
minimized the burden on both small and large entities alike.
6. Describe the consequences to Federal program or policy activities if the collection is
not conducted or conducted less frequently, as well as any technical or legal obstacles to
reducing burden.
RUS requires current information for borrowers’ officials because documents submitted to
the agency by borrowers, e.g., loan applications and requests for advance of loan funds, must
be authorized/signed by borrowers’ appropriate officials. In addition, the agency must
maintain accurate information in order to direct official written communications and have
contact with the appropriate borrower representative. Failure to collect information from
borrowers could result in failure to protect the government’s security interest when
determining eligibility and administering loan programs.
3

https://www.eauth.usda.gov/
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7. Explain any special circumstances that would cause an information collection to be
conducted in a manner:
a. Requiring respondents to report information more than quarterly.
There is no requirement to report more than quarterly.
b. Requiring written responses in less than 30 days.
This form should be submitted as soon as a change in the borrower’s officials occurs.
c. Requiring more than an original and two copies.
The Agency does not request more than one original. A copy is sent to the Washington, DC
office and a copy to the Borrower's General Field Representative.
d. Requiring respondents to retain records for more than 3 years.
There is no requirement to retain records for more than 3 years.
e. That is not designed to produce valid and reliable results that can be generalized to the
universe of study.
This collection does not involve a survey.
f. Requiring use of statistical sampling which has not been reviewed and approved by
OMB.
There is no use of statistical sampling involved with this collection.
g. Requiring a pledge of confidentiality.
There is no requirement of a pledge of confidentiality.
h. Requiring submission of proprietary trade secrets.
There is no such requirement.
8. If applicable, identify the date and page number of publication in the Federal
Register of the agency’s notice soliciting comments on the information collection.
Summarize public comments received and describe actions taken by the agency in
response to these comments. 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, reporting format (if any), and on
data elements to be recorded, disclosed, or reported.

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As required by 5 CFR 1320.8(d), a Notice to request public comments was published in the
Federal Register on December 9, 2019, at 84 FR 67254 (236). The public was given until
February 7, 2020, to submit comments on this proposed collection. The agency received no
comments.
In addition, the agency consulted the following representatives to obtain their opinion
regarding the collection of information and their views on the availability of data, clarity of
instruction, frequency of collection and other concerns or comments. Comments are
summarized below:
Sarah Nottingham, General Manager
Spruce Knob Seneca
Rocks Telephone Inc.
P O Box 100
Riverton, WV 26814
(304)567-2121
Overall the borrower believes the collection of information requested is necessary and not too
burdensome accept that the address requested to be filled in does not specify if the business
address or personal address of the officials are requested.
Lexi Lawson, Executive Assistant
West River Telecommunications Cooperative
101 Main St. West
Hazen, ND 58545
(701) 748-2211
Overall the borrower believes the collection of information requested is necessary and not too
burdensome.
Mr. Timothy Fencl, Manager
Danville Mutual Telephone Company
102 S main Street
P.O. Box 158, Iowa
(319) 392-4251
The borrower stated that the form was no problem at all to complete accept that the address
requested to be filled in does not specify if the business address or personal address of the
officials are requested. The form did not take long to complete maybe 10-15 minutes.

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9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
Payments or gifts are not provided to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for
the assurance in statute, regulation, or Agency policy.
No assurance of confidentiality has been provided to the respondents. This information
collection does not require confidentiality. Information submitted to the agency by borrowers
is covered by provisions of the Freedom of Information Act (5 U.S.C. 552).
11. Provide additional justification for any question of a sensitive nature, such as
sexual behavior or attitudes, religious beliefs, and other matters that are commonly
considered private.
This information collection includes no questions of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information.
Based upon the current Electric Program and Telecom caseload and the number of previous
borrowers, the agency estimates that there are 985 respondents with 985 responses and 246
burden hours. See the attached spreadsheet (RUS Form 36) for complete breakout of burden.
The total cost to respondents is estimated to be $7,697. The estimated wage rate of $20.15 is
based on information from the Bureau of Labor Statistics, median hourly wage for
Information and Records Clerks (Occupation Code 43-4199) 4 . With the addition of cost of
benefits in the amount of $9.22 per hour (31.4% of total compensation of the total hourly
wage is $29.37. The wage rate for calculating respondent cost is selected from the
Department of Labor, Bureau of Labor Statistics, May 2018 National-Industry Specific
Occupational Employment and Wage Estimates for the Telecommunications industry
Typical calculations:
Using data from https://www.bls.gov/news.release/pdf/ecec.pdf
Table 1 calculate the benefit costs as an added percentage of wages and salaries in
order to calculate the total compensation. Note that the published table provides
truncated data which may affect decimal values.

4

https://www.bls.gov/oes/current/oes434199.htm

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Table 1

Total compensation
Cost per hour worked % of total compensation
2018 ............................................................... $36.61………...100%
Wages and salaries
2018 ............................................................... $25.12………....68.6%
Total benefits
2018 ............................................................... $11.48…………31.4%
The wage cost for the collection is summarized as follows:
To calculate the additive percentage representing the benefits from data in the table:
$11.48 (the total benefits) / $25.12 (wages and salaries) = 45.70% (additive
percentage of benefits)
So, as a check $20.15 (Occupation Code 43-4199)4 x (1 + 0.457) = $29.36, the total
compensation
Or, alternatively from the table:
Benefit as percentage of wages = (1 / (1 – total benefits as a percentage of total
compensation)) - 1
Benefit as percentage of wages = (1 / (1 – 31.4%)) – 1 = 45.77%
Then, using the salary and wage data for the applicable professions from
http://www.bls.gov/oes/current/oes_nat.htm\ calculate the total hourly
compensation costs including benefits. For example:
Hourly compensation = mean hourly wage + hourly benefits cost
= mean hourly wage x (1 + benefit as % of wages as
calculated in the equations above)
Cost for Professional Staff preparation time:
Total Professional Cost = (Quantity of responding Borrowers) X (Professional
hourly wage + Benefits loading) X (professional hours per response)
Cost for Clerical time:
Total Clerical Cost = (Quantity of responding Borrowers) X (Clerical hourly wage +
Benefits loading) X (clerical hours per response)
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Total burden cost = Total Professional Cost + Total Clerical Cost
Program

Number of
Respondents

Annual
Responses

Total
hours
155

Wage/
Benefit @
$29.37
$4552

Mailing
Cost @
.49
$303

Electric

620

620

Telecommunications

365

Totals

985

Total
Costs
$4855

365

91

$2663

$179

$2842

985

246

7215

$482

$7697

Completion Costs
Clerical position @ $29.37 hr. X 245 hours =
Mailing Costs – 980 responses X $.49
=

$7215
$482
$7697

13. Provide an estimate of the total annual cost burden to respondents or record
keepers resulting from the collection of information.
(a) Total capital and start-up cost component (annualized over its expected useful
life); and
There are no capital and/or start-up costs associated with this collection.
(b) Total operation and maintenance and purchase of services component.
There are no operation and maintenance and/or purchase of services components associated
with this collection.
14. Provide estimates of annualized cost to the Federal Government.
RUS estimates that the annualized cost to the Federal Government is $ $7710. Each of the
985 responses requires .25 hours of Administrative/Clerical time. The wage rate for
administrative/Clerical wage is (GS 6/5) of $22.98 per hour 5. The fringe benefit cost factor
of 36.25% 6 is applied for total hourly wage cost of $31.31.
Current hourly wages used to calculate federal costs are found on the Office of Personnel
Management General Schedule tables at https://www.opm.gov/policy-dataoversight/pay-leave/salaries-wages/
Total hourly Federal compensation cost = Hourly Wage per OPM table X (1 + benefit
loading percentage)
5
6

https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2017/DCB_h.pdf
The fringe benefit cost factor of 36.25% is applied in accordance with OMB Memorandum M-08 13.

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Total Federal cost = Total hourly Federal Compensation Cost X quantity of hours worked
Estimated cost to the Federal Government:
Admin/Clerical 0.25 hours X $31.31 X 985 responses = $7710 (GS 6/5) with
benefits
15. Explain the reasons for any program changes or adjustments reported in items 13
or 14 of the OMB Form 83-1.
During the last collection period, the number of RUS Electric and Telecommunication
program borrowers increased by 5 from 980 to 985 respondents. This change increased
responses by 5 from 980 to 985 and the estimated hour burden was increased by 1hour. The
increase is a result of the Electric program adding 5 new borrowers to the program.
16. For collection of information whose results will be published, outline plans for
tabulation and publication.
There are no plans to publish the information.
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.
The agency plans to display the expiration date for OMB approval of the information
collection on all instruments.
18. Explain each exception to the certification statement identified in item 19 on OMB
83-1.
There are no exceptions to the certification statement.
B.

Collection of Information Employing Statistical Methods.

This information collection does not employ statistical methods.

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