DEPARTMENT OF TRANSPORTATION
FEDERAL TRANSIT ADMINISTRATION
JUSTIFICATION STATEMENT
JOB ACCESS AND REVERSE COMMUTE (JARC) PROGRAM
(OMB # 2132-0563)
This supporting statement is associated with a request for revision of a currently approved information collection. The change in this collection reflects a reduction in burden on the public and federal government due to the Job Access and Reverse Commute (JARC) Program being repealed by Congress under the Moving Ahead for Progress in the 21st Century Act (MAP-21) and reduction in open grants and corresponding reporting requirements. As a result, the application stage and all information collected as part of this process in the program have been eliminated. This IC is only being renewed because there are still very small amounts of funding left sitting in respondents accounts for draw down. FTA must continue to collect information under the program management stage until the period of availability expires; the funds are fully expended; the funds are rescinded by Congress; or the funds are otherwise reallocated. Once all funds are fully expended and the reporting requirements expire, this information collection will be discontinued.
A. Justification
CIRCUMSTANCES THAT MAKE THE COLLECTION NECESSARY.
The Federal Transit Administration (FTA) provided financial assistance to States, local governments, private nonprofit organizations and public transportation authorities through
49 U.S.C. Section 5316, the Job Access and Reverse Commute (JARC) Program. The program provided funding to states for areas with a population of less than 200,000 and designated recipients in urbanized areas of 200,000 persons or greater to transport welfare recipients and other low-income individuals to and from jobs related to employment. The (JARC) program was established to address the unique transportation challenges faced by welfare recipients and low-income persons seeking to obtain and maintain employment.
The provisions of Title 49 U.S.C. Section 5316, 49 C.F.R. Part 18, the Uniform Administrative Requirements for Grants and Cooperative Agreements to State and local governments (the Common Grant Rule), and prudent administration of federal grant funds dictate that grantor agencies review applications for federal assistance to assure eligibility and other criteria, as appropriate, and monitor approved projects to ensure timely expenditure of federal funds by grant recipients. Information collected under this program is structured to comply with federal mandates.
On October 1, 2013, the Job Access and Reverse Commute (JARC) Program was repealed by Congress under the Moving Ahead for Progress in the 21st Century Act (MAP-21). Originally, the program had two reporting requirements by grant recipients; the application stage and the project management stage. Since being repealed, the program no longer announces grant funding opportunities, thus eliminating the application stage. However, to meet federal program oversight responsibilities for those JARC grants that are still active, FTA must continue to collect information under the program management stage until the period of availability expires; the funds are fully expended; the funds are rescinded by Congress; or the funds are otherwise reallocated.
Project Management Stage
The reporting requirements under this stage are necessary to ensure the proper and timely
expenditure of federal funds within the scope of the approved project. The requirements
comply with the Common Grant Rule and are contained in FTA Circular 5010.1B, and
may also be included in sections of the grant contract. These reporting requirements are:
Milestone/Progress Reports (MPRs) – SUBMITTED ANNUALLY
These narrative reports define the level of activity for each project element during the reporting period. All significant events (e.g. delays, problems, milestone achievements, etc.) are reported in the MPR. The reports greatly reduce the need for on-site visits by staff.
USED AND CONSEQUENCES IF THE INFORMATION IS NOT COLLECTED.
The eligible designated grant recipients of the JARC program included States and public bodies. Eligible sub-recipients were private non-profit organizations, State or local governments, and operators of public transportation services including private operators of public transportation services. The recipients submit annual reports via FTA’s Transit Award Management System (TrAMS) data collection system. The information submitted ensures FTA's compliance with applicable federal laws and the Common Grant Rule. Without these reports, significant resources and manpower would be necessary to conduct on-site inspections. In addition, the FFR report permits an assessment of program effectiveness for the federal government in both the executive and congressional branches. If this information was not collected, FTA could not ensure the proper expenditure of federal funds or assess the program effectiveness.
This information collection also satisfies the infrastructure goal in the Departmental Strategic Plan for FY 2018-2022. The infrastructure goal states that DOT will invest in Infrastructure to ensure safety, mobility and accessibility and to stimulate economic growth, productivity and competitiveness for American workers and businesses.
CONSIDERATION OF IMPROVED INFORMATION TECHNOLOGY TO REDUCE
BURDEN AND ANY TECHNICAL OR LEGAL OBSTACLES TO REDUCING
BURDEN.
FTA's electronic grant making and management system Transit Award Management System (TrAMS) is a paperless, electronic grant application, review, approval, acceptance and management process. All JARC grants and periodic reports are submitted (100%) electronically. Grantees also use the electronic system for signature of annual certifications and assurances.
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.
The reports are project specific and the information is not available elsewhere. There is no duplication.
5. METHODS USED TO MINIMIZE BURDEN ON SMALL BUSINESSES OR OTHER
SMALL ENTITIES.
The information collected does not involve small business.
CONSEQUENCES TO FEDERAL PROGRAMS OR POLICY ACTIVITIES IF
INFORMATION WAS NOT COLLECTED OR COLLECTED LESS FREQUENTLY, AS WELL AS ANY TECHNICAL OR LEGAL OBSTACLES TO REDUCING THE BURDEN.
If these and other reports were required less frequently, additional site visits by agency staff would be required to ensure compliance with program objectives. Additionally, the agency would not be able to effectively evaluate the program in accordance with the Government and Performance and Results Act.
SPECIAL CIRCUMSTANCES THAT REQUIRE THE COLLECTION TO BE
CONDUCTED IN A MANNER INCONSISTENT WITH 5 CFR 1320.6.
The information collected is consistent with the guidelines in 5 CFR 1320.6.
EFFORTS TO CONSULT WITH PERSONS OUTSIDE THE AGENCY TO OBTAIN
THEIR VIEWS.
A 60-day Federal Register notice was published on December 8, 2021 Vol. 86 No. 233 (page 69712-69713) soliciting comments prior to submission to the Office of Management and Budget (OMB). No comments were received from that notice. A 30-day Federal Register notice was published on February 10, 2022 Vol. 87 No. 28 (pages 7899-7900). Although there is no formal outreach that is held with respondents as a result of this program being repealed, the FTA program manager reached out to several of the respondents during the initial review of this information collection. As a result of the outreach efforts, many of the respondents that had funding available, actually fully expended those funds or returned to FTA. As a result, there are only 49 respondents. FTA program managers will continue to reach out to check the status of the funding until the funds are fully expended; the funds are rescinded by Congress; or the funds are otherwise reallocated.
EXPLAIN ANY DECISION TO PROVIDE ANY PAYMENT OR GIFT TO
GRANTEES.
No payment is made to respondents.
DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED
RESPONDENTS.
There is no assurance of confidentiality regarding these submissions.
11. ADDITIONAL JUSTIFICATION FOR QUESTIONS OF A SENSITIVE NATURE.
None of the information is of a sensitive nature.
ESTIMATE OF THE HOUR BURDEN OF THE COLLECTION AND ANNUALIZED COST TO RESPONDENTS.
Estimated Annual Number of Respondents: 49
Estimated Annual Number of Responses: 49 (1 response per respondent annually)
Estimated Total Burden Hours per Respondent: 2 hours
Estimated Annual Total Annual Burden Hours: 98 hours
Estimated Annual Total Cost to Respondents: $4,400.20
Report Requirements |
# Total Open Grants |
#Total Submissions/Reports Annually |
Burden hours per submission |
Total Submissions/Reports Annual Burden Hours |
Milestones/Progress Reports (MPR) Submitted Annually 16,696
|
49 |
1
|
2
|
98 |
Totals |
49 |
49 |
N/A |
98 |
There is currently a total of (49) respondents/grantees that previously had projects under the JARC program. Due to the program being repealed and all projects are now complete, grantees are only required to submit (1) annual Milestone Progress Reports annually. This IC is only being renewed because there are still very small amounts of funding left sitting in their accounts for draw down. FTA must continue to collect information under the program management stage until the period of availability expires; the funds are fully expended; the funds are rescinded by Congress; or the funds are otherwise reallocated. The chart is detailed below:
Total Annual Responses: 49 (49 x 1 = MPRs)
49 projects x 1 yearly = 49 MPRs annual reports)
Total Annual Burden Hours: 98 hours (49 MPRS x 2 burden hours each respondent)
The time allotted to review the existing Milestone Report, research the financial status and make updates has decreased dramatically because the projects are completed. The reports already exist and very minimal edits need to be made in TrAMS.
Estimated Cost to Respondents:
Project Management Stage:
According to the U.S. Bureau of Labor Statistics, FTA estimates that a Business and Financial Operations Personnel/Cost Estimator (occupation code 13-1051 Cost Estimators (bls.gov) will be involved in the preparation of the request. As stated above it is estimated to take each respondent approximately 2 hours to review, update and submit (1) MPR on an annual basis for each grant. It is estimated that (1) individual will prepare each MPR report at $44.90 per hour ($35.08 x .28% for fringe benefits) for a total cost of $89.80 per grant. The total cost to the respondents to prepare and submit MPR’s on annual basis is $4,400.20 (89.80 x 49).
The total annual burden cost to the respondents is $4,400.20
ESTIMATE OF TOTAL ANNUAL COST BURDEN TO RESPONDENTS OR
RECORDKEEPERS RESULTING FROM THE COLLECTION OF INFORMATION
(NOT INCLUDING THE COST OF ANY HOUR BURDEN SHOWN IN ITEMS 12
AND 14).
There is no additional cost beyond that shown in items 12 and 14.
14. ESTIMATE OF THE ANNUALIZED COST TO THE FEDERAL GOVERNMENT.
The cost is calculated as follows:
Project Management Stage:
Individuals managing projects throughout FTA vary from GS-9 to GS-14. However, in looking at the average salary of grant program managers in FTA’s Office of Program Management, the employee reviewing program management reports (FFRs and MPRs) submitted into TrAMS by recipients is a GS-12 step 5 (average salary, $48.78 per hour SALARY TABLE 2022-DCB (opm.gov) which includes locality payment of 31.53% for the DC, MD, VA, WV and PA areas. If takes (1) federal employee approximately 2 hours per MPR review, the total cost is $97.56 per report. There are 49 total annual report submissions, thus the total cost to the government for the project management stage is $4,780.44
EXPLAIN REASONS FOR CHANGES IN BURDEN, INCLUDING THE NEED FOR
ANY INCREASES.
The annual burden hours decreased from 3,971 to 98 hours for the current request, representing a decrease of 3,873 hours. The decrease is due to the decline in the open grants and the elimination of the quarterly Federal Financial Reporting requirements. All of the JARC projects are 100% completed, however there are still small amounts of funding left available in the respondents’ program accounts. As a result of the 100% completion, only annual Milestone Progress Reports (MPR’s) are required to be submitted to FTA. These reports already exist, and respondents need only review, update and submit the status of the project and available funds on an annual basis. FTA must continue to collect information under the program management stage until the period of availability expires; the funds are fully expended; the funds are rescinded by Congress; or the funds are otherwise reallocated. Once all funds are fully expended and the reporting requirements expire, this information collection will be discontinued. The burden hours will continue to decrease until all funds are expended and no reporting is required. This IC will be discontinued at this point.
PLANS FOR TABULATION AND PUBLICATION FOR COLLECTIONS OF
INFORMATION WHOSE RESULTS WILL BE PUBLISHED.
FTA plans to publish the results of the information collected for use by grantees.
IF SEEKING APPROVAL NOT TO DISPLAY THE EXPIRATION DATE FOR OMB
APPROVAL EXPLAIN THE REASONS.
There is no reason not to display the expiration date of OMB approval.
18. EXPLAIN ANY EXCEPTIONS TO THE CERTIFICATION STATEMENT
IDENTIFIED IN ITEM 19 OF OMB FORM 83-I.
No exceptions are stated.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | 49 U |
| Author | masselinks |
| File Modified | 0000-00-00 |
| File Created | 2022-02-23 |