Final Ssa--1093-0006 2024

FINAL SSA--1093-0006 2024.docx

Natural and Cultural Resource Agencies Customer Relationship Management (Volunteer.gov) and OF 301 Forms.

OMB: 1093-0006

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Supporting Statement A for

Paperwork Reduction Act Submission

Natural and Cultural Resource Agencies
Customer Relationship Management (Volunteer.gov) and OF 301 Forms
(Volunteer Service Application OF 301, Volunteer Service Agreement OF 301a, Volunteer Sign-up Form for Groups OF 301b)


OMB Control No. 1093-0006


Terms of Clearance: None


1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.


Federal land management agencies are authorized to work with volunteers to plan, develop, maintain, and manage projects and service activities on public lands throughout the nation. This information collection request will enable the effective engagement of and capture the required information for hundreds of thousands of volunteers, and enable seamless efficient reporting on their projects and activities.


Laws, statutes, and regulations listed below authorize federal land management agencies (identified in Table 1A below) to work with volunteers:


  • 16 U.S.C. §1721 et. seq. – Public Lands Corps Act (PLC)

  • 16 U.S.C. §4601 – Outdoor Recreation Authority

  • 16 U.S.C. §558 a-d – Volunteers in the National Forests Program

  • 16 U.S.C. §583j-4 – Forest Foundation Volunteers

  • 16 U.S.C. §1246 – Administration and development of national trails system

  • 16 U.S.C. §1250 – Volunteer trails assistance

  • 16 U.S.C. §1246(h)(1) – Agreements to Operate, Develop, and Maintain Portions of National Trails

  • 16 U.S.C. 742a-742j – Fish and Wildlife Act of 1956

  • 16 U.S.C. 760aa, 1-4 – The National Fish Hatchery System Volunteer Act of 2006

  • 31 U.S.C. §3325 – Vouchers

  • 33 U.S.C. §569c – Services of Volunteers

  • 38 U.S.C. §4301 – The Uniformed Services Employment and Reemployment Rights Act

  • 43 U.S.C. 1737 Federal Land Policy and Management Act of 1976 (FLPMA), as amended, including amendment by Public Law 98-540 of 1984 (the BLM volunteers for the Public Lands Statute)

  • PL 92-300 all – Volunteers in the National Forest Act of 1972

  • 54 U.S.C. §101702(a) Cooperative Agreements, Transfer of Service Appropriated Funds

  • 54 U.S.C. §101702(b) Cooperative Agreements, Cooperative Research and Training Programs

  • Presidential Memorandum - Expanding National Service, July 15, 2013

  • Department of the Interior Secretary Order No. 3333

  • Water Resources Reform and Development Act of 2014, Pub. L. 113-121, Title I, Sec. 1047(d), 128 Stat. 1193, 1255 (2014).

  • PL 105-242 Sec. 1-7 - The National Wildlife Refuge System Volunteer and Community Partnership Act of 1998



Table 1A – Participating Land Management Agencies

Department of Agriculture

  • U.S. Forest Service, and

  • National Resources Conservation Service

Department of the Interior

  • Office of the Secretary (OS),

  • Bureau of Indian Affairs (BIA),

  • Bureau of Land Management (BLM),

  • Bureau of Reclamation (BOR),

  • National Park Service (NPS),

  • Office of Surface Mining Reclamation and Enforcement (OSMRE),

  • U.S. Fish and Wildlife Service (FWS), and

  • U.S. Geological Survey (USGS)

U.S. Department of Commerce

  • National Oceanic and Atmospheric Administration (NOAA)

U.S. Department of Defense

  • U.S. Army Corps of Engineers (USACE)


Agencies and their authorized partners may recruit, train, and accept the services of individuals and groups to aid in interpretive functions, visitor services, conservation measures, research and development, recreation, or other activities in nearly all areas of service. Agencies provide the participants of these efforts with benefits that require verification of identification and enrollment.


In February of 2016, the U.S. Department of the Interior Inspector General Report No: 2015-CR-001, noted that DOI’s inability to maintain an accurate count of volunteers also impacts understanding of employee injury rates and associated costs. The report recommended that all DOI bureaus use a standard method for counting and reporting the number of volunteers and the amount of time they worked. This would allow DOI bureaus to formulate strategies to address safety issues more effectively by creating a better understanding of the causes and effects of such injuries.

The volunteer management web-based portal and common OF 301 forms (“the collection”) are the participating agencies’ response for meeting citizens’ expectations for streamlined digital services while allowing the agencies to collect the data needed to keep volunteers and the public safe. The collection allows prospective and current program participants (“volunteers”) to access and apply for volunteer opportunities.


The volunteer management web-based portal (“Volunteer.gov”) allows volunteers to establish an account for electronic submission of program applications and to obtain the status of applications and benefits, such as the America the Beautiful Pass. In addition, Volunteer.gov enables volunteers to maintain a single account application for reuse and updating to apply for all interested opportunities, rather than requiring them to complete an application for each opportunity. The collection minimizes the burden on volunteers.


Additionally, the collection addresses partner’s requests to standardize and centralize data collection for more efficient data sharing and for management for the safety and security of volunteers. The renewal of this collection maintains the common OF 301 forms and maintains a reduced number of portals (originally seven across agencies, now one). With this collection, volunteers are requested to provide a common set of information across agencies and not burdened with entering the same information into different portals. This shifts the burden to agencies to minimize the amount of data that volunteers must enter.



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. Be specific. If this collection is a form or a questionnaire, every question needs to be justified.


The primary goal of this collection is to continue to provide thousands of federal field units a standardized system of records for volunteer management, allowing for greater citizen usability, security, and accessibility. We collect information from potential and selected volunteers in either Volunteer.gov or in the OF 301 forms. All this information is currently used by participating agencies in the management of their volunteer programs. All information proposed for continued collection has been deemed necessary for effective and compliant volunteer management by participating agencies; information no longer required has been proposed for removal (see below). In addition, we solicited input from individual volunteers to verify that they concurred all information collected was reasonable and necessary (see section 8.2).


Participating agencies will use this information to manage agency volunteers. In addition, through the information collected, federal agencies will be more accountable to taxpayers by providing annual reports and descriptions of volunteer activities. This information will be accessible online from information gathered through the Volunteer.gov website and on the participating federal agency websites. As required, we will share general and summary information in reports to participating agencies. We may also provide this information to Congress and the public in reports. However, we will not share information regarding individual’s PII. Volunteers under 18 years of age must have written consent from a parent or guardian.


See additional attachments for copy of information collected on Volunteer.gov and information collected via OF 301 forms. A review of information requested in this collection is outlined in Table 2A.


Volunteer.gov

Volunteer.gov is a shared service to multiple federal agencies. The volunteer portal provides federal staff volunteer managers the ability to perform recruitment, selection, hours tracking, onboarding, and certain recognition activities by accessing required services and data in a user-friendly web-based format. Additionally, the volunteer portal allows volunteers to establish an account for applying, tracking, and managing volunteer applications.


Previously, volunteers had to complete required forms for each volunteer opportunity they wished to apply to. Using Volunteer.gov, volunteers may use a common application to apply to multiple volunteer opportunities at the same agency or at any participating agency. All online forms are accessible via the Internet and the data is stored in a centralized database for ongoing use. All users also have easy access to update and review data.


In addition, because participating agencies can use Volunteer.gov to track volunteer hours, they can capture the volunteer time reporting needed to provide America the Beautiful Volunteer Passes for volunteers that have contributed more than 250 hours. The America the Beautiful Pass provides free access to more than 2,000 federal recreation sites. Tracking volunteer hours is required to receive the benefit of the America the Beautiful pass and to prevent fraud or misuse. Previously, agencies could not track an individual’s volunteer hours across agencies because there was no way to centrally share volunteer information. Now, using Volunteer.gov, participating agencies can see volunteer hours across agencies. This allows agencies to reward volunteers with cumulative volunteer hours that meet the minimum.



OF 301 Forms

Participating agencies currently use the OF 301 Forms to collect required information to manage their volunteer programs. Agencies may choose to have volunteers complete paper-based or electronic PDF versions of the OF 301 forms. These standard forms are offered through Volunteer.gov to further reduce volunteer burden and to enhance information sharing.



Minor revisions are being proposed for the forms to correct grammatical mistakes, provide clarity for users, and to remove unnecessary requests for information. All revisions proposed are based on participating agency and volunteer input. A summary of those revisions is below.


OF 301 (Volunteer Service Application) 
Note: Optional. Volunteers use this to express general interest, not to apply to a specific volunteer opportunity

  • Title: Remove “-NATURAL & CULTURAL RESOURCES” from the title, resulting in the title of “Volunteer Service Application”

  • Burden Statement: Correct grammar

  • Privacy Act Statement: Correct grammar


OF 301a (Volunteer Service Agreement) 
Note: individual volunteers use this to apply and agree to a specific volunteer opportunity

  • Title: Remove “-NATURAL & CULTURAL RESOURCES” from the title, resulting in the title of “VOLUNTEER SERVICE AGREEMENT”

  • Box 4: Correct grammar

  • Box 12c.: Updating to “Military affiliation (Select one): Active Duty, Veteran, None”

  • Box 27: Correct grammar

  • Box 28: Add clarifying language “(Last, First)”

  • Box 45: Remove Box “45. Total Hours Completed”

  • Box 46: Update Box number to “45.”

  • Privacy Act Statement: Correct grammar


OF 301b (Volunteer Sign-up Form for Groups) 
Note: volunteers in a group use this to agree to a specific volunteer opportunity

  • Title: Remove “Natural & Cultural Resources” from the title, resulting in the title of “VOLUNTEER SERVICE AGREEMENT - Volunteer Sign-up Form for Groups”

  • Instructions: Correct grammar

  • Burden Statement: Correct grammar

  • Privacy Act Statement: Correct grammar

  • Footer: Adjusted page numbers to allow for multiple copies of the second page to be printed.


Table 2A: Data Collection Methods

Similar information is necessary to collect in both Volunteer.gov and the paper forms to ensure equal access to volunteer opportunities for all participants.


The table below details what information is collected in what form, as well as the different purpose of each form in the collection. Of note: Volunteer.gov allows volunteers to auto-fill previously completed information to reduce their burden, and includes a digital version of the OF 301a for volunteers to complete as a part of their onboarding process once selected for a volunteer opportunity. All fields of the digital OF 301a form are auto-filled from the volunteer’s application.


Data Collection Method


Volunteer Portal – Complete Volunteer Profile
Note: volunteers use this to express general interest, not to apply to a specific volunteer opportunity

Volunteer Portal – Apply for Volunteer Opportunity

Note: repeating information from Profile auto-fills into Application. Individual volunteers use this to apply to a specific volunteer opportunity

Form 301 – Volunteer Service Application
Note: Optional. Volunteers use this to express general interest, not to apply to a specific volunteer opportunity

Form 301a – Volunteer Service Agreement
Note: individual volunteers use this to apply and agree to a specific volunteer opportunity

Form 301b- Form for Groups
Note: volunteers in a group use this to agree to a specific volunteer opportunity








Information requested:

Optional:






Name


X

X

X

X

X

Phone number


X

X

X

X

X

Email address


X

X

X

X

X

Address


X

X

X

X


Date of Birth


X

X

X

X


Email address


X

X

X

X

X

Citizenship, permanent resident, or visa type


X

X


X


Ethnicity

X

X



X


Race

X

X



X


Veteran status

X

X



X


Disability and accommodation

X

X



X


Emergency contact information


X

X


X


For minors only: parental contact information and consent


X



X


Photo release checkbox

X

X

X


X

X

Physical condition requirements



X

X

X

X

Description of services to be performed



X


X


Areas of interest

X

X


X



Qualifications and skills

X

X

X

X



Previous volunteer experience


X

X

X



Schedule availability


X

X

X



Location availability



X

X



Lodging needs


X

X

X



* Department of Interior intends to further reduce duplication across the paper forms and the volunteer portal by incorporating OF 301 forms directly into the volunteer portal; this would represent a significant reduction in the duplication of information requested from recurring volunteers across multiple agencies. We expect to accomplish this before the next renewal period.



Table 2B: Data Collection Frequency


The table below details the frequency of information collected across the various forms.
Of note: the volunteer portal allows volunteers to utilize previously completed information again to reduce their burden.


Form

Frequency of Information Collected

Volunteer.gov (online)*

Complete a volunteer profile

Complete once and update only as needed for use across all participating federal agencies.

Apply for a volunteer opportunity

Complete once for every volunteer opportunity. The information is auto filled from the volunteer profile, minimizing time and effort. User receives automatic notification when application is submitted and approved.

Complete a digital OF 301a

Complete once for every volunteer opportunity the volunteer is selected for. This information is auto filled from the volunteer application, minimizing time and effort.

OF 301 Forms (paper or PDF)

OF 301

Volunteer Service Application. Optional. Complete as needed to express general interest in volunteering with a particular agency or site.

OF 301a

Volunteer Service Agreement. Complete once for every volunteer opportunity. Revisit once a year and complete again if changes are needed.

OF 301b

Volunteer Sign Up Form for Groups. Complete once for every volunteer opportunity.

*OF 301 forms are incorporated directly into Volunteer.gov; this offers a significant reduction in the duplication of information requested from recurring volunteers across multiple agencies.


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 and specifically how this collection meets GPEA requirements.


Volunteer information in the collection can be completed via Volunteer.gov or through hard copy or PDF. While paper versions are still available to ensure equal access, electronic use of these forms is highly encouraged. Completion of volunteer applications onVolunteer.gov allows for information to autofill, reducing volunteer burden. Federal employees will assist citizens who are unable to provide data electronically.


4. 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 above.


The collection helps standardize and streamline volunteer management among participating agencies. As a shared service, Volunteer.gov eliminates duplication of efforts and the creation of duplicate volunteer records by creating one central point for volunteer tracking among multiple federal agencies. The common OF 301 forms eliminates duplication of similar volunteer management forms across multiple agencies. There is not a similar collection available for use.


Department of Interior has further reduced duplication across the paper forms and the Volunteer.gov by incorporating OF 301 forms directly into the Volunteer.gov; this represents a significant reduction in the duplication of information requested from recurring volunteers across multiple agencies.


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


This collection establishes common data elements and centralizes the data collected. The intention of the collection is to minimize the number of forms collected from volunteers and to eliminate the need for multiple forms across federal agencies. Information collected is the minimal necessary for program participation and reporting.

Small businesses or partner organizations that have entered into partnership agreements may currently collect this information for multiple Federal, state, and private purposes, if required. The information collected does not impose new data elements on small businesses or partner organizations above what they already collect.


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 information gathered through this collection, participating agencies will not be able to effectively manage their volunteer programs or coordinate with other federal agencies on volunteer initiatives. If the Volunteer.gov online collection of information is not available, the impacted agencies would not have an efficient means to advertise volunteer opportunities or collect information about volunteers. If paper or PDF versions of the OF 301 forms are not made available, volunteers without internet access would be unable to participate in volunteer programs. If the collection is not approved, individual volunteers will need to complete more forms that are uniquely established by individual agencies, increasing the burden on the volunteer.


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;

* 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;

* 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 secrets, 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.


The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.6. Through this collection, we offer volunteers a more streamlined way to participate in volunteer programs while also reducing the burden on participating agencies. We have centralized the data elements across agencies, therefore preventing multiple submissions for each different federal agency. We collect data as infrequently as possible - generally once, yearly, or updated only as necessary.


8. If applicable, provide a copy and identify the date and page number of publication 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 in response to the PRA statement associated with the collection over the past three years, and describe actions taken by the agency in response to these comments. Specifically address comments received on cost and hour burden.


Describe efforts to consult with 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.


Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every three 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.


8.1 – Publication of 60-day Federal Register Notice

On March 14, 2024, we published a notice asking for comments on this information collection in the Federal Register (89 FR 18665). In that notice, we solicited comments for 60 days, ending on May 13, 2024. We received 0 public comments in response to this notice.


8.2 – Targeted Outreach

In addition to the Federal Register Notice, we consulted with the following nine individuals to obtain their views. We specifically requested input on:

(1) Whether or not the collection of information is necessary for the proper performance of the functions of the agency, including whether or not the information will have practical utility;

(2) The accuracy of our estimate of the burden for this collection of information, including the validity of the methodology and assumptions used;

(3) Ways to enhance the quality, utility, and clarity of the information to be collected; and

(4) How might the agency minimize the burden of the collection of information on those who are to respond, including through the use of appropriate automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g., permitting electronic submission of response.


General comments on the data elements and methods led to further streamlining reflected in this supporting statement.

Table 8A: Targeted Outreach


Individual

Organization They Volunteer With

Volunteer A

National Park Service, Rocky Mountain National Park

Volunteer B

National Park Service, Rocky Mountain National Park

Volunteer C

National Park Service, Rocky Mountain National Park

Volunteer D

National Park Service, Homestead National Historical Park

Volunteer E

National Park Service, Homestead National Historical Park

Volunteer F

National Park Service, Homestead National Historical Park

Volunteer G

National Park Service, Chesapeake & Ohio Canal National Historical Park

Volunteer H

National Park Service, Chesapeake & Ohio Canal National Historical Park

Staff I

National Park Service, Grand Canyon National Park


Summary of feedback received:


1. No respondents expressed concern with the collection of information in general. One respondent asked why address information was collected on the OF 301, and one respondent asked why date of birth was collected.

  • Seems appropriate

  • Information to be collected seems reasonable


2. No respondents believed that any form in the collection would take longer than 15 minutes to complete, one respondent suggesting a reorganization of the information.

  • I agree with the estimated time for completion of the form.

  • Accurate

  • Yes, the form is quick to fill out - 5 minutes. It could be reorganized so that all the info that an individual volunteer has to fill out is grouped together.


3. Respondents recommended a few potential improvements:

  • State - if on V.Gov [Volunteer.gov] put in a drop down selection of the 2 digit state abbreviation

  • Delete Phone #/DOB unless needed

  • The forms are self-explanatory and easy to use. The requested information is clear. Use of the Adobe pff [PDF] form is simple and effective. I personally have not had an issue completing them.

  • The National Park Service Volunteer Program is moving towards electronic collection of this information.

  • From my perspective, I cannot pinpoint any changes that need to be made.


4. Many respondents noted the convenience of having the forms electronically (on Volunteer.gov) while a few noted the need for paper forms still in addition to electronic version.

  • Electronic submission is a good option, but not always the most convenient for everyone in all cases.

  • Assuming on V.gov [Volunteer.gov] this information will be retained year after year and volunteers will need to review and only update as applicable.

  • For volunteer offices, it will be extremely helpful to easily extract certain levels of this information in mass - for example:

    • email addresses to support distribution lists - to issue newsletters and event notifications

    • mailing addresses for year end thank you's, etc.

  • Not sure of any way to make this form more user friendly.

  • Once a person has applied through Volunteer.gov, all of their demographic information should pull forward, and the applicant should edit as needed only.

  • Providing the form electronically could be useful. However, a paper form would still be appropriate for those who either prefer it because they do not or cannot connect to an electronic version.

  • Additionally, it could prove beneficial to have the information saved to the volunteers file electronically so when it is due to be renewed each year the volunteer could do a review of the information already on file and simply resubmit it verses filling it out again.


8.3 Additional Consultation


In a series of meetings during 2023 and 2024, the following agencies provided input on the desired content, format, and collection processes for this collection of required information. All represented agencies are members of the Federal Interagency Team on Volunteerism, an interagency community of practice for volunteer managers in the federal government.


This collection is part of a continuing effort by participating agencies to adopt a standardized approach to volunteer management. When Volunteer.gov and common forms were first created, these agencies were also engaged in the design and review of the prototypes.


Table 8B: Additional Consultation


Agency

Title

USDA – Forest Service

Volunteer Program Manager

DOI – All bureaus

Volunteer, Youth, and Partnership Managers

USDA - National Resources Conservation Service

Volunteer and Program Manager

US Army Corps of Engineers

Volunteer and Partnership Program Managers

National Oceanic and Atmospheric Administration (NOAA)

Volunteer Manager




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


We will not provide payment or gifts for the collection of the information.


10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.


Each form will show the presence of Privacy Act statement and Burden Statement as assurance to respondents. Collection and use is covered by Privacy Act System of Records INTERIOR/DOI–05 Interior Volunteer Services File System (which may be viewed at https://www.doi.gov/privacy/doi-notices) and OPM/GOVT–1 General Personnel Records (which may be viewed at https://www.opm.gov/information-management/privacy-policy/#url=SORNs) and is consistent with the provisions of 5 U.S.C. 552a (Privacy Act of 1974), which authorizes acceptance of the information requested on this form. The information is used to identify persons interested in participating in a government volunteer program, managing the volunteer program, including tort claims and injury compensation. Records or information contained in this system may be disclosed outside the agencies participating in this program as a routine use pursuant to 5 U.S.C. 552a(b). Completing this form is voluntary, but failure to provide the information will prevent program participation.


Authority includes Public Law (PL) 91-357; 5 U.S.C. 1302, 2951, 3301, 3372, 4118, 8347, and Executive Orders 9397, as amended by 13478, 9830, and 12107. The Government-wide Systems of Records satisfies some requirements under the Privacy Act and DOI specific Systems of Records satisfies other requirements. Since this ICR establishes common forms, agencies using the common forms are responsible to ensure they have satisfied the Privacy Act Requirements with their own Systems of Records as necessary.


11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and 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.


No information on sexual behavior and attitudes or religious beliefs is collected.

Demographic information that may be considered private by some such as gender, disability, race, ethnicity, and veteran status is optional. Citizenship or visa status is collected to ensure only eligible individuals volunteer, according to agency requirements.* The government commonly captures this information government-wide for prospective program participants during the exchange of benefits and services.



*National Park Service example, Director’s Order 7:
5.8   Any non-U.S. citizens with legal permanent resident status in the United States may be accepted as Volunteers In Parks upon providing proof of resident status.  All other non-U.S. citizens must meet Department of State and Department of Homeland Security requirements before participating as a VIP.  All non-resident non-U.S. citizens who wish to volunteer for the NPS must enter the country pursuant to a J-1 or other approved visa.  United States Citizenship and Immigration Services (USCIS) considers any type of reimbursement, whether it be for housing, meals, or other types of compensation (e.g., for training), as a form of payment.  It is illegal for a person traveling under a normal tourist visa to work for compensation.  The J-1 visa allows non-U.S. citizens to train/study in the United States for a limited time while receiving compensation.  The J-1 visa application, Form DS-2019, will be issued by the NPS Office of International Affairs.

Any individual traveling on a tourist visa may volunteer provided there is absolutely no remuneration whatsoever, including, but not limited to, uniforms, meals, housing, or transportation.

12. Provide estimates of the hour burden of the collection of information. The statement should:

* Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

* If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

* Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here.


We estimate that we will receive 526,775 annual responses totaling 99,109 burden hours. We estimate the dollar value of the annual burden hours to be $4,501,517 (rounded). See DOI Burden Calculator, Public Respondent Burden Calculator tab.


Respondent number estimate:

We estimated the number of respondents by reviewing DOI agency numbers of volunteers, based on FY23 totals; it is expected that this recent year is a reasonable estimate for respondents moving forward.


Time estimate:

Based on consultation and current actuals, we estimated the total number of forms expected to be completed and average length of time per form. We expect each volunteer to take 15 minutes to complete one form, based on the consultation process. Because both Volunteer.gov and the OF 301 forms collect similar information, the same time estimate is used across the forms. In addition, it is noted that Volunteer.gov offers a time savings for volunteers, as their information auto-fills across later applications.


Cost estimate:

Bureau of Labor Statistics (BLS) News Release USDL-24-0485, March 13, 2024, Employer Costs for Employee Compensation—December 2023, was used for all labor and benefit calculations.

BLS News Release USDL-20-0451 lists the total compensation (including benefits) for all workers in the following categories as:

Individuals. Table 1 lists the hourly rate for all workers $45.42, including benefits.

Private Sector. Table 5 lists the hourly rate for all workers as $43.11, including benefits.

Government. Table 3 lists the hourly rate for all workers as $60.66, including benefits.


Notes:

  • There is no record-keeping burden placed upon respondents in relation to this information collection.

  • Department of Interior intends to continue to further reduce duplication across the paper forms and Volunteer.gov with the incorporation OF 301 forms directly into the volunteer portal; this represents a significant reduction in the duplication of information requested from recurring volunteers across multiple agencies.



13. Provide an estimate of the total annual non-hour cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected in item 12.)

* The cost estimate 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. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information (including filing fees paid for form processing). Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

* If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

* Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information burden or keep records for the government, or (4) as part of customary and usual business or private practices.


There are no non-hour costs to respondents or recordkeepers resulting from the collection of information; all hour burden is captured in item 12.


14. Provide estimates of annualized cost to the Federal government. Also, provide a description of the method used to estimate cost, which should include quantification of hours, operational expenses (such as equipment, overhead, printing, and support staff), and any other expense that would not have been incurred without this collection of information.


We estimate the total annual cost to the Federal Government to administer this information collection is $3,449,616 (rounded). This amount includes $1,355,015 (rounded) for Federal salary/benefits and $2,094,601 for program administration costs. See DOI Burden Calculator, Costs to the Federal Government Calculator tab.


All costs are currently funded with existing government FTEs and program funds.


15. Explain the reasons for any program changes or adjustments in hour or cost burden.


Volunteer.gov:

For Volunteer.gov, this collection is receiving only minor updates and adjustments in hour or cost burden to reflect current use based on FY23 data.


We estimated the hour and cost burden by reviewing cross-agency numbers of volunteers, based on FY23 data; it is expected that this recent year average is a reasonable estimate for respondents moving forward.


16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.


Other than inclusion in general summary agency reports, there were no plans for publishing or tabulation of volunteer information. We will not report any specific individual’s or partner information.


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.


We will display the OMB control number and expiration date on the login page for Volunteer.gov and on the OF 301 forms prior to publishing the information collection.


18. Explain each exception to the topics of the certification statement identified in "Certification for Paperwork Reduction Act Submissions."


There are no exceptions to the certification statement.

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