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August 2, 2021
Supporting Statement for
Paperwork Reduction Act Submissions
OMB Control Number: 1660 - 0070
Title: National Fire Department Registry
Form Number(s): FEMA Form FF-USFA-FY-21-100 – Paper Version (formerly FEMA Form 070-0-0-1)
FEMA Form FF-USFA-FY-21-110 – Online Version
(formerly the screenshots of FEMA Form 070-0-0-1)
A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(1)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When Item 17 or the OMB Form 83-I is checked “Yes”, Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.
Explain the circumstances that make the collection of information necessary.
Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information. Provide a detailed description of the nature and source of the information to be collected.
The Federal Fire Prevention and Control Act of 1974 (Public Law 93-498) provides for the gathering and analyzing of data as deemed useful and applicable for fire departments. The National Fire Department Census evolved from recommendations of the Blue Ribbon Panel. In the spring of 1998, the Director of the Federal Emergency Management Agency (FEMA) convened a Blue Ribbon Panel of prominent members of the U.S. fire service to review the structure, mission, and purpose of the U.S. Fire Administration (USFA) and to make recommendations for the future of the Federal fire focus. The Blue Ribbon Panel noted the lack of a comprehensive list of fire departments and baseline data for the definition of the composition, capabilities, and activities of the nation's fire service. Their recommendation was for the USFA to develop a fire department census.
The action report requests the following: “Develop a fire service census that captures demographic information that will help clarify the perception issue and establish baselines and benchmarks for USFA activities, and identify and maintain the demographics of fire departments in the United States by conducting a fire services census.”
From 2001 to 2016, the number of registered fire departments grew from about 16,000 to over 27,000. Because the census was cumulative over time, it did not reflect a typical census in the way that the data were collected. As a result, in the fall of 2016, the USFA renamed the census to the National Fire Department Registry.
USFA receives many requests from fire service organizations and the public for information related to fire departments, including total number of departments, number of stations per department, population protected, and number of firefighters. Additionally, USFA maintains the registry for the purpose of disseminating fire safety and prevention information to fire departments across the country.
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. Provide a detailed description of how the information will be shared, if applicable, and for what programmatic purpose.
The USFA is working to identify all fire departments in the United States to develop a database that includes information related to their demographics, capabilities, and activities. The database is used by the USFA to guide programmatic decisions and to provide the Fire Service and the public with information about fire departments. Additionally, USFA maintains the registry database for disseminating critical fire safety and prevention information to departments. The Critical Infrastructure Protection (CIP) program uses the registry for the purpose of distributing sensitive information to senior fire and EMS personnel.
A fire department database was developed and populated with the responses and made available to the public for online look-ups through the USFA Web site. The database contains fields included on the registry form instrument with the exception of the name and contact information of the individual completing the form and the specialized services fields. Information collected to date (27,225 departments) is being used as described. The data is updated typically every five years based on current experience. Updates can be executed at any time online through the USFA Web site, or can be mailed, e-mailed or faxed via the paper-version questionnaire.
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.
Fire department personnel are able to complete the registry form online through the USFA Web site: https://apps.usfa.fema.gov/registry/. Fire department personnel can also complete the paper form and fax, mail, or e-mail the completed form. Instructions for completing the form are provided online or included in the cover letter accompanying the paper form. For the initial responses, about 90 percent of the completed forms are submitted online. For periodic data updates, about 95-100 percent of the updates are submitted online.
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.
A nationwide search for existing databases was conducted, and it was determined that existing databases were either well short of the estimated 30,000 fire departments (based on the National Fire Protection Association (NFPA) annual average estimate of fire departments), or they did not have the demographic information necessary for future sample surveys, which are not part of this effort. Existing mailing lists are combined and geocoded to avoid duplicate mailings to identify every fire department possible.
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize.
This information collection has an impact on small entities, however, USFA mitigates that impact. Of the 27,225 fire departments participating in the National Fire Department Registry, the USFA estimates that 26,408, or 97 percent,[1] are considered small entities.[2] The USFA mitigates the impact of this information collection by providing two options for submitting information—fully web-based entry or paper forms entry which reduces the burden to all departments that are voluntarily reporting the data. Department inclusion in the National Fire Department Registry consists of a one-time initial registration. The online database allows fire department personnel to access previously submitted data to provide additional updates so the initial registration information does not need to be resubmitted.
6. Describe the consequence to Federal/FEMA program or policy activities if the collection of information is not conducted, or is conducted less frequently as well as any technical or legal obstacles to reducing burden.
The Agency’s ability to conduct future studies will be severely limited if USFA does not conduct or maintain the fire department registry. The ability to assess current needs of the fire service based on services currently provided will also be limited. Additionally, without this collection of information, it would severely limit USFA’s ability to provide critical information to senior fire and emergency medical services personnel.
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.
(b) 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.
(f) Requiring the use of a statistical data classification that has not
been reviewed and approved by OMB.
(g) 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.
(h) 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.
8. Federal Register Notice:
a. Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice soliciting comments on the information collection prior to submission to OMB. Summarize public comments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.
A 60-day Federal Register Notice inviting public comments was published on April 27, 2021, at 86 FR 22235. No comments were received.
A 30-day Federal Register Notice inviting public comments was published on August 2, 2021, at 86 FR 41504. The public comment period is open through September 1, 2021.
b. 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.
Several organizations were contacted to identify the type of information they collect about fire departments nationwide. These organizations were asked if they collected similar information and were also asked about the numbers of fire departments included in their databases. Organizations contacted included the NFPA, Insurance Services Office (ISO), State Fire Marshal’s Offices, as well as several commercial vendors that maintain fire department mailing lists.
c. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.
Consultation with fire department personnel from whom information is obtained is continuous. The USFA Web page includes a contact us form in which respondents can provide comments regarding the forms and clarity of instructions (https://www.usfa.fema.gov/contact.html). Most of the comments received from respondents involve questions about how to obtain their Fire Department Identification Number (FDID) number. Information regarding how to obtain FDID numbers is included on the Register Online page and the registry update letter.
9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
FEMA does not provide payments or gifts to respondents in exchange for a benefit sought.
10. Describe any assurance of confidentiality provided to respondents. Present the basis for the assurance in statute, regulation, or agency policy.
A Privacy Threshold Analysis (PTA) was completed by FEMA and adjudicated by the DHS Privacy Office on January 26, 2021 and is still valid (expires January 26, 2024).
The National Fire Department Registry is a privacy sensitive collection requiring Privacy Impact Assessment, PIA coverage. This collection is covered by PIA, DHS/ALL/PIA – 006, Department of Homeland Security General Contact Lists, approved by DHS on June 15, 2007. SORN coverage is not necessary. A privacy notice is included on the collection form.
There are no assurances of confidentiality provided to the respondents for this information collection.
11. Provide additional justification for any question 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.
There are no questions of a sensitive nature.
12. Provide estimates of the hour burden of the collection of information. The statement should:
a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated for each collection instrument (separately list each instrument and describe information as requested). 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 desired. 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.
Most of the responses are from volunteer fire departments. For 2018, the NFPA estimated that 81.9 percent of fire departments were volunteer departments and the remaining 18.1 percent of fire departments were considered career (or paid) departments.
It is anticipated that 2,775 fire departments will complete the initial National Fire Department Registry form using FEMA Form FF-USFA-FY-21-100 (formerly FEMA Form 070-0-0-1) or FF-USFA-FY-21-110 (formerly the screenshots of FEMA Form 070-0-0-1) resulting in 925 fire department responses annually over three years (i.e., 925 x 0.181 = 167 career departments and 925 x 0.819 = 758 volunteer departments). Personnel from each fire department will complete the form once and each response will require 0.4167 hours (i.e., 25 minutes) to complete the form. The average burden per response of 25 minutes applies to both the completion of the paper form and the online form. The total annual hour burden for initial responses is 925 x 0.4167 = 385 hours.
Approximately 20 percent (5,445 departments) of the current registrants are contacted by the USFA on a rotating basis each year. Fire department personnel are asked to update the information for their fire department. This results in each fire department being contacted by the USFA about once every five years to supply registry data updates. This ensures that USFA has the most up to date information as possible regarding the registered departments. With the establishment of the online database, however, fire departments may provide the USFA with data updates at any time.
It is anticipated that 5,445 fire departments (i.e., 5,445 x 0.181 = 986 career departments and 5,445 x 0.819 = 4,459 volunteer departments) will provide updates to their current data each year. For the updates, fire departments do not need to resubmit the entire form since the data already exist online. The departments access the data online and then only need to change those items that need to be updated. Each updated response will require .1667 hours (i.e., 10 minutes). The total annual hour burden for the updated responses is 5,445 x .1667 hours = 908 hours.
The total annual hour burden for the initial responses and updated responses is 385 hours + 908 hours = 1,293 hours.
FEMA Form FF-USFA-FY-21-110 was formerly the screenshots of the form FEMA Form 070-0-0-1 when the respondent fire department used USFA’s online portal to either register or update their registration. These screenshots were given their own form number as part of FEMA’s general overhaul of our form numbering system and all burden hour assessments are incorporated with FF-USFA-FY-21-100 (formerly FEMA Form 070-0-0-1) because there is no difference in average burden per response between the two and there is only the administrative difference based on FEMA’s numbering overhaul.
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Estimated Annualized Burden Hours and Costs |
|||||||
Type of Respondent |
Form Name / Form No. |
No. of Respondents |
No. of Responses per Respondent |
Total No. of Responses |
Avg. Burden per Response (in hours) |
Total Annual Burden (in Hours) |
Avg. Hourly Wage Rate |
Total Annual Respondent Cost |
State, Local, or Tribal Government (Career, Full Registration) |
National Fire Department Registry / FEMA Form FF-USFA-FY-21-100 or FF-USFA-FY-21-110 |
167 |
1 |
167 |
0.4167 |
70 |
$42.57 |
$2,980 |
State, Local, or Tribal (Volunteer, Full Registration) |
National Fire Department Registry / FEMA Form FF-USFA-FY-21-100 or FF-USFA-FY-21-110 |
758 |
1 |
758 |
0.4167 |
316 |
$0.00 |
$0 |
State, Local, or Tribal Government (Career, Update) |
National Fire Department Registry / FEMA Form FF-USFA-FY-21-100 or FF-USFA-FY-21-110 |
986 |
1 |
986 |
0.1667 |
164 |
$42.57 |
$6,981 |
State, Local, or Tribal (Volunteer, Update) |
National Fire Department Registry / FEMA Form FF-USFA-FY-21-100 or FF-USFA-FY-21-110 |
4,459 |
1 |
4,459 |
0.1667 |
743 |
$0.00 |
$0 |
Total |
|
6,370 |
|
6,370 |
|
1,293 |
|
$9,961 |
b. If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in Item 13 of OMB Form 83-I.
While this request covers two forms, the respondents can use either form at their discretion and have the exact same burden cost. The chart is separated by whether the respondents are a career or a volunteer fire department and whether they are performing a full registration or just an update, as that is where we find actual differences in burden hour calculations.
c. Provide an estimate of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. NOTE: The wage-rate category for each respondent must be multiplied by 1.62 and this total should be entered in the cell for “Avg. Hourly Wage Rate”. The cost to the respondents of contracting out or paying outside parties for information collection activities should not be included here. Instead this cost should be included in Item 13.
As previously noted in 12a, most of the responses will be from volunteer fire departments for which no direct labor costs will be incurred. Volunteer firefighters receive no compensation for their services. The minimal direct labor cost of a single firefighter or emergency service worker completing the registry form only applies to those fire departments and emergency service agencies with career (or paid) firefighters. For 2018, the NFPA estimated that 18.1 percent of fire departments were career departments.
According to the U.S. Department of Labor, Bureau of Labor Statistics1, the May 2020 Occupational Employment and Wage Estimates wage rate for firefighters (SOC 33-2011) is $26.28. Including the wage rate multiplier2 of 1.62, the fully-loaded wage rate is $42.57 per hour. Therefore, the annual burden hour cost is estimated to be $9,961 annually ($42.57 x 234 hours = $9,961).
For the updates, fire departments do not need to re-complete the entire form. The data already exist online. The departments access the data online and then only need to change those items that need to be updated. Thus, the estimated burden hour cost to career State,
13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. (Do not include the cost of any hour burden shown in Items 12 and 14.)
Annual Cost Burden to Respondents or Recordkeepers |
||||
Data Collection Activity/Instrument |
*Annual Capital Start-Up Cost (investments in overhead, equipment, and other one-time expenditures |
*Annual Operations and Maintenance Costs (such as recordkeeping, technical/professional services, etc.) |
Annual Non-Labor Cost (expenditures on training, travel, and other resources) |
Total Annual Cost to Respondents |
N/A |
$0 |
$0 |
$0 |
$0 |
Total |
$0 |
$0 |
$0 |
$0 |
The cost estimates should be split into two components:
a. Operation and Maintenance and purchase of services component. These estimates should take into account cost associated with generating, maintaining, and disclosing or providing information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred.
There are no operation and maintenance costs associated with this information collection.
b. Capital and Start-up-Cost should include, among other items, preparations for collecting information such as purchasing computers and software, monitoring sampling, drilling and testing equipment, and record storage facilities.
There are no record keeping, capital, start-up or maintenance costs to respondents associated with this information collection.
14. Provide estimates of annualized cost to the federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing and support staff), and any other expense that would have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.
Annual Cost to the Federal Government |
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Item |
Cost ($) |
Contract Costs [Contract: annual cost to maintain Registry is $16,786] |
$16,786 |
Staff Salaries: One GS 11, step 5 employee in Washington, D.C. spending approximately 15% of time annually maintaining database records for this data collection. One GS 13, step 5 employee in Washington, D.C. spending approximately 10% of time annually monitoring database records maintenance. [[1 x $82,453 x 0.15 x 1.45] + [1 x $117,516 x .10 x 1.45]] = $34,973 |
$34,973 |
Facilities [cost for renting, overhead, etc. for data collection activity] |
$0 |
Computer Hardware and Software [cost of equipment annual lifecycle] |
$0 |
Equipment Maintenance [cost of annual maintenance/service agreements for equipment] |
$0 |
Travel |
$0 |
Printing [925 data collection instruments and cover letters annually; 5,445 update letters annually] |
$310 |
Postage [(925+5,445) x .55] |
$3,504 |
Total |
$55,573 |
1 Office of Personnel Management 2021 Pay and Leave Tables for the Washington-Baltimore-Arlington, DC-MD-VA-WV-PA locality. Available online at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/21Tables/html/DCB.aspx. Accessed July 13, 2021. 2 Wage rate includes a 1.45 multiplier to reflect the fully-loaded wage rate. |
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Contract costs of $16,786 include a contractor to annually maintain the registry [total contractor cost is $839,287.10 per year ($769,287.10 Support Services + $70,000 Content Management/Storage); the registry accounted for two percent of the total work performed by the team for a total of $16,786]. The cost for staff salaries is $34,973 which includes one Federal employee at a GS-11, step 5 level (15% of the employee’s time is spent on the registry project) to maintain the database and prepare mailings and one employee at a GS-13, step 5 level (10 % of the employee’s time is spent on the registry project) to monitor database maintenance. Additional costs include printing and postage totaling $3,814 ($310 + $3,504). The total annual cost burden to the Federal Government is $55,573.
15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I in a narrative form. Present the itemized changes in hour burden and cost burden according to program changes or adjustments in Table 5. Denote a program increase as a positive number, and a program decrease as a negative number.
A “Program increase” is an additional burden resulting from a federal government regulatory action or directive. (e.g., an increase in sample size or coverage, amount of information, reporting frequency, or expanded use of an existing form). This also includes previously in-use and unapproved information collections discovered during the ICB process, or during the fiscal year, which will be in use during the next fiscal year.
A “Program decrease”, is a reduction in burden because of: (1) the discontinuation of an information collection; or (2) a change in an existing information collection by a Federal agency (e.g., the use of sampling (or smaller samples), a decrease in the amount of information requested (fewer questions), or a decrease in reporting frequency).
“Adjustment” denotes a change in burden hours due to factors over which the government has no control, such as population growth, or in factors which do not affect what information the government collects or changes in the methods used to estimate burden or correction of errors in burden estimates.
Itemized Changes in Annual Burden Hours |
||||||
Data Collection Activity/Instrument |
Program Change (hours currently on OMB inventory) |
Program Change (new) |
Difference |
Adjustment (hours currently on OMB inventory) |
Adjustment (new) |
Difference |
National Fire Department Registry/ FEMA Form FF-USFA-FY-21-100 or FF-USFA-FY-21-110 |
0 |
0 |
0 |
2,067 |
1,293 |
-774 |
Total |
0 |
0 |
0 |
2,067 |
1,293 |
-744 |
Explain:
There is a decrease of 774 burden hours from the current OMB inventory of 2,067. This difference is a negative adjustment as fewer fire departments are needed to complete the remaining registry database. Since the National Fire Department Registry is a one-time initial registration and this is a continuing collection, fewer fire departments (respondents) are needed to meet the objective of this collection which is to incorporate into the database all 30,000 fire departments nationwide. With the continuing collection effort, about 91 percent of the desired respondents are currently registered. The primary continued use of this form is to collect information from the remaining estimated 2,775 fire departments. Follow-up information is also provided from approximately 20 percent of previously registered departments each year on a rotating basis over a five-year period.
FEMA also noticed while preparing this extension that the summary of burden numbers on the IC List in ROCIS were not updated to match the Supporting Statement A in 2019. The correct numbers found in the Supporting Statement A were an estimated 8,223 annual responses and 2,067 annual burden hours, but they appeared in ROCIS’s IC List (and therefor the Notice of Action) as 7,787 annual responses and 1,887 annual burden hours. This is 436 responses and 180 burden hours less than they should have been listed. FEMA’s calculations started with the previous numbers in the Supporting Statement A and with this extension request, FEMA is correcting the previous technical error in ROCIS.
Itemized Changes in Annual Cost Burden
Itemized Changes in Annual Cost Burden |
||||||
Data Collection Activity/Instrument |
Program Change (cost currently on OMB inventory) |
Program Change (new) |
Difference |
Adjustment (cost currently on OMB inventory) |
Adjustment (new) |
Difference |
[Form Name/#] |
|
|
|
|
|
|
Total |
$0 |
$0 |
$0 |
$0 |
$0 |
$0 |
Explain:
There is no cost burden for this collection.
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.
There are no outlying plans for tabulation and publication of data for this information collection.
17. If seeking approval not to display the expiration date for OMB approval of the information collection, explain reasons that display would be inappropriate.
This collection does not seek approval to not display the expiration date for OMB approval.
18. Explain each exception to the certification statement identified in Item 19 “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.
FEMA does not request an exception to the certification of this information collection.
B. Collections of Information Employing Statistical Methods.
There is no statistical methodology involved in this collection.
[1][1] See NFPA, U.S. Fire Department Profile 2018, (2020), https://www.nfpa.org/-/media/Files/News-and-Research/Fire-statistics-and-reports/Emergency-responders/osfdprofile.pdf.
[2][2] See 44 U.S.C. 3506, 5 U.S.C. 601.
1 Information on the mean wage rate from the U.S. Department of Labor, Bureau of Labor Statistics is available online at: https://www.bls.gov/oes/2020/may/oes_nat.htm
2 Bureau of Labor Statistics, Employer Costs for Employee Compensation, Table 1. “Employer costs per hour worked for employee compensation and costs as a percent of total compensation: Civilian workers, by major occupational and industry group, March 2021.” Available at https://www.bls.gov/news.release/archives/ecec_06172021.pdf. Accessed June 24, 2021. The wage multiplier is calculated by dividing total compensation for State and local government workers of $53.68 by Wages and salaries for State and local government workers of $33.20 per hour yielding a benefits multiplier of approximately 1.62
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Modified | 0000-00-00 |
| File Created | 2021-10-28 |