Supporting_Statement

The Supporting Statement for OMB 0596-NEW

FEDERAL EXCESS PERSONAL PROPERTY

June 2008

The Supporting Statement for OMB 0596-NEW

FEDERAL EXCESS PERSONAL PROPERTY

June 2008

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.

Laws, Regulations, and Statutes:

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

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

The Federal Property Services and Administrative Assistance Act of 1949 and the Cooperative Forestry Assistance Act of 1978, as amended, authorize the 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. Program managers became aware of the lack of OMB approval for this information collection while reviewing regulatory requirements pertinent to creation of an automated FEPP process. The Forest Service is now intent on bringing this program into compliance with the Paperwork Reduction Act.

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 Forest Service Federal Excess Property Management Information System (FEPMIS) database will allow the Forest Service to collect this information electronically, as well as managing inventory. Access to the database is limited to those 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.)

The following information will be collected via the FEPMIS database:

• 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 collected from employees of participating state agencies granted access to the database.

Access requested through state foresters to Forest Service property management officers. Only authorized recipients of Federal Excess Personal Property (FEPP) granted access to the Forest Service Federal Excess Property Management Information System (FEPMIS).

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

The collected information is used to manage FEPP 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.

• Records and Inventory (Includes inventories of accountable personal property such as AD-112, Report of Unserviceable, Lost or Damaged Property, AD-113, Fiscal Inventory Report For The Period Ending and PMIS/Property Report #350.) (N1-95-88-2) – Retention Period is 5 years after file closed.

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?

Information is collected via an electronic database (FEPMIS) that requires Forest Service approved user names and passwords. Generation of official forms occurs when users enter pertinent data and the Forest Service Property Management Officer approves the request. Several screens require entry of mandatory information prior to submission to the Forest Service for approval. There will be no other options for reporting this data.

5. How frequently will the information be collected?

It is estimated that 100 respondents will provide 5,400 responses annually or 54 responses each.

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

No

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

This ongoing collection does not have an OMB number.

The same requirements have existed for 52 years. Changes have occurred in the technology used, but the collection parameters remain the same.

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 FEPMIS database enables state cooperators to inform Forest Service officials of the condition of property loaned to these cooperators. The information provided to the Forest Service includes condition of property loaned, current location of property, description of property, and any additional relevant details. The database also manages inventory and certification. The use of the database will reduce the burden on state cooperators as well as Forest Service property management officers. The Internet-based system will generate 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 purpos­es de­scri­bed in Item 2 above.

The Forest Service has no other database that allows state cooperators access to view property information or the status of property. FEPMIS works with PMIS/PROP, identifying the status of property, preventing duplication of changes or request.

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

This program does not impact any 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.

Inventory management by the Forest Service is a huge undertaking. The current FEPP program has over 35 thousand Federal inventory items with an acquisition value of over 1 billion dollars.

Currently, if a state agency makes a change to a property item, an e-mail or fax is transmitted to the appropriate Forest Service office. If the e-mail or fax is not received, for whatever reason, the Forest Service does not record the property information. Often, identification of incorrect property information does not occur until an official inventory is performed (biennially).

The FEPP is a substantial inventory and would be easier to manage using an electronic database (such as FEPMIS) that provides needed information with the click of a button. We expect the FEPMIS database will save substantial time and money for both state agencies and the Forest Service.

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;

Acquisition and disposal of property items occurs daily, therefore, it is in the best interest of the Federal government to track actions as they occur.

• Requiring respondents to prepare a writ­ten response to a collection of infor­ma­tion in fewer than 30 days after receipt of it;

Currently, the Forest Service does not know if the state or territory cooperator receives the property until the receipt is reported. The Forest Service works with 50 states and 5 territories, and it is common for a million dollars in Personal Property to enter or leave the Agency’s possession on a given day. Requiring a written response allows the Agency and states to track acquisition and disposal of property from beginning to end.

• 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;

The Forest Service owned database will automatically retain the records as outlined in Forest Service Handbook 6209.11 – Records Management, file code 6410.

• 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 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.

A Federal Register Notice for this information collection was published on November 27, 2007, in Volume 72, page 66130. Once comment was received, from B. Sachau. The commenter stated that the property belongs to the taxpayers, and that USDA is out to lunch and needs purpose and direction. The Forest Service did not respond to this comment.

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 record keeping, 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.

The Forest Service consulted with four persons outside the Agency, to obtain their views on this information collection. The following questions were asked:

1. Will the use of FEPMIS allow you to provide the Forest Service with the required FEPP property information?

2. Do you wish to access FEPMIS 24 hours a day/ 7 days a week through the internet with an authorized User ID and Password?

3. Is it reasonable for the Forest Service to request you enter your property receipts, changes, and modifications within 14 days of taking custody of FEPP or becoming aware of changes to property status or information?

4. Will your agency benefit by using FEPMIS to provide you with property and inventory information as needed?

5. Does FEPMIS provide clear instructions and direction on how to enter data?

6. Are all the responsibilities of reporting data available in FEPMIS (i.e. required property information, transfer orders, change of status, and report for lost/stolen/damaged property)?

7. Is there something else that needs to be included in FEPMIS?

8. Can sufficient reports be generated in FEPMIS?

9. Is property easily identifiable in FEPMIS?

10. Comments

Commenters

• Randy Pogue

RFP Coordinator

Arkansas Forestry Commission

PO Box 10 Greenbrier, AR. 72058

Phone Number: 501-679-3186

randy.pogue@arkansas.gov

Responses

1. Yes

2. Yes

3. Yes

4. Yes

5. Yes

6. Yes

7. No

8. Yes

9. Yes

10. None

• William F. Gifford

Property Administrator III

Florida Division of Forestry

3125 Conner Blvd. Tallahassee, FL 32399

Phone Number: 850-922-0261

gifforb@doacs.state.fl.us

Responses

1. Yes

2. Yes

3. Yes, 14 days from custody and not from request date.

4. Yes

5. Yes

6. Yes

7. No

8. Yes

9. Yes

10. FEPMIS is the ideal format for me as a state manager, as I can access the information from any Division site at any time.

• Todd Lafleur

FEPP Manager - Massachusetts

Massachusetts Forestry

PO Box 66, So. Carver, MA 02366

Phone Number: 508-866-2580 x 108

Todd.lafleur@state.ma.us

Responses

1. Yes

2. Yes

3. Yes

4. Tremendously!

5. Yes

6. Yes

7. Not at this time.

8. Yes

9. Yes

10. FEPMIS is an invaluable tool for State (FEPP Program) Managers and something that has eliminated compiling results in two different locations.

• Darlene Bolser

Administrative Assistant

Department of Agriculture, Food and forestry – Oklahoma Forestry Division

830 NE 12^th Ave.

Phone Number: 405-288-2385

Darlene.bolser@oda.state.ok.us

Responses

1. Yes

2. Yes

3. Yes

4. Yes

5. Yes

6. Yes

7. Yes, fields for state and federal legislature districts.

8. The ability to pull reports by legislative districts could be beneficial to our state.

9. Yes

10. FEPMIS will be a great tool for our agency. By using FEPMIS for disposal of property, 90 percent of the information will already be in FEPMIS. We will add the additional information requested and the form is generated by FEPMIS. This will save us from hand typing the SF-120 and AD-112 forms.

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

There will not be any payment or gift to respondents

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

The database is User Id and Password protected. Information collected is not available to the public unless requested through the Forest Service Washington Office/Regional/Area program managers. Records are of property information only and User Id set up does not require any information of personal or sensitive nature. Contact information for respondents is listed as work numbers and work e-mail addresses.

9. 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.

None of the examples of information listed above will be collected in FEPMIS.

9. 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.

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form.

a) Description of the collection activity

b) Corresponding form number (if applicable)

c) Number of respondents

d) Number of responses annually per respondent,

e) Total annual responses (columns c x d)

f) Estimated hours per response

g) Total annual burden hours (columns e x f)

Table 1 - Response Burden

(a) Description of the Collection Activity	(b) Form Number	(c) Number of Respondents	(d) Number of responses annually per Respondent	(e) Total annual responses (c x d)	(f) Estimate of Burden Hours per response	(g) Total Annual Burden Hours (e x f)
Data Entry – Transfer, Report of Excess, Report of lost/stolen/damaged equipment/ internal transfer	FEPMIS	100	54	5400	.10	540

• Record keeping burden should be addressed separately and should include columns for:

a) Description of record keeping activity:

b) Number of record keepers:

c) Annual hours per record keeper:

d) Total annual record keeping hours (columns b x c):

Table 2 - Record-Keeping Burden

(a) Description of record keeping activity	(b) Number of Record keepers	(c) Annual hours per record keeper	(d) Total annual record keeping hours (b x c)
Property receipts	50	30.5	1525
Inventory modifications	50	100	5000
Totals	100	---	6525

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

Table 3 - Estimated Cost to Respondents

(a) Description of the Collection Activity	(b) Estimated Total Annual Burden on Respondents (Hours)	(c)* Estimated Average Income per Hour	(d) Estimated Cost to Respondents
Response	540	$ 15.81	$ 8,537.40
Record Keeping	6525	15.81	103,160.25
Totals		---	$111,69765  $111,698

According to the Bureau of Labor statistical data for February 2008, found at http://www.bls.gov/news.release/pdf/realer.pdf. The average hourly salary for a general worker is $15.81, which was used as the positions doing the data entry best fit into that category.

9. 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 and maintenance costs.

9. Provide estimates of annualized cost to the Federal government. 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.

The response to this question covers the actual costs the agency will incur as a result of implementing the information collection. The estimate should cover the entire life cycle of the collection and include costs, if applicable, for:

• Employee labor and materials for developing, printing, storing forms

• Employee labor and materials for developing computer systems, screens, or reports to support the collection

• Employee travel costs

• Cost of contractor services or other reimbursements to individuals or organizations assisting in the collection of information

• Employee labor and materials for collecting the information

• Employee labor and materials for analyzing, evaluating, summarizing, and/or reporting on the collected information

Table 4 - Estimated Annual Cost to the Government

ACTION ITEM	PERSONNEL	GS/Step	HOURLY RATE*	HOURS	Cost to the Govt.
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.	Program Manager	(1) GS-13/2	$44.174	2080	$91,881.92
Employee Labor – Collection of information; analyzing, evaluating, summarizing, and reporting; and, program reviews and technical assistance	9 Property Management Officers	(1) GS 12/1 (3) GS 12/2 (4) GS 12/3 (1) GS 13/6	$ 35.945 37.141 38.35 49.868	2,080 2,550 1,550 1,600	$ 74,765.60 94,709.55 59,442.50 79,788.80
Employee Labor – Collection of information; analyzing, evaluating, summarizing, and reporting; and, program reviews and technical assistance	9 Property Technicians	(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	$ 21.619 26.338 26.442 28.925 30.992 33.995 34.996	1,800 2,080 2,880 350 200 2,080 2,080	$ 38,914.20 54,783.04 76,152.96 10,123.75 6,198.40 70,709.60 72,791.68
Office Supplies (paper, file cabinet, fax machine)	---	---	---	---	$ 5,000.00
Travel Costs	---	---	---	---	$ 57,500.00
Total Annual Cost to the Government					$ 792,762.00

* Taken from: http://www.opm.gov/oca/08tables/index.asp - Cost to Government calculated as hourly wage multiplied by 1.3; Salary Table 2008-GS used, no locality pay incorporated into calculations, as listed positions are located throughout the United States. Assumption made that the 30 percent margin for other salary costs includes any increases in base pay due to locality differential.

9. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of OMB form 83-I.

This is a new information collection.

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

Results will not be published.

9. If seeking approval to not display the expiration date for OMB approval of the information collection, explain the reasons that display would be inappropriate.

Agency plans on displaying expiration date on initial data entry screen.

9. Explain each exception to the certification statement identified in item 19, "Certification Requirement for Paperwork Reduction Act."

No exceptions needed.

B. Collections of Information Employing Statistical Methods

This information collection does not employ statistical methods.

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