Supporting Statemen A 0596-0223 - FY2021-Final.daj

The 2021 Supporting Statement for OMB 0596-0223

Federal Excess Personal & Firefighter Property Program Administration

A. Justification

1. 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.

Statutes and Regulations:

• Federal Property and Administration Services Act of 1949, 40 U.S.C., Sec 202

• Public Law 106-508 (Federal Property Services and Administrative Assistance Act of 1949, as amended), December 29, 2000

• Excess personal property: sale or donation to assist firefighting agencies, 10 U.S.C., Subtitle A, Part IV, Chapter 153, 2576b

• 16 USC 2101-2114 (Cooperative Forestry Assistance act of 1978, as amended)

Federal Excess Personal Property (FEPP) and Firefighter Property (FFP) programs provide state (including US territories) forestry agencies the opportunity to obtain excess Department of Defense and other Federal agencies’ equipment and supplies to be used in firefighting and emergency services.

The FEPP program loans excess property to individual states.

The FFP program sometimes transfers ownership of the equipment to state agencies or the individual fire departments.

The Federal Property Services and Administrative Assistance Act of 1949 and the Cooperative Forestry Assistance Act of 1978, as amended, authorize the U.S. Department of Agriculture’s Forest Service to loan federally owned property to state cooperators to use in fighting fires and providing emergency services.

Established in 1956 in cooperation with state forestry agencies, the Federal Excess Personal Property (FEPP) program administers the loan of Forest Service Fire and Aviation Management fire-control stock to states.

The FEPP program provides Forest Service officials with updated information on the condition of property loaned to state and territory cooperators. The information provided by cooperators to the Forest Service includes condition of property loaned, current location of property, description of property, and any additional relevant details.

The FFP program provides Forest Service officials with information on the condition of the property acquired by the state and territory cooperators. The information provided by the cooperators to the Forest Service for the purpose of identifying the acquisition includes location of the property, date property was placed in service, use of property, and any additional relevant details. This information is retained by the Agency for a period of one year after the property has been placed into service.

The Forest Service Federal Excess Property Management Information System (FEPMIS) database allows the Forest Service to collect FEPP and FFP information used to manage property inventory electronically. Access to the database is limited to those state employees with access authorized by Forest Service Management Officers working in the Fire and Aviation staff.

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.

1. What information will be collected - reported or recorded? (If there are pieces of information that are especially burdensome in the collection, a specific explanation should be provided.)

FEPP and FFP Cooperative Agreements collect the state agency name, the points of contact information, and identify and record the signature of the responsible official for the cooperating state.

The following information will be collected via the FEPMIS database from the state employees with authorized access to the database when new property items are acquired or when property is inventoried or disposed:

• Property details, including, manufacturer, model, year of manufacture, date of acquisition, Federal property identification number, serial number, condition of property, location of property, and users of property

• Requests for property

• Items excess to Federal agency needs

• Reports of excess (when property is no longer needed or usable within the state agency)

• Change of Status (to request modification or cannibalization of property, or to report, lost, stolen, or damaged property items)

• Inventory management; verification and certification of property location; and item details and status

2. From whom will the information be collected? If there are different respondent categories (e.g., loan applicant versus a bank versus an appraiser), each should be described along with the type of collection activity that applies.

The information is collected from States that participate in the FEPP and FFP programs.

3. What will this information be used for - provide ALL uses?

The collected information is used to manage FEPP and FFP from acquisition to disposal.

In addition, this information is used to allow access to states for reporting changes in property information at the user level. A Forest Service property technician verifies and loads the collected information into the National Finance Center’s (NFC) Property Management Information System (PMIS/PROP).

This information is used to create transfer forms (SF-122 and AD-107), disposal documents (SF-120 and AD-112), and inventory certification reports.

The collected information is stored and retained according to the Forest Service records retention period for file code 6410 (per FSH 6209.11, 41, part 08):

• Excess and Surplus (Includes correspondence and forms relating to the declaration of personal property as excess and surplus and the acquisition of excess personal property.) (N1-95-88-2) – Retention Period is 3 years after file closed.

This information is used for Records and Inventory management.

Federal Excess Personal Property (FEPP) and Firefighter Property (FFP) cooperative agreement forms are used to collect information from the participating state agency and outlines the requirements and rules for the cooperation.

Control and administration of the Federal Excess Personal Property (FEPP) and Firefighter Property (FFP) agreements are currently approved under OMB no. 0596-0218 Federal Excess Personal Property (FEPMIS Database).

4. How will the information be collected (e.g., forms, non-forms, electronically, face-to-face, over the phone, over the Internet)? Does the respondent have multiple options for providing the information? If so, what are they?

Each state designates an Accountable Officer who will be responsible for the integrity of the program within their respective state. This individual is responsible for filling out the required cooperative agreements that collect information from the participating state agency and outlines the requirements and rules for the cooperation. Participating state agencies must submit separate agreements if they desire to participate in both programs. Accountable Officers complete and submit cooperative agreement documents for the state forestry agency that desires to participate in one or both of the programs.

FEPP and FFP Cooperative Agreements both require hard signatures. FEPP Agreements are collected on form FS-3100-10, and FFP Agreements are collected on form FS-3100-11.

These forms are emailed to the state upon request. The completed forms may be submitted by a variety of means of the respondent’s choosing, such as submitting hardcopy documentation via any mail delivery service, scanned and sent by email, or by fax.

All information concerning property is collected electronically in the FEPMIS database. There is no other option for reporting property data.

5. How frequently will the information be collected?

FEPMIS data is collected as property status changes. It is estimated that 401 responses each for a total of 22,500 responses annually

Cooperative Agreements are collected as a State signatory changes or every five (5) years, whichever is first. It is estimated that 10 respondents, for each (FFP Agreements, and FEPP Agreements) will provide on average 1 response each, totaling 20 responses annually.

6. Will the information be shared with any other organizations inside or outside USDA or the government?

The information is used internally for property management purposes only and is not shared.

7. If this is an ongoing collection, how have the collection requirements changed over time?

There have been no changes to the collection 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. Also, describe any consideration of using information technology to reduce burden.

Use of modern information technology to reduce burden for this collection is encouraged and utilized wherever possible.

FEPP and FFP Cooperative Agreements require hard signatures and may be submitted by a variety of means of the respondent’s choosing, such as submitting hardcopy documentation via any mail delivery service, scanned and sent by email, or by fax.

All information on the property is collected by use of the internet based FEPMIS database. This is accomplished by respondents simply keying in the appropriate information into the appropriate screen in the database. The technology also manages inventory, certification, form generation, and reporting. The use of the database considerably reduces the burden on State cooperators as well as Forest Service property management officers, generating clear and concise documentation.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose described in item 2 above.

The information is unique to particular pieces of property and to each Agreement. There are no other databases or collection methods that collect this information.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

This collection does not impact small entities.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing burden.

Without the ability to collect the information requested of a respondent for cooperative agreement, the Forest Service would not be able to conduct the activities falling under the authorities and instruments listed. The agency would not be able to loan or transfer ownership of excess Department of Defense or Federal excess property. There are no technical or legal obstacles to reducing burden.

Inventory management of the property is essential to protect the interests of the Forest Service. The database enables the users of the property to provide clear and accurate information to the Forest Service. If FEPMIS would not be used, the chances of Forest Service property being lost and/or misidentified would increase dramatically. Currently there are over 115 thousand Federal inventory items on loan to the state cooperators with an acquisition value over 950 million dollars. Lost FEPP is lost money to the Federal government.

Assigned

114158

$925,318,638.53

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;

Although there is no requirement, acquisition and disposal of property items often occurs more often than quarterly, therefore there may be instances when a respondent will respond more often than quarterly.

• 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;

Federal Excess Personal Property (FEPP) and Firefighter Property (FFP) program Cooperative Agreements programs require the record keeping of property transferred in the cooperative agreements for six years and three months after year of final disposal. Accountable Officers shall retain records of property to be available upon request by the Forest Service.

Cooperative agreements will be kept on file until superseded by a new or updated agreement.

• 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;

• requiring the use of a statis­tical data classi­fication that has not been re­vie­wed and approved by OMB;

• 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; or

• 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.

There are no other special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.6.

8. If applicable, provide a copy and iden­tify the date and page number of publications in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), 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.

The Federal Register 60-day Notice for the renewal of this information collection was published on September 25, 2020 (Vol. 85, No. 187, Pg. 60417-60418). The Forest Service did not receive comments.

Describe efforts to consult with knowledgeable 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.

There is an open line of communications between the Forest Service, Defense Logistics Agency and State partners where the exchange of knowledge is encouraged by everyone

in the partnership.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years even if the col­lection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

Respondents consulted:

1. Fire Equipment Manager, Nebraska Forest Service     

2. Project Coordinator, Texas A&M Forest Service

3. Fire Resource Manager, Florida Department of Agriculture and Consumer Services

4. Federal Property Coordinator, Oregon Department of Forestry    

The Forest Service contacted the above Accountable Officers and FEPMIS users across the country requesting comments on the cooperative agreements. In summary, respondents were happy to use the standard agreements provided, and had no suggestions for improvement.

The overall comments concerning the FEPMIS database is that it is simple and easy to use, and respondents had no suggestions for improvement.

8. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No financial incentive, payment or gift, will be 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 is provided to respondents.

10. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or 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 or commonly considered private.

10. Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

Please refer to supplemental document entitled 0596-0223 2020 FEPP Burden-Cost Spreadsheet for respondent burden and cost estimates.

There are currently 76 respondents who interact with the FEPMIS database from the 56 participating states/territories.

The number of responses per respondent for the Cooperative Agreements was estimated by taking average number cooperative agreements received in any one year.

The time per response was estimated by using the professional judgment of the program manager whom has extensive experience in performing each of these tasks.

The cost to respondents was estimated by estimating the cost per hour of state workers and multiplying by the number of hours, using data found at Department of Labor, Occupational Employment and Wages http://www.bls.gov/oes/current/oes131199.htm

Record keeping burden:

Please refer to supplemental document entitled 0596-0223 2020 FEPP Burden-Cost Spreadsheet for respondent record keeping burden and cost estimates.

Although there is no requirement, it is recommended that each state store property records for a period of 6 years and 3 months after the year of disposal. The estimated time for record keeping was estimated using the professional judgment of the program manager whom has extensive experience in performing this task.

13. Provide estimates of the total annual cost burden to respondents or record keepers resulting from the collection of information; (do not include the cost of any hour burden shown in items 12 and 14). The cost estimates should be split into two components: (a) a total capital and start-up cost component annualized over its expected useful life; and (b) a total operation and maintenance and purchase of services component.

There are no capital operation or maintenance costs.

14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

Hourly rates stated below are taken from OPM: http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2017/GS_h.pdf.

Table 1 – Estimated Annual Cost to the Government

Action Item	Number of Employees	GS Level	Hourly Rate	Total Hours	Cost to Govt.
Employee labor for developing, printing, storing Agreement forms	1	GS-12/Step 5	$35.93	60	$ 2,156
Employee labor for collecting Agreement information	1	GS-12/Step 5	$35.93	30	$ 1,078
Employee labor for analyzing, evaluating, summarizing, and/or reporting on the collected Agreement information	1	GS-12/Step 5	$35.93	50	$ 1,796
Employee Labor – Development of system/screens; collection of information; analyzing, evaluating, summarizing, and reporting; and, meetings, web design, conduct training, technical assistance, program reviews, and managing programs.	1	GS-14/Step 4	$49.01	2080	$101.941
Employee Labor – Collection of information; analyzing, evaluating, summarizing, and reporting; and, program reviews and technical assistance for FEPMIS	9	(1) GS 12/1 (3) GS 12/2 (4) GS 12/3 (1) GS 13/1	$31.70 $32.76 $33.82 $37.70	2,080 2,550 1,550 1,600	$ 65,936 $ 83,538 $ 52,421 $ 60,320
Employee Labor – Data entry of FEPMIS information into NFC	9	(2) GS 7/3 (1) GS 7/10 (2) GS 9/3 (1) GS 9/6 (1) GS 11/2 (1) GS 11/5 (1) GS 11/6	$19.06 $23.23 $23.32 $25.51 $27.33 $29.98 $30.86	1,800 2,080 2,880 350 200 2,080 2,080	$ 34,308 $ 48,318 $ 67,162 $ 8,928 $ 5,466 $ 62,358 $ 64,189
Office Supplies paper, file cabinet, fax machine, etc.)	---	---	---		$ 6,000
Travel Costs (18 employees conducting two reviews per year at a cost of $2,500 per trip)	18	---	---		$ 90,000
Total Cost to Government					$755,915

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.

The burden estimates since 2017 haven’t changed, this is information collection is a renewal without revisions.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

There are no plans for the information to be published.

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 valid OMB control number and Burden Statement will be displayed on all instruments.

Cooperative Agreements are valid for a period of 5 years from the date of execution. Cooperators often confuse the OMB approval expiration date with the Agreement’s expiration or superseding date.

The FEPMIS database is not publicly available. Access and use are restricted to only the authorized employees of the 56 states and territories currently participating in these programs, solely for the purposes of reporting the state or territory’s use, acquisition, and disposal of the Federal property loaned or given to them. Maintaining the expiration date on this closed system is time consuming and costly to the Agency yet serves no practical function.

Therefore, the Agency requests approval to not display the OMB expiration date.

18. Explain each exception to the certification statement identified in Item 19 "Certification for Paperwork Reduction Act."

There are no exceptions to the certification statement. The Agency can certify that this request complies with 5 CFR 1320.

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