In future submissions, the agency will include detailed explanation of their usability testing when it is used for new burden estimates. The agency is reminded that burden changes stemming from previous changes to a collection or new estimates from usability testing should be considered estimate changes. The Information Collection Budget will not consider these burden estimate changes as burden reduction. In the future, the agency should submit non-substantive change requests when only the burden estimates are changing and those changes are not driven by form or collection changes.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
10/31/2026
36 Months From Approved
10/31/2023
260
0
360
552
0
1,007
0
0
0
The loan package for the CDL Program provides local governments that have suffered substantial loss of tax or other revenues as a result of a major disaster, the opportunity to obtain financial assistance in order to perform their governmental functions. The loan must be justified on the basis of need and actual expenses.
US Code:
42 USC 5184
Name of Law: Community Disaster Loans
Overall, the annual burden for this collection was reduced by 455 (405 + 50) hours. Time burden for FEMA Form FF-104-FY-22-226 (formerly 112-0-3C) rounded to 22 hours for a difference of zero (0) burden hours compared to the previous submission. Program is reducing burden by 50 hours through the removal of FEMA Form 090-0-4 (Letter of Application). Program found that sending a template request letter served the requirement of the prior form while reducing the burden on the local government. Through usability testing, burden hours for applicant changed from prior renewal of this collection. An example of this is the Certificate of Eligibility, FEMA Form FF-104-FY-22-223 (formerly 090-0-1). Previously, FEMA estimated 2.5 hours to fill the form, while this yearâs testing yielded an estimate of 2 hours. FEMA Form FF-104-FY-22-225 (formerly 085-0-1), Local Government Resolution â Collateral Security, entails coordination of a session for a Local Government to obtain consent from its governing body to go into the loan, plus the development of a Resolution. Most of that coordination is not controlled or driven by the information requested on the form itself. FEMA adjusted the estimated burden to reflect only the time required to complete and submit the form. That change reduced the time burden from the estimated 10 hours to 3 hours. FEMA Form FF-104-FY-22-227 (formerly 090-0-15), Application for Loan Cancellation, in the last three years had more users due to FEMAâs caseload at the time. The number of loans expected to use the form between September of 2023 and August of 2026 was significantly reduced via a blanket cancellation authorized by Congress through P.L. 117-43.
Overall, the annual cost burden for this collection was reduced by $28,138 ($25,459 + $2,679) by reducing the burden about 455 hours, mainly from eliminating FEMA Form 090-0-4, Application for Federal Assistance (Application for Community Disaster Loan) and change in the average hourly wage rate.
In previous years we had utilized the general public mean wage rate to calculate burden cost to the applicant to fill out these forms. This year, we are correcting the type of applicant since our applicants are local governments, plus using the local government multiplier of 1.61 instead of the general public multiplier of 1.45. FEMA used the wage rate for All Occupations SOC 00-0000 is $29.03. Including the wage rate multiplier of 1.61, the fully-loaded wage rate is $46.74 per hour.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Application for Loan Cancellation