2021201 draft v2.0 AMJP PRA renewal Supporting Statement

DEPARTMENT OF TRANSPORTATION
INFORMATION COLLECTION
SUPPORTING STATEMENT
Agency Request for Renewal and Revision of Previously Approved Information Collection
of Information Associated with the Aviation Manufacturing Jobs Protection (AMJP)
program
(Part of the American Rescue Plan Act of 2021)
OMB Control #2106-0048
INTRODUCTION
This is to request the Office of Management and Budget’s (OMB) renewal and revision of
previously approved information collection required in support of the Aviation Manufacturing
Jobs Protection (AMJP) program, which is required as part of the “American Rescue Plan Act of
2021” (ARPA), Public Law (P.L.) 117-2, enacted on March 11, 2021.
Part A. Justification
1.

Circumstances that make the collection of information necessary.

On March 11, 2021, ARPA was enacted. The ARPA included subtitle B of title VII, establishing
the “Aviation Manufacturing Jobs Protection” (AMJP) program. The stated purpose of the
program is “to provide public contributions to supplement compensation of an eligible employee
group” (which is defined in the statute), by entering into agreements with qualified business
entities (outlined in Section 2), to pay up to half of the payroll costs for that group of employees
for up to six months, in return for several commitments, including a commitment that the
company will not involuntarily furlough or lay off employees within that group.
Business entities eligible to apply are those that either build aircraft or aircraft components, or
that provide maintenance, repair and overhaul services. To receive funding, businesses must
meet all of the requirements set forth in the law. Therefore, DOT must collect certain
information from applicants to determine eligibility. DOT must also verify the accuracy of
specific payment requests from approved applicants, in accordance with other laws and
regulations governing Federal financial assistance programs, including (but not limited to) the
Antideficiency Act, the Federal Funding Accountability and Transparency Act (FFATA), the
Payment Integrity Information Act of 2019, and 2 CFR Part 200, among others.
All of the agreements must be established within a six-month period (i.e., from the effective date
of the first agreement, DOT has only six months before all remaining agreements must be in
place).
Accordingly, DOT developed an expedited process and a system that enabled businesses to apply
for financial assistance under the AMJP. DOT used an online, web-based system to collect the

required information.
This program also meets the criteria of Executive Order 14002.
2.

How, by whom, and for what purpose is the information to be used.

Individual companies deemed eligible for AMJP funds (referred to hereafter as “the recipient”),
must enter into agreements with the DOT. These agreements require the recipient to provide
information related to compensation for their designated Eligible Employee Group (EEG) during
the period of the agreement with DOT. DOT will use an online, web-based system to collect the
following information necessary for DOT to evaluate payment requests from program recipients:
•

Recipient business name and changes to the EEG that may affect the public contribution
amount (and an explanation of the reason for the change). Employee information will be
protected by the employer and not include personally identifiable information (PII).

•

Explanation of why a member of the EEG was replaced by a new employee and
compensation comparisons between old and new EEG member(s).

•

Description and justification of employment actions, such as layoffs or furloughs, within
the company but which do not impact the EEG.

•

In the case of an interim payment request, the company would need to provide financial
data proving allowable costs incurred are greater than previous payments received, and
that the cumulative amount requested would not be greater than 90% of the estimated
public contribution.

•

Redacted EEG payroll reports including job category, compensation level, pay frequency,
and any actions affecting the size or composition of the EEG.

•

See Forms: AMJP-1A.2.2, AMJP-1A.2.3, AMJP-1A.2.4, AMJP-1A.6.4, AMJP-1A.6.5,
AMJP-1A6.6, AMJP-1A.6.7 for more details.

•

Recipients will be required to provide supporting documentation in sufficient detail to
substantiate the actual costs, specifically excluding any Personally Identifiable
Information (PII) for any individual employees, in support of disbursement requests.

•

DOT may also ask recipient businesses to submit voluntary reports regarding
demographic data associated with the workforce that is and is not included in the Eligible
Employee Group. This would be voluntary on the part of the employer and based solely
on data self-reported by employees, disaggregated from any Personally Identifiable
Information in order to avoid any potential privacy concerns. If a statistically valid
sample can be developed, then it may be possible to extrapolate for reporting and
program evaluation purposes. Such information may be used to support program
evaluation.

•

3.

DOT may also ask recipient businesses to identify how they first learned about the AMJP
program. Such information may be useful in implementation of future financial
assistance programs.
Extent of automated information collection.

DOT anticipates using an online, web-based system to collect all the necessary data and
supporting documentation. This will reduce costs for applicants as well as eliminate the risk of
hard-copy documentation getting lost, delayed, or delivered to incorrect addresses. The system
will enable applicants to save their work frequently and easily upload supporting documentation.
DOT uses the GrantSolutions platform (https://www.grantsolutions.gov) as the online data
collection and record keeping platform for the AMJP program. Applications were uploaded into
GrantSolutions, communications between DOT reviewers and applicants were recorded in the
system, and additional supporting documents are saved within. Therefore, the recipient
companies already have established account access and are familiar with the GrantSolutions
system. DOT has decided to continue using GrantSolutions to collect subsequent data required to
review payment requests and authorize payments. Recipients will be expected to upload the
necessary forms and supporting documentation.
4.

Describe efforts to identify duplication.

By using the same data collection platform during the application and post-award phase,
GrantSolutions, DOT has streamlined the reporting process for recipient companies, eliminating
the need to manage and learn multiple logins and systems. This also reduces the risk of
redundant disbursements or other errors. In addition, in Form AMJP-1A.6.5 (“AMJP Recipient
Notification to USDOT of EEG Composition”), DOT requires the applicant to assign a unique
identification number to each employee in the Eligible Employee Group, in order to streamline
reconciliation efforts throughout the life-cycle of each award.
5.

Efforts to minimize the burden on small businesses.

In order to help reduce the burden on recipients (and particularly on small businesses), DOT
decided to make an initial disbursement shortly after award of each agreement. The initial
disbursement is up to 50 percent of the award amount. This provides the recipient businesses
with an immediate cash infusion, while also reducing the total number of disbursements and the
cumulative paperwork required.
6.

Impact of less frequent collection of information.

DOT carefully considered the impacts of shifting from monthly disbursement requests to an
approach involving an initial and final disbursement and giving recipients the option to request
an interim reimbursement. This results in fewer opportunities to monitor the rate at which
recipients are incurring allowable costs. However, DOT is requiring periodic reports from
higher-risk recipients, so that DOT can identify emerging issues or trends earlier than otherwise,
and DOT has built in safeguards to minimize the risk of having to recover funds from recipients.

7.

Special Circumstances.

No special circumstances apply to this collection.
8.

Compliance with 5 CFR 1320.8(d).

DOT has published a notice in the Federal Register at [insert link] notifying the public of the
intent to seek approval for this renewed and revised information collection.
In addition, almost immediately after enactment of ARPA on March 11, 2021, various
associations representing U.S. aircraft manufacturers and repair stations began contacting DOT
via letters, phone calls, and emails to provide input on every aspect of implementation of the
Aviation Manufacturing Jobs Protection (AMJP) program. In one notable instance, a letter
arrived bearing the logos and signatures of 12 separate associations. Likewise, letters from
various Members of Congress expressed their views about the program.
The primary concern expressed by stakeholders was the urgency of implementing the AMJP
program as swiftly as possible, due to the extreme financial hardships affecting the industry.
DOT consistently pointed out that the Paperwork Reduction Act requirements would need to be
met before beginning the application process. Particularly because the statutory provisions
governing both eligibility and magnitude of financial assistance under the AMJP required data
from applicant businesses that was not publicly available, the new information to be collected
necessitated emergency PRA procedures be followed.
At the same time, DOT quickly determined that one key step that many prospective applicants
would have to take involved registering in the System for Award Management (SAM).
Accordingly, 34 days after enactment, DOT published a set of dedicated webpages on the DOT
website, highlighting the most urgent information for prospective applicants, including the need
to secure a DUNS number and register in SAM. DOT issued a press release on that same day,
and sent copies of that press release out through the established Small Business Office
distribution lists maintained by both DOT and the FAA. This gave prospective applicants two
full months of advance notice to get registered in SAM while DOT continued developing the
application process.
Additionally, on the same date, DOT published a Federal Register notice announcing its intent to
request emergency approval from OMB for the new information collection.
These early steps elicited additional feedback from stakeholders. Two sets of comments were
formally submitted in response to the April 14 Federal Register notice. However, phone calls
and emails continued to come in, and DOT carefully listened to input and feedback. These
contacts came from individual businesses that were interested in applying, and association
representatives or consultants representing prospective applicants.
DOT seized the opportunity to talk with anyone who called and made note of all such input. This
information played a key role in how DOT implemented the application process. In one notable

example, stakeholders emphasized the importance of keeping the application process as simple
as possible, while also recognizing that applicants would range in size from very small familyowned businesses with fewer than 10 employees, to large, complex international corporations
with more than 100,000 employees. Stakeholders also highlighted the fact that the types of
documentation prepared by publicly held corporations (e.g., SEC filings, audited financial
reports, etc.) would not exist for unincorporated sole proprietorships. Stakeholders also
emphasized the value of integrating the required forms with the instructions, so that applicants
would not have to consult multiple documents simultaneously. DOT took all of this input into
consideration and designed the application process accordingly.
Likewise, some stakeholders expressed concern about the financial constraints on applicants,
especially if they had to file monthly disbursement requests and then wait until DOT was able to
process them. Stakeholders highlighted this could prevent some businesses from swiftly rehiring
or recalling employees who had been laid off or furloughed. Accordingly, DOT decided (and
announced in mid-June 2021 in the AMJP application package) that DOT would make an initial
disbursement shortly after award of the AMJP agreements, of up to 50 percent of the award
amount. This helps recipient businesses make swift decisions to help retain their existing
workforce as well as rehiring or recalling laid-off employees.
DOT also established dedicated help lines (via both phone and email) for anyone with questions
about the AMJP program and/or the application process. DOT responded to several hundreds of
inquiries, ranging from general questions about purpose and eligibility for the program to details
about the application process. The process of reviewing and responding to those questions gave
DOT valuable insights into the types of information that prospective applicants needed and could
readily provide to DOT.
DOT used those insights to develop a series of three publicly available webinars, all of which
were recorded and remain available for public access on DOT’s website with the accompanying
presentation materials. Participants were able to submit questions through a live portal and DOT
addressed as many as they could during the live program, and then addressed the remaining
questions through other communication mechanisms. Additionally, DOT issued numerous largescale distribution emails, each to more than 10,000 representatives of prospective applicants.
These mass communications were triggered by urgent program clarifications or critical updates
to the application process. Those email messages invariably led to further inquiries from
prospective applicants, which DOT took into consideration in subsequent program
implementation decisions.
9.

Payment or gifts to respondents.

Not applicable.
10.

Assurance of confidentiality.

DOT will protect data submitted by applicants for the AMJP program consistent with the
Freedom of Information Act (FOIA) and DOT’s regulations implementing the FOIA. DOT has
also emphasized repeatedly (in the Federal Register notices, on the DOT website, and in the

forms that DOT has created) that applicants must not include any Personally Identifiable
Information (PII) for any individual employees.
11.

Justification for collection of sensitive information.

Not applicable. None of the data required for this collection meets the stated criteria as being
sensitive.
As noted above, DOT may also ask recipient businesses to submit voluntary reports regarding
demographic data associated with the workforce that is and is not included in the Eligible
Employee Group. This would be voluntary on the part of the employer, and based solely on data
self-reported by employees, disaggregated from any Personally Identifiable Information in order
to avoid any potential privacy concerns.
12.

Estimate of burden hours for information requested.

DOT originally estimated as many as 4,900 applications. Initially, DOT received only 384
applications. DOT then reopened the application process for another four-week period, and
received another 191 applications. Those figures reflect some duplicate or replacement
applications. To be conservative, DOT is rounding the figure up to 600 applications in total.1
All of the information required to complete the application process should have been readily
available to the applicant, with the exception of the internal calculations needed to define the
Eligible Employee Group and the associated compensation costs. DOT originally estimated that
the application process itself could require up to 9 hours, plus 1 hour to assemble the necessary
documentation to support eligibility criteria, plus 2 hours to complete the online application
process. That equated to a total of 12 hours. Based on anecdotal observations and the nature of
questions received, DOT has now increased that estimate to 16 hours.

In addition to the application submission, DOT originally estimated it could take up to 2 hours to
prepare each disbursement request, and that there could be as many as 6 disbursement requests
(once monthly for the maximum 6-month duration of each agreement). DOT subsequently
decided to make an initial disbursement of up to 50 percent of the award amount, and a final
disbursement, and to give recipients the option to request an interim disbursement. Accordingly,
1

DOT published the 60-day renewal notice on September 21, 2021. At that time, DOT believed that the application
process had been concluded. Therefore, DOT no longer included figures associated with the AMJP application
process (which DOT had included in the original request for emergency approval published on April 14, 2021).
DOT subsequently reopened the application process for a third and final round, with an application deadline of
December 13, 2021. If another 150 applicants apply, then this would represent an additional burden of 2,400 hours
at an estimated cost of $89,740.50.

DOT increased the estimated workload for the interim and final disbursements, but reduced the
number of disbursements to just two (2) for which the recipient has to take any action:

In addition to the application and disbursement requests, and consistent with the original notice,
DOT has established additional reporting requirements during the period of performance,
including:
•
•
•
•
•
•
•

Form AMJP-1A.2.2 (“AMJP Recipient Report to USDOT of Employment Action
Affecting the Eligible Employee Group”)
Form AMJP-1A.2.3 (“AMJP Recipient Report to USDOT of Replacement in the Eligible
Employee Group”)
Form AMJP-1A.2.4 (“AMJP Recipient Report to USDOT of employment action not
affecting the Eligible Employee Group”)
Form AMJP-1A.6.4 (“AMJP Recipient Request for Interim Payment”)
Form AMJP-1A.6.5 (“AMJP Recipient Notification to USDOT of EEG Composition”)
Form AMJP-1A.6.6 (“AMJP Recipient Interim Financial Report”)
Form AMJP-1A.6.7 (“AMJP Recipient Final Financial Report”)

The assumptions and resulting burden calculations for each of these forms is addressed below:

DOT estimates it could take up to 4 hours to prepare the final closeout documentation:

In addition, DOT may ask recipients to submit a voluntary form (either SF-100 or a facsimile
thereof), providing demographic data, based solely on data self-reported by employees. DOT
may also ask recipients to identify how they first heard about the AMJP program.

Therefore, the total estimated burden hours and costs would be:

13.

Estimate of the total annual costs burden.

Estimated labor costs for applicants are included in Section 12. There should be no other cost to
applicants because they should already have all of the information needed, and there should be
no additional costs required.
14.

Estimates of costs to the Federal Government.

DOT plans to use a combination of Federal and contract personnel to review applications and
process subsequent disbursement requests.

As noted above, DOT originally anticipated monthly disbursement requests (one per applicant
for each month of the maximum 6-month duration of the agreements), but subsequently revised
that to an initial disbursement, an interim disbursement, and final disbursement. The initial
disbursement is a simple calculation across all recipients—50 percent of the award amount.
Therefore, only the interim and final disbursement drive any significant workload for the
government or its support contractor:

DOT will rely upon a combination of contractor and Federal personnel to review the forms. The
assumptions and resulting cost calculations for each of these forms is addressed below:

If DOT asks recipients to submit a voluntary form (either SF-100 or a facsimile thereof),
providing demographic data, then DOT will review and compile the resulting data, with the
following estimated costs:

Finally, DOT anticipates requiring a simple closeout process for each agreement:

In summary:

In addition, DOT incurred initial costs to acquire and configure the web-based tools that will be
used to manage the entire application, evaluation, award, disbursement and documentation
process. DOT does not yet have a complete estimate for this cost, but it is very likely that
between internal labor, contract support, and acquisition, configuration and operation of the
existing GrantSolutions system for this purpose, DOT may need to use the full amount allowed
for in the statute (up to 1% of the $3 billion appropriated, or $30 million overall).
15.

Explanation of the program change or adjustments.

Not applicable—this is a new program.
16.

Publication of results of data collection.

DOT anticipates publishing the list of approved applications including the maximum eligible
amounts, the estimated amounts to be paid (reflecting any pro-rata reduction if necessary), and
actual disbursements as soon as practicable after the data has been verified.
17.

Approval for not displaying the expiration date of OMB approval.

Not applicable. DOT is not seeking approval to not display the expiration date for OMB approval
of the information collection.
18.

Exceptions to the certification statement.

No exceptions stated.