Icr 2502-0233

Paperwork Reduction Act Submission

Please read the instruction before completing this form. For additional forms or assistance in completing this forms, contact your agency’s Paperwork Reduction Officer. Send two copies of this form, the collection instrument to be reviewed, the Supporting Statement, and any additional documentation to: Office of Information and Regulatory Affairs, Office of Management and Budget, Docket Library, Room 10102, 725 Seventeenth St. NW, Washington, DC 20503.

1. Agency/Subagency Originating Request: U.S. Department of Housing and Urban Development U.S. Department of Housing and Urban Development, Office of Manufactured Housing Programs		2. OMB Control Number: a. 2502-0233	b. None      
3. Type of information collection: (check one) New Collection Revision of a currently approved collection Extension of a currently approved collection Reinstatement, without change, of previously approved collection for which approval has expired Reinstatement, with change, of previously approved collection for which approval has expired Existing collection in use without an OMB control number For b-f, note item A2 of Supporting Statement instructions.	4. Type of review requested: (check one) Regular Emergency - Approval requested by       Delegated 5. Small entities: Will this information collection have a significant economic impact on a substantial number of small entities? Yes No 6. Requested expiration date: a. Three years form approval date b. Other (specify)      

7. Title:

Manufactured Home Construction and Safety Standards Program

8. Agency form number(s): (if applicable)

HUD-101, HUD-203, HUD-203B, HUD-301, HUD-302, HUD-303, HUD-304

9. Keywords:

Housing, Manufactured Homes, Inspection Fees, Label Fees, Production Reports

10. Abstract:

The National Manufactured Home Construction and Safety Standards Act, 42 U.S.C. authorizes HUD to promulgate and enforce reporting standards for the production of manufactured housing. HUD uses these information collections to calculate and collect monitoring inspection fees for manufactured housing.

11. Affected public: (mark primary with “P” and all others that apply with “X”) a.   Individuals or households e.   Farms b. P Business or other for-profit f.   Federal Government c.   Not-for-profit institutions g. X State, Local or Tribal Government		12. Obligation to respond: (mark primary with “P” and all others that apply with “X”) a.   Voluntary b.   Required to obtain or retain benefits c. P Mandatory
13. Annual reporting and recordkeeping hour burden: a. Number of respondents (161 manufacturers, 15 IPIAs) 176 b. Total annual responses 5,622 Percentage of these responses collected electronically 98% c. Total annual hours requested 2,811 d. Current OMB inventory 3,491 e. Difference (+,-) -680 f. Explanation of difference: 1. Program change: 0 2. Adjustment: -680		14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) a. Total annualized capital/startup costs 0 b. Total annual costs (O&M) 0 c. Total annualized cost requested 0 d. Total annual cost requested 0 e. Current OMB inventory 0 f. Explanation of difference: 1. Program change: - 2. Adjustment: -
15. Purpose of Information collection: (mark primary with “P” and all others that apply with “X”) a. P Application for benefits e. X Program planning or management b.   Program evaluation f.   Research c.   General purpose statistics g. X Regulatory or compliance d.   Audit		16. Frequency of recordkeeping or reporting: (check all that apply) a. Recordkeeping b. Third party disclosure b. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biannually 8. Other (describe)      
17. Statistical methods: Does this information collection employ statistical methods? Yes No	18. Agency contact: (person who can best answer questions regarding the content of this submission) Name: Adrian Browner Phone: 202-708-6423 x4532

19. Certification for Paperwork Reduction Act Submissions

On behalf of this Federal Agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9.

Note: The text of 5 CFR 1320.9, and the related provisions of 5 CFR 1320/8(b)(3). Appear at the end of the instructions. The certification is to be made with reference to those regulatory provisions as set forth in the instructions.

The following is a summary of the topics, regarding the proposed collections of information, that the certification covers:

1. It is necessary for the proper performance of agency functions;

2. It avoids unnecessary duplication;

3. It reduces burden on small entities;

4. It uses plain, coherent, and unambiguous terminology that is understandable to respondents;

5. Its implementation will be consistent and compatible with current reporting and recordkeeping practices;

6. It indicates the retention periods for recordkeeping requirements;

7. It informs respondents of the information called for under 5 CFR 1320.8(b)(3):

1. Why the information is being collected;

2. Use of the information;

3. Burden estimate;

4. Nature of response (voluntary, required for a benefit, or mandatory);

5. Nature and extent of confidentiality; and

6. Need to display currently valid OMB control number;

8. It was developed by an office that has planned and allocated resources for the efficient and effective management and use of the information to collected (see note in item 19 of the instructions);

9. It uses effective and efficient statistical survey methodology; and

10. It makes appropriate use of information technology.

If you are unable to certify compliance with any of these provisions, identify the item below and explain the reason in item 18 of the Supporting Statement.

     

Signature of Program Official: X Michael Winiarski, Director, Organizational Policy, Planning and Analysis Division, HROA	Date:
Signature of Senior Officer or Designee: X Lillian Deitzer, Departmental Reports Management Officer Office of Investment Strategies, Policy, and Management, Office of the Chief Information Officer	Date:

Supporting Statement for Paperwork Reduction Act Submissions

A. Justification

1. This request for OMB review and approval seeks extension of the subject information collection systems. The National Manufactured Housing Construction and Safety Standards Act (42 U.S.C. 5401-5426) established the construction and safety standards for manufactured housing in the United States. 42 U.S.C. 5413, Inspections and investigations for promulgation or enforcement of standards or execution of other duties, prescribes the authority of the Secretary and requires that he shall furnish the Attorney General and, when appropriate, the Secretary of the Treasury, any information indicating noncompliance with such standards for appropriate action. 42 U.S.C. 5413(c)(3) authorizes the Secretary to require reports or answers in writing to specific questions relating to the function of the Secretary under this statute.

HUD regulations for the program are found at 24 C.F.R. 3282.1 through 3282.554. Specific regulations for this collection of information are as follows:

24 C.F.R. Section 3282.362 requires the Production Inspection Primary Inspection Agency (IPIA) to obtain certification labels from the Secretary or the Secretary’s agent, requires manufacturers to request certification labels from their IPIAs, and requires the IPIA to replace damaged certification labels.

24 C.F.R. Section 3282.501 authorizes the Secretary to take such actions to oversee the system as the Secretary deems appropriate.

24 C.F.R. Section 3282.552 authorizes the Secretary to establish and impose on manufacturers, dealers, and distributors of manufactured housing such reasonable fees as may be necessary to offset the expense incurred by the Secretary in conducting inspections required by the Act.

24 C.F.R. Section 3282 Sections 552 and 553 require the IPIA to report monthly the number and location of homes manufactured in any factory.

2. This information collection is used in conjunction with labels, which are 2-inch x 4-inch metal tags permanently attached to each section of manufactured homes to provide a unique identifying number to each home produced under the HUD-code. Labels are required by 24 CFR 3282.362(c)(2). Respondents are both approved Production Inspection Primary Inspections Agencies (IPIAs) as described in 24 CFR 3282.362, and producers of manufactured homes as defined in 24 CFR 3280. Through HUD’s Monitoring and Inspection Contractor, labels are issued to HUD-approved IPIA agencies and label fees are collected. IPIAs in turn issue the labels to manufacturers that they service. The information collected provides the Department with information that will help identify a manufactured home after it leaves the plant. The information will facilitate any recall or safety-related defect campaigns, and provide the data that is needed to pay required fees or credits for program participants in the various states where such homes are shipped.

Form HUD-101, IPIA Request for Labels, is used by the IPIA to obtain certification labels from HUD’s monitoring agent. 67% of respondents are state agencies; 33% of respondents are private businesses.

Form HUD-203, Lost Label Report, is used by the IPIA to report any lost labels or salvaged manufactured home units. The information collected here will be used to request such lost labels or salvaged units. This form must be submitted within 5 days of the discovery of missing labels. 67% of respondents are state agencies; 33% of respondents are private businesses.

Form HUD-203B, Damaged Label Report, is used by the manufacturer to return damaged labels to the IPIA, and by the IPIA to assign replacement labels to the manufacturer. 67% of respondents are state agencies; 33% of respondents are private businesses.

Form HUD-301, Request and Payment for Labels, is used by the manufacturer to request and pay for the needed labels. This form is prepared by the manufacturer and submitted with payment to Pay.gov and then a copy of the form and payment receipt is sent by the manufacturer to the IPIA that will provide the physical labels. The IPIA then completes the form and provides the information to HUD’s Monitoring and Inspection Contactor. The information on the HUD-301 is needed by HUD and HUD’s monitoring agency to track the request, approval, and application of authorized labels. 67% of respondents are state agencies; 33% of respondents are private businesses.

Form HUD-302, HUD Manufactured Home Monthly Production Report, is used by manufacturers to provide information to account for the shipment of homes and the calculation of monthly payments to the state agencies as required. 100% of respondents are private businesses.

Form HUD-303, Refunds Due Manufacturer, is used by manufacturer to request a refund for unused labels when a plant closes and has no parent or sister company to take the credit. The IPIA then completes the form and provides the information to HUD’s Monitoring and Inspection Contactor. 67% of respondents are state agencies; 33% of respondents are private businesses.

Form HUD-304, Adjustment Report, Monthly Production Report, is used by manufacturers to report any adjustments to previously submitted monthly production reports. 100% of respondents are private businesses.

3. HUD’s monitoring contractor uses an automated system to facilitate this information collection. Ninety-eight percent of respondents are reporting electronically.

4. The information collection is unique to the manufactured housing program and does not duplicate other data gathering methods.

5. The collection of information does not have a significant impact on a significant number of small businesses or entities.

6. Regulations at 24 CFR 3282.362(c)(2) states the inspection agency, at the convenience of the IPIA and the manufacturer, shall continuously provide the manufacturer with a two-to-four week supply of labels. The labels are the means used by HUD to create a unique identification for each section of a home built under the program and each is tracked by the label number. The construction of the units are also monitored for compliance with the manufactured housing construction and safety standards and ensure adequate quality control is taking place in the production facility. A supply quantity greater than four weeks would tend to diminish quality control effectiveness and may impact the integrity of the program if control of the labels is not tight. Yet, if the labels are not provided, manufacturers cannot produce the needed homes.

7. Monthly reports for joint monitoring fees are required per 24 CFR 3282.552, Manufacturer reports for joint monitoring fees, which states: “For each month, the manufacturer shall submit to the IPIA in each of its manufacturing plants a report that includes the serial numbers of each manufactured home at that plant during that preceding month, and the State of first location, after leaving the manufacturing plant, of such manufactured homes. The State of first location for the purpose of this report is the State of the premises of the distributor, dealer, or purchaser to whom the manufactured home is first shipped. The report for each month shall be submitted by the tenth day of the following month.”

Form HUD-203, Lost Label Report, must be completed within 5 days of discovery or loss. This requirement is necessary to preclude fraudulent use of stolen or otherwise lost labels.

8. The agency notice soliciting comments on the information collection for OMB #2502-0233 was published in the Federal Register on June 30, 2009, (Vol. 74, No. 124, page 31289-31290). No comments were received.

HUD consults regularly with the Manufactured Housing Consensus Committee (MHCC) on all matters related to HUD oversight of the manufactured housing.

9. There are no payments or gifts of any kind given to respondents.

10. Section 24 CFR 3282.54 details the requirements to be followed by HUD and its agents in protecting information which falls within the definition of confidential, commercial, or financial information. Only the monitoring agency and HUD receive the completed forms. No additional distribution to the public and to other program participants is made. Therefore any proprietary or commercial information is held in strict confidentiality.

11. There are no questions of a sensitive nature.

12. Estimate of public burden and cost to respondents:

Information Collection	Number of Respondents	Responses per Respondent	Number of Responses	Hours per Response	Total Annual Hours	Hourly Cost	Total Annual Cost
HUD-101 Request for Labels (order control)	15	12	180	0.5	90	$23	$2,070
HUD-301 Request and Payment for Labels	161	12	1932	0.5	966	$23	$22,218
HUD-302 Manufactured Home Monthly Production Report	161	12	1932	0.5	966	$23	$22,218
HUD-303 Refunds Due Manufacturer	50	1	50	0.5	25	$23	$575
HUD-304 Adjustment Report	176	8	1408	0.5	704	$23	$16,192
HUD-203 Lost Label Report	10	6	60	0.5	30	$23	$690
HUD-203B Damaged Label Report	10	6	60	0.5	30	$23	$690
Totals	176		5622		2811		$64,653

The hourly cost is based on an estimate of the average annual salary of industry support staff at $47,800.

Respondents are manufacturers and approved IPIA agencies. The current number of manufacturing plants that may request labels is 161; and the number of IPIA agencies is 15. There are a total of 176 respondents.

13. There are no costs to the respondents other than those reported in item 12 above.

14. The Government utilizes a contractor to process the forms, and collect fees and distribute labels tracked by these forms. This contractor is referred to as the “Monitoring Contractor”. The contractor utilizes 1.5 full-time equivalent administrative employees to perform the duties required to administer this fee and label program; all work associated with the fee and label program is essentially processing the form data. This data is maintained by the contractor utilizing its proprietary computer software program called WebLabels.

There is also minimal cost associated with the WebLabels program that maintains the form data and allows for direct electronic submission of the data. This software is maintained with Helpdesk support and very minimal contact support for periodic enhancements. The support paid by the department to ensure data required by regulation is collected is approximately $25,000 annually.

Administrative personnel through Monitoring Contractor: $90,000

(2 employees, 75% of time, at $65,000 annual rate for each)

Management/reporting/overhead through Monitoring Contractor $10,400

(2 hours/week, 52 weeks, at $100/hour)

Allocated contract support for data management cost $25,000

Allocated contract and program oversight by HUD $7,280

(2 hours/week, 52 weeks, at $70/hour)

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Total Annual Cost to the Government $132,680

Note that this approximately $132,680 annual cost to the Government to collect and maintain data associated with these forms represents about 2.5 % of the approximately 5.4 million dollars in annual fees collected through these forms ($132,680/$5,400,000).

15. There are no program changes since the previous OMB approval of this collection package. The decrease to the labor burden break-down that is itemized above in item #12 reflects a reduction in the number of manufacturers reporting from 222 to 161.

There has been no program, processing, or administrative change since the previous OMB collection approval. The actual cost to the Federal government has decreased from the previous submission due to the lower number of respondents and associated burdens.

16. HUD does not plan to publish the data.

17. HUD is not requesting not to display the expiration date.

18. There are no exceptions to the Certification Statement.

B. Collections of Information Employing Statistical Methods

19. This collection does not use statistical methods.

OMB 83-I 10/95