Narrative of Changes

Narrative of Changes

The purpose of the Narrative of Changes is to clearly indicate changes to a collection since the previous approval.

Collection Title: Property Acquisition and Relocation for Open Space

OMB Control No.: 1660-0103

Current Expiration Date: 1/31/2018

Collection Instruments: FEMA Form 086-0-31, Deed restrictions (No form), Verification of Monitoring and Reporting (No form).

The following are the changes to the collection:

Supporting Statement:

In compliance with 2 CFR Part 200, specific language has been changed throughout the Supporting Statement, Model Deed Restriction, Privacy Threshold Analysis, and Form 086-0-31: “Grantee” to “Recipient”; “”; Subrecipient” to “Subgranteeand “States” are generally followed by a separate recognition of “Tribes”.

Question 8a – Updated to reflect FRN publication information.

Question 10 – Updated to reflect current privacy information.

Question 12 – Respondents, responses, total burden hours, total annual respondent cost, wages, and wage multiplier were updated to reflect the most accurate information.

Estimated Annualized Burden Hours and Costs
Type of Respondent	Form Name / Form Number	No. of -dentsRespon	No. of -dentRespon per Respon-ses	Total No. of Responses	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate	Total Annual Respondent Cost
Individuals or Households	Property Owners Voluntary Participation Statements / FEMA Form 086-0-31	1201	1	1201	1 hour	1201	$37.94	$45,565.94
State, Local, and Tribal Government	States Review and Submit Deed Restrictions / No Form	56	21.50	1201	4 hours	4804	$49.39	$237,269.56
State, Local, and Tribal Government	State Officials Reporting Requirements / No Form	56	0.333	19	1.3 (1 hour and 18 minutes)	25	$49.39	$1,234.75
State, Local, and Tribal Government	Transfer Certification / No Form	**	**	**	**	**	**	**
State, Local, and Tribal Government	Enforcement Notices / No Form	**	**	**	**	**	**	**
Total		1,313		2,421		6,030		$284,070.25

• Note: The “Avg. Hourly Wage Rate” for each respondent includes a 1.59 multiplier to reflect a fully-loaded wage rate.

• “Type of Respondent” should be entered exactly as chosen in Question 3 of the OMB Form 83-I

Question 14 – A change in wages necessitated an update of the annualized cost to the Federal Government to enforce Property Acquisition requirements.

Question 15 - Insert full explanation and chart from 15.

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
Property Owners Voluntary Participation Statements / FEMA Form 086-0-31				2240	1201	1039
States Review and Submit Deed Restrictions / No Form				8960	4804	4156
State Officials Reporting Requirements / No Form				25	25	0
Total(s)				11,225	6,030	5,195

Explain:

The change in number of submissions of FEMA Form 086-0-31 is calculated from the average number of property acquisitions per year over the last ten years (2007-2016). Thus, the change in state review and submission of deed restriction also changed because it requires 4 hours per response, i.e. 1,201 responses x 4 hours = 4,804 burden hours. State officials reporting requirements did not change.

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
Property Owners Voluntary Participation Statements / FEMA Form 086-0-31				$61,331.20	45,565.94	$15,765.26
States Review and Submit Deed Restrictions / No Form				$606,860.80	237,269.56	$369,591.24
State Officials Reporting Requirements / No Form				$1,693.25	1,234.75	$458.50
Total(s)				669,885.25 $	284,069.65	$ 385,815.00

Explain:

There are no capital, start-up or operations and maintenance costs associated with this information collection that would be reported in Item 14 of OMB Form 83-I, as stated in Item 13 of this Supporting Statement. There is no actual difference in the reportable costs associated with capital, start-up or operations and maintenance because there was none in 2014 and none currently. The adjustment in annual cost burden reflected in the table above is the difference between the erroneous costs reported in 2014, and the actual absence of capital, start-up or operations and maintenance costs associated with this information collection. It is clear in the OMB Form 83-I instructions for Item 14 that the costs identified in Item 14 must exclude the cost of hour burden identified in Item 13 [of Form 83-I].