BAS_SupportingStatement_Part_A_092524

SUPPORTING STATEMENT A

U.S. Department of Commerce

U.S. Census Bureau

Boundary and Annexation Survey

OMB Control No. 0607-0151

Abstract

The Boundary and Annexation Survey (BAS) provides eligible governments, which include tribal, state, and general-purpose local governments, an opportunity to review the Census Bureau’s legal boundary data to ensure the Census Bureau has the correct boundary, name, and status information and make necessary updates. BAS also allows for the review and update of census designated place (CDP) boundaries and linear features. It fulfills the agency’s responsibility as part of the National Spatial Data Infrastructure, for which the Office of Management and Budget (OMB) Circular A-16 designates the Census Bureau as the lead federal agency for maintaining national data about legal government boundaries, as well as statistical and administrative boundaries. It also supports the geospatial data steward responsibilities of the Geospatial Data Act, the Evidence Act, OMB E-Gov, the Federal Geographic Data Committee, Data.gov, GeoPlatform.gov, the National Map, the Geographic Names Information System, and the Geospatial One-Stop.

The Census Bureau uses the boundaries collected during BAS to tabulate data for various censuses and surveys including the decennial census and American Community Survey (ACS) as well as the Population Estimates Program (PEP). It also uses the boundaries collected through BAS to support other programs such as the Redistricting Data Program, the Economic Census, the Geographically Updated Population Certification Program, and the Special Census program.

Other federal programs also rely on accurate boundaries collected through BAS. The Department of Housing and Urban Development uses boundaries to determine jurisdictional eligibility for various grant programs, such as the Community Development Block Grant program. In addition, the Department of Agriculture uses boundaries to determine eligibility for various rural housing and economic development programs.

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.

BAS updates the inventory and boundaries of eligible governments for compliance with responsibilities specified in the OMB Circular A-16, Governmental Units and Administrative and Statistical Boundaries Data Theme.

BAS supports the spatial data steward responsibilities of the OMB E-Gov, Data.gov, the National Map, and updates to the Geographic Names Information System (GNIS). BAS results provide information documenting the creation of newly incorporated municipalities and designated tribal areas (including American Indian Reservations and Off-Reservation Trust Lands). BAS also includes the dissolution of incorporated places and minor civil divisions (MCDs), and changes in the boundaries of tribal, state, and general-purpose local governments. BAS information provides an appropriate record for reporting the results of the decennial and economic censuses, including surveys such as the ACS and programs such as the PEP. The Census Bureau’s legal authority for conducting activities in support of BAS is codified in Title 13, United States Code, Section 6.

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.

The data and information collected from the BAS serves eligible governments and the private sector. BAS is the primary provider for the following services and products:

• Classifies legal boundary data collected in the decennial and economic censuses and annual surveys.

• Serves as the primary source of information regarding new incorporations, disincorporations, and other changes in the eligible government inventory for the Federal Information Processing Series codes, InterNational Committee for Information Technology Standards (formerly the Federal Information Processing Standards) codes, and GNIS codes.

• Generates updated population estimates through the creation of new governments, the dissolution of governments, or changes in boundaries for existing eligible governments.

• Serves as the source for eligible government boundary information as a framework layer for the National Map and the Data.gov website.

Information quality is an integral part of the pre-dissemination review of the information disseminated by the Census Bureau (fully described in the Census Bureau’s Information Quality Guidelines). In addition, information quality is integral to information collections conducted by the Census Bureau, and it is incorporated into the clearance process required by the Paperwork Reduction Act.

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.

The Census Bureau continually researches and develops new technology in the fields of geographic information systems (GIS) and web services to lessen the burden of our BAS partners. Eligible governments with updates to provide have multiple options for participating in BAS digitally.

• BAS Partnership Toolbox. The BAS Partnership Toolbox allows eligible governments to create the submission in ArcGIS Pro. The toolbox automates data download, boundary update creation, and exports standardized files for submission.

• Geographic Update Partnership Software (GUPS). GUPS is a free, customized geographic information system software application provided by the Census Bureau. It is offered as download (GUPS Standalone) and online (GUPS Web) applications.

  • GUPS Standalone allows eligible governments to manually create boundary updates and export standardized files for submission.

  • GUPS Web allows eligible governments to manually create boundary updates or import local boundary data to automate the creation of boundary updates and export standardized files for submission.

Public access to the Census Bureau’s boundary data, applications, and accompanying tabular and spatial data files used to participate in BAS are available from the Census Bureau’s website. Paper maps are also available for download in PDF format. Additionally, the Census Bureau also provides public access to TIGERweb, an easy-to-use web-based system that enables eligible governments to view their boundaries stored in the Census Bureau’s Topologically Integrated Geographic Encoding and Referencing (TIGER) System for accuracy and in relation to other geographic data and imagery.

All eligible governments can respond to the survey electronically. The Census Bureau estimates that over 90 percent of the eligible government who respond to BAS will do so electronically. The Census Bureau notifies eligible governments about BAS through email or phone, if no email address is on file. Eligible governments respond on the BAS website or through email to indicate if they have updates to provide the Census Bureau. Those with updates can choose to create their submission using the BAS Partnership Toolbox, GUPS Standalone, GUPS Web, all are free of charge and can be found on the Census Bureau’s website. Updates created by these applications are then returned through the Census Bureau’s secure online data sharing portal.

To support BAS, the Census Bureau also conducts multiple online webinars for governments eligible to participate in the survey.

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 Question 2.

Boundary data can be obtained and updated from tribal, state, and general-purpose local governments; however, the Census Bureau is the designated federal agency through OMB Circular A-16. There is no similar federal boundary data collection occurring on a consistent national basis.

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

To reduce the burden on all respondents, the Census Bureau accepts spatial data that meet our quality standards. Eligible governments that respond online and/or provide a BAS submission using digital response method are not required to use paper materials.

In addition, to reduce burden on smaller governments, the Census Bureau maintains state and county (CBAS) agreements that coordinate the sharing of information and resources between the federal government and state or county governments in collecting boundary information for general-purpose local governments. These agreements aim to reduce the duplication of effort across various levels of governments as well as the cost and time burden associated with BAS participation.

The Census Bureau currently maintains two types of state agreements. In the first type of agreement, the state reports boundary updates for all eligible governments within its jurisdiction. Eligible governments in this type of agreement are notified about BAS; however, they do not receive the request to provide updates and are instructed to report all boundary updates to the state. Under the second type of agreement, the state provides the Census Bureau with a list of eligible governments that reported boundary changes. The Census Bureau uses the list to target those general-purpose local governments during BAS.

CBAS agreements also allow county or county-equivalent governments to submit updates for eligible general-purpose local governments within their jurisdiction. Once under an agreement, these governments are notified about BAS; however, they do not receive the request to provide updates and are instructed to report all boundary updates to the county or county-equivalent government.

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.

BAS must continue to support the decennial census, ACS, PEP, Economic Census, as well as other censuses and surveys. Conducting BAS less frequently would reduce the efficiency in preparing for the decennial census and Economic Census, and annual ACS and PEP data releases. Conducting BAS less frequently would also disrupt the flow of information to the agencies that use this information in administering their programs. BAS is the only current federal source of a nationally consistent inventory of governments, their legal status, and their boundaries.

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 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.

BAS data collection does not require any of the special circumstances mentioned above.

• BAS is an annual program. There are no special circumstances that require eligible governments to report more often than annually.

• There are no special circumstances that require eligible governments to prepare a written response fewer than 30 days from the start of BAS.

• There are no special circumstances in BAS that require eligible governments to submit more than an original and two copies of any document they submit.

• There are no special circumstances in BAS that require eligible governments to retain records for more than three years.

• BAS is not a statistical survey. There are no special circumstances in connection with a statistical survey.

• There are no special circumstances in BAS that require the use of a statistical data classification that has not been reviewed and approved by the OMB.

• There are no special circumstances in BAS that requires eligible governments to take an oath of confidentiality.

• There are no special circumstances in BAS that require the inclusion of proprietary trade secrets or other confidential information.

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.

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.

The 60-day Federal Register Notice (FRN) announcement publication date was on May 6, 2024, Vol. 89, No. 88 (pages 37169-37172). The public comment period closed on Friday, July 5, 2024. The Census Bureau received three comments for this FRN. One comment involved the timing of the results of the annual BAS and how they are reported back to participants. The Census Bureau will take this comment into consideration with future planning and notes that legal boundary changes provided to BAS by March 1 are incorporated into all ACS data products which are published each summer. Additionally, all legal changes submitted to BAS are available in the next year’s BAS products, published at the beginning of each calendar year. The two additional comments are out-of-scope for this information collection.

The purpose, methodology, and problems with BAS are discussed with eligible government officials, plus a network of frequent users of Census Bureau data, during periodical local and national meetings with tribal, state, and general-purpose local government stakeholders. Discrepancies in maps are discussed with government officials at the time the officials are contacted during problem resolution. As the primary stakeholders in the accuracy of boundary information and the resulting data, respondents are cooperative and willing to provide BAS information. The following is a representative sample of the officials we consulted with during the 2024 BAS.

Table 1: Sample of Respondents Consulted During 2024 BAS

Contact Information	Contact Information
State of Arkansas Shelby Johnson State Geographic Information Officer 1 Capital Mall Suite 6D Little Rock, AR 72201 501-682-2943 <[email protected]>	State of Washington Mike Mohrman Senior Forecast Analyst Financial Management, Forecasting & Research Division 106 11th Ave SW Suite 2200 Olympia, WA 98501 360-902-0599 <[email protected]>
State of Georgia Lisa Westin Senior GIS Specialist Community Affairs 60 Executive Park S NE Atlanta, GA 30329 404-679-3135 <[email protected]>	State of Wisconsin Ryan Squires GIS Manager Legislative Technology Services Bureau 17 W Main Street Suite 200 Madison, WI 53703 608-283-1814 <[email protected]>

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

The Census Bureau does not pay respondents or provide them with gifts for responding to BAS.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.

All information requested in this survey is public information of a non-sensitive nature and available to any person requesting it by participating officials. The Census Bureau informs eligible governments of the voluntary nature of BAS in the introductory email, or for those without an email on file, in a phone call. In addition, the Census Bureau provides the OMB approval number, expiration date, and reasons for data collection.

11. 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 in BAS.

12. 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. 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. Instead, this cost should be included under ‘Annual Cost to Federal Government’ (Item #14).

Table 2: Estimated Annualized Respondent Burden Hours

Information Collection	Estimated Annual # of Respondents (a)	Estimated Annual # of Responses / Respondent (b)	Total # of Annual Responses (c) = (a) x (b)	Estimated Burden Hours/ Response (d)	Total Annual Burden Hour (e) = (c) x (d)
BAS, State Certification, Boundary Quality Project	40,000	1	40,000	7.5 hours	300,000 hours
Feedback	1,000	1	1,000	0.5 hours	500 hours
Totals			41,000		300,500 hours

Table 3: Estimated Annualized Respondent Costs

Type of Respondent / Occupational Title	Number of Respondents	Number of Responses per Respondent	Average Burden per Response	Hourly Wage Rate*	Total Burden Costs
BAS, State Certification, Boundary Quality Project	40,000	1	7.5 hours	$34.78	$10,434,000
Feedback	1,000	1	0.5	$34.78	$17,390
Totals	-	-	-	-	$10,451,390

*Hourly wage rate is derived from the May 2023 National Occupational Employment and Wage Estimates report located at the following website: <www.bls.gov/bls/blswage.htm> by averaging the mean hourly wage for the five common position types that normally respond to Census Bureau geographic programs, e.g., Geographers ($44.45), Cartographers/Photogrammetrists ($37.89), Surveyors ($35.58), Surveying/Mapping Technician ($26.00), Municipal Clerks ($23.44) and Urban/Regional Planner ($41.32). 

The Census Bureau based the estimated hour burden using information from the 2022, 2023, and 2024 BAS cycles. The estimate of 7.5 hours per response is based on an average of 5 hours for an eligible government with no updates and 10 hours for an eligible government with updates to report. To provide feedback, the Census Bureau estimates that eligible governments will need no more than 30 minutes to prepare their response. The total maximum number of burden hours for the timeframe of the operation is 300,500 hours (i.e., 40,000 x 7.5 hours + 1,000 x 0.5 hours).

13. Provide an estimate for 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 already reflected on the burden worksheet).

Other than the staff time to prepare the submission, there are no capital costs or operating and maintenance costs associated with this information collection.

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.

The estimate to conduct the BAS is approximately $6,000,000 annually. This includes all costs for the Census Bureau’s National Processing Center and headquarters. The Census Bureau’s Geography Division has reviewed all requirements for conducting the BAS, including material and person-hour costs to arrive at this estimate and have determined that the resources are available for efficient administration of the BAS.

15. Explain the reasons for any program changes or adjustments reported in ROCIS.

The following changes have been made to the BAS program for the 2025-2027 clearance cycle. Many of the changes outlined below are designed to reduce the amount of paper materials included in the survey as well as the overall cost to conduct the survey.

• The Census Bureau will no longer provide eligible governments a hard-copy of the BAS introductory letter or paper response form. All BAS communication will be done through email or by phone if no email address is on file.

• The Census Bureau will no longer conduct nonresponse follow-up over the phone. Only eligible governments without a valid email address on file will be contacted by phone. Additional nonresponse email notifications will be sent to eligible governments to encourage participation in BAS.

• The Census Bureau will only accept legal boundary changes for BAS resulting from any legal action taking by the eligible government(s) to add or remove land to their official boundary. Boundary corrections that are the result of spatial inaccuracies and do not substantially alter the Census Bureau’s representation of the boundaries will be implemented as time permits.

• The Census Bureau will offer GUPS Web as a method to submit BAS updates. GUPS Web is an online application that allows eligible governments to manually create boundary updates or import local boundary data to automate the creation of boundary updates and export standardized files for submission.

• The Census Bureau will no longer offer the BAS Partnership Toolbox for ArcGIS Desktop as a method to submit updates to the Census Bureau. ArcGIS Desktop was decommissioned at the Census Bureau as of March 1, 2024. A new toolbox was created to support use of ArcGIS Pro.

• The Census Bureau will no longer offer CD/DVD materials. All materials used to create a BAS submission will be able to be downloaded from the Census Bureau’s BAS website. The Census Bureau will continue to provide paper maps to eligible governments on request.

• The Census Bureau added a feedback component that may apply to a maximum of 1,000 eligible governments. As a result, the estimated burden hours were increased 500 hours, from 300,000 to 300,500 hours annually.

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.

The information collected in BAS is published both internally and externally to fulfill program requirements. The priority of BAS is to fulfil the agency’s responsibility as part of the National Spatial Data Infrastructure, for which the OMB Circle A-16 designates the Census Bureau as the lead federal agency for maintaining national data about legal government boundaries, as well as statistical and administrative boundaries.

Because BAS relies on external engagement from eligible governments, updates submitted to BAS are published in the BAS partnership shapefiles created by the Census Bureau. These files are made available to the public and are the primary source used by eligible governments in reviewing their boundary data and providing updates to BAS.

The annual BAS schedule is reflected in the table below:

Table 4: BAS Schedule

Date	Activity
January 1	Legal boundary changes must be in effect on or before this date to be reported in the current survey year.
January to May	The Census Bureau conducts BAS.
Early January	The Census Bureau notifies eligible governments about BAS through email. Eligible governments are contacted through email to determine if they have legal boundary, CDP, linear feature, or contact updates to report. Any eligible government without an email on file with the Census Bureau will be contacted by phone and asked to provide their response.
Mid-February, Mid-March, and Mid-April	The Census Bureau conducts nonresponse follow-up for BAS through email. Eligible governments that have not responded to annual response, along with those that indicated they have updates to report but have not yet submitted those updates, are contacted through email on up to three occasions.
March 1	Legal boundary changes returned by this date will be reflected in the ACS and PEP data and in next year’s BAS materials.
May 31	Legal boundary changes returned by this date will be reflected in next year’s BAS materials. If time permits, boundary corrections returned by this date may also be shown.

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 Census Bureau will display the expiration date for OMB approval on the collection instruments.

18. Explain each exception to the certification statement identified in “Certification for Paperwork Reduction Act Submissions.”

There are no exceptions. The agency certifies compliance with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

Appendix A–BAS Materials List (This table contains 29 materials used in support of BAS.)

Table 5: List of BAS Materials

ID	Description or Title	Type of Material
BAS-E-1	Email to all non-tribal BAS contacts of all eligible governments that are not within a state or consolidated BAS (CBAS) agreement.	Email
BAS-E-2	Email to all tribal BAS contacts.	Email
BAS-E-3	Email to the highest elected officials of all eligible governments within a state or CBAS agreement.	Email
BAS-E-4	Courtesy copy email to the highest elected officials of all eligible governments that are not within a state or CBAS agreement.	Email
BAS-E-SA	Email to all BAS state agreement contacts.	Email
BAS-E-SDC	Email to all Census Bureau State Data Centers informing them about BAS and asking them to encourage eligible governments in their state to participate in the survey.	Email
BAS-E-NRFU-1	Nonresponse follow-up email to all governments that have not responded to BAS.	Email
BAS-E-NRFU-2	Nonresponse follow-up email to all governments that have responded that there are updates to report but have not yet submitted those updates.	Email
BAS-E-SWIM-HASACCT	Email to the BAS contact of all eligible governments that request to use the BAS Partnership Toolbox or GUPS. The email provides notification that the BAS contact already has access to the Census Bureau’s secure online data sharing portal.	Email
BAS-E-SWIM-TOKEN	Email to the BAS contact of all eligible governments that request to use the BAS Partnership Toolbox or GUPS. The email provides a token to access the Census Bureau’s secure online data sharing portal.	Email
BAS-E-WEB	Email to all eligible governments that signed up to attend an informational webinar about BAS.	Email
BASSC-E-1	Email to the Governors notifying them of the program and asking them to appoint a State Certifying Official (SCO).	Email
BASSC-E-2	Email to the SCO notifying them of their appointment and next steps.	Email
BASSC-E-3	Email to local governments notifying them the SCO has submitted additional legal changes to their boundary that are not in the Census Bureau records and additional action is needed.	Email
BASSC-E-4	Email to local governments notifying them the SCO has requested changes be removed from their boundary due to failure to report them to the appropriate state agency and additional action is needed.	Email
BASSC-E-NRFU-1	Follow-up email to governors reminding them to appoint an SCO before the deadline.	Email
BASSC-E-NRFU-2	Follow-up email to SCO asking them to review listing files and submit changes to the Census Bureau before the deadline.	Email
BAS-6	Fillable form used for county or county equivalent governments to sign up for a CBAS agreement.	Fillable Form
BASSC-1	Fillable form sent as an attachment with BASSC-E-1 to Governors to appoint an SCO.	Fillable Form
BASSC-3	Prefilled form sent as an attachment with BASSC-E-3 to local governments listing boundary changes reported by the SCO that are not in the Census Bureau records.	Prefilled Form
BASSC-4	Prefilled form sent as an attachment with BASSC-E-4 to local governments listing boundary changes reported by the SCO that are not valid and have been removed from Census Bureau records.	Prefilled Form
BAS Feedback Form	Fillable form that may be used to capture feedback about materials, method(s) of data collection, manner of communications, and the usability of the program applications and tools.	Fillable Form
BAS-L-9	Cover letter for paper map packages sent to eligible governments that requested to provide updates on paper maps.	Letter
BAS Partnership Toolbox Pro – How-to Guide	Instructional document for users of Esri ArcGIS Pro to guide them through the steps of creating a BAS submission using the Census Bureau’s Partnership Toolbox.	How-to Guide
BAS GUPS Standalone – How-to Guide	Instructional document for users of GUPS to guide them through the steps of creating a BAS submission using the standalone version of GUPS.	How-to Guide
BAS Paper Maps – How-to Guide	Instructional document for paper map submission creation.	How-to Guide
BAS State Certification – How-to Guide	Instructional document that guides SCOs on how to review the changes submitted by local governments and provide changes back to the Census Bureau.	How-to Guide
BAS Technical Guide	Supplemental resource that includes background information and technical details in support of BAS.	How-to Guide
BAS TIGERweb Quick Guide	High-level instruction and guidance for using TIGERweb in support of BAS.	Quick Guide

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