Narrative of Changes

Changes to Collection OMB No. 1660-0001

The following questions have been updated since the last OMB Approval:

2. Identify 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. Provide a detailed description of: a) how the information will be shared, if applicable, and for what programmatic purpose. Changes are the new form number assigned and a more descriptive narrative about the collection.

FEMA Form 646-0-1 (new number assignment replacing FEMA Form 85-3), National Defense Executive Reserve Personal Qualifications Statement, is an application form that is used by Federal departments and agencies to fill NDER vacancies. To become a Reservist, individuals with the requisite qualifications must complete the application form. FEMA serves as the NDER coordinator for all Federal departments and agencies. As the government-wide coordinator, FEMA ensures that applicants are not already serving in a Federal department or agency sponsored unit; reviews the application form to ensure that the candidate meets all basic membership qualifications for the program; and in some cases, determines the Federal department or agency best suited for the applicant.

 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. Changes reflect the electronic submission capabilities of the collections.

This completed collection of information tool can be sent to FEMA via fax at (940) 323-2766 or scanned into a PDF document and then submitted via e-mail.

12. Provide estimates of the hour burden of the collection of information. The statement should: Changes are detailed in Question 15.



 a. 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 desired. 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.

The estimated annual hour burden FEMA Form 646-0-1 for this collection is .5 hours per response, and based on 10 respondents completing this application form the estimated total annual hour burden is 5 hours.

 b. 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.

c. 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 14.

Table A.12: Estimated Annualized Burden Hours and Costs

Type of Respondent	Form Name / Form Number	No. of Respondents	No. of Responses per Respondent	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate (x1.4)	Total Annual Respondent Cost
Individuals or households	National Defense Executive Reserve Personal Qualifications Statement / FEMA Form 646-0-1	10	1	.5 Hours	5 Hours	101.88	$509.40
Total		10			5 Hours		$509.40

According to the U.S. Department of Labor, Bureau of Labor Statistics website (www.bls.gov) the wage rate category for Chief Executives is estimated to be $101.88 per hour (including the 1.4 modifier representing wage plus benefit); therefore, the estimated burden hour cost to respondents Chief Executive is estimated to $509.40 annually.

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 have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table. Changes are based on a reduction in the number of respondents.

The estimate is based on receiving 10 applications.

ANNUALIZED COST TO THE FEDERAL GOVERNMENT
Item	Cost ($)
Staff Salaries [1 GS-14 Analyst @ $43.98/hour spending approximately 1 hour per application in collection-related activities.	$219.90
Total	$219.90



15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I. Changes in hour burden, i.e., program changes or adjustments made to annual reporting and recordkeeping hour and cost burden. A program change is the result of deliberate Federal government action. All new collections and any subsequent revisions of existing collections (e.g., the addition or deletion of questions) are recorded as program changes. An adjustment is a change that is not the result of a deliberate Federal government action. These changes that result from new estimates or actions not controllable by the Federal government are recorded as adjustments. See the notes below for details on the changes made.



Itemized Changes in Annual Burden Hours
Data collection Activity/Instrument	Program Change (hours currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (hours currently on OMB Inventory)	Adjustment (New)	Difference
National Defense Executive Reserve Personal Qualifications Statement / FEMA Form 646-0-1				15	5	-10
Total(s)				15	5	-10

Explain:

Funding for the program has been reduced and as a result the number of positions expected to be filled has been reduced, which reduces the number of respondents and decreases the total annual burden hours.

Itemized Changes in Annual Cost Burden
Data collection Activity/Instrument	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New)	Difference
National Defense Executive Reserve Personal Qualifications Statement / FEMA Form 646-0-1				$1,015.00	$509.40	- $505.60
Total(s)				$1,015.00	$509.40	-$505.60

Explain:

Due to the reduction in number of respondents expected as a result of reduced funding, the total annual cost burden is also affected.