Supporting Statement for Paperwork Reduction Act Submissions
General Instructions
A Supporting Statement, including the text of the notice to
the public required by 5 CFR 1320.5(a)(i)(iv) and its actual
or estimated date of publication in the Federal Register,
must accompany each request for approval of a collection of
information. The Supporting Statement must be prepared in
the format described below, and must contain the
information specified in Section A below. If an item is not
applicable, provide a brief explanation. When Item 17 of the
OMB Form 83-I is checked "Yes", Section B of the
Supporting Statement must be completed. OMB reserves
the right to require the submission of additional information
with respect to any request for approval.
Specific Instructions
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.
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.
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.
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.
5. If the collection of information impacts small businesses
or other small entities (Item 5 of OMB Form 83-I), describe
any methods used to minimize burden.
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.
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.
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 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 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.
9. Explain any decision to provide any payment or gift
to respondents, other than reenumeration of
contractors or grantees.
10. Describe any assurance of confidentiality provided
to respondents and the basis for the assurance in
statute, regulation, or agency policy.
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.
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 in Item
13 of OMB Form 83-I.
* 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 in Item 13.
13. Provide an estimate for the total annual cost
burden to respondents or recordkeepers resulting
from the collection of information. (Do not include
the cost of any hour burden shown in Items 12 and
14).
* 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. 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 collections
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
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