SuptStmt (FEPP) and (FFP) Cooperative Agreements 1 4 2010

Federal Excess Personal Property (FEPP) and

Firefighter Property (FFP) Cooperative Agreements

2011

2011 SUPPORTING STATEMENT

Federal Excess Personal Property (FEPP) and

Firefighter Property (FFP) Cooperative Agreements

OMB # 0596 – NEW

Note: This new request is for approval of cooperative agreement documents and corresponding burden related to the Federal Excess Personal Property (FEPP) and Firefighter Property (FFP) programs. Control and administration of the Federal Excess Personal Property (FEPP) and Firefighter Property (FFP) agreements are currently approved by OMB 0596-0218 Federal Excess Personal Property.

Terms of Clearance:

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.

Statutes and Regulations:

• Federal Property and Administration Services Act of 1949, 40 U.S.C., Sec 202

• Excess personal property: sale or donation to assist firefighting agencies, 10 U.S.C., Subtitle A, Part IV, Chapter 153, 2576b

Federal Excess Personal Property (FEPP) and Firefighter Property (FFP) program Cooperative Agreements programs provide state forestry agencies the opportunity to obtain excess Department of Defense and other Federal agencies equipment and supplies to be used in firefighting and emergency services. The FEPP program loans excess property to individual states while the FFP program transfers ownership of the equipment to state agencies or the individual fire departments.

Each state designates an Accountable Officer who will be responsible for the integrity of the program within their respective state. This individual is responsible for filling out the required cooperative agreements which collects information from the participating state agency and outlines the requirements and rules for the cooperation. Participating state agencies must submit separate agreements if they desire to be participating in both programs. Due to state regulatory requirements, minor alterations may be made to the Purpose of the agreement. Agreements will be processed and maintained at the United States Department of Agriculture, Forest Service, Fire and Aviation Management, Partnerships, Cooperative Programs branch in each Forest Service Regional Office.

The USDA Forest Service is requesting OMB approval to collect information from individual states in Cooperative Agreements who participate in both or either the Federal Excess Personal Property (FEPP) and Firefighter Property (FFP) programs. The authority to provide excess supplies to state agencies comes from Federal Property and Administration Services Act of 1949, 40 U.S.C., Sec 202. Authority to loan excess supplies comes from 10 U.S.C., Subtitle A, Part IV, Chapter 153, 2576b grants the authority for the FFP program.

2. Indicate how, by whom, how frequently, 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.

Federal Excess Personal Property (FEPP) and Firefighter Property (FFP) cooperative agreement forms collect information from the participating state agency and outlines the requirements and rules for the cooperation. Each state forestry agency shall provide an Accountable Office who will be responsible for the integrity of the program within their respective state and completing the necessary documentation for each program that the state participates in.

Accountable Officers completes and submits cooperative agreement documents for the state forestry agency that desires to participate in one or both of the programs. Participating state agencies must submit separate agreements if they desire to be participating in both programs. Agreements will be processed and maintained at the United States Department of Agriculture, Forest Service, Fire and Aviation Management, Partnerships, Cooperative Programs branch in each Forest Service Regional Office for the purpose of documenting terms of cooperation.

Agreements will be updated as a signatory changes or at least once every five (5) years. The information contained on the agreement will identify the Accountable Officer for the management and integrity of the program within the state and will identify the responsibilities of the Federal and State participation.

Control and administration of the Federal Excess Personal Property (FEPP) and Firefighter Property (FFP) agreements are currently approved by OMB 0596-0218 Federal Excess Personal Property. This request is for the approval of the agreements documents and the according record keeping burden.

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.

Respondents to the Forest Service’s request for information collection may respond to information collection requests by either: manually typed documentation submitted via any mail delivery service; electronic documentation submitted via internet, including emails; or by electronic submission via fax. Official agreement will require hard signatures. Use of modern information technology to reduce burden is encouraged by both parties, whenever possible.

4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purpose described in item 2 above.

Currently, there are no efforts to identify duplication. In the case of the collection of new information from new respondents, previous information of the respondent is not available to the Forest Service. When similar information is already available, the Forest Service cannot use the information efficiently and effectively while administering new agency procedural actions.

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

The Forest Service minimizes the burden to all cooperators by materially assisting in the drafting of the agreements, after both informal and formal discussions. Additionally, the Forest Service does not request the same information twice, unless a problem arises related to any previous request. Furthermore, the Forest Service only seeks information required to carry out the basic administrative functions and to establish the scope of the project(s) related to the agreements.

The Forest Service provides a number of customer service products available to assist the cooperator, such as: a comprehensive website providing regulatory and policy information; forms; procedural information; and agency points of contact include the name, address, email, and phone number for the agreements specialist, the program manager, and other relevant project contacts.

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.

Without the ability to collect the information requested by a respondent, the Forest Service would not be able to conduct the activities falling under the authorities and instruments listed. The agency would not be able to loan or transfer ownership of excess Department of Defense or Federal excess property. There are no 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;

Federal Excess Personal Property (FEPP) and Firefighter Property (FFP) program Cooperative Agreements programs require the record keeping of property transferred in the agreements. Accountable Officer’s shall retain records of property to be available upon request by the Forest Service.

• 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, 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.

The Federal Register 60-day Notice for this new information collection was published on October 5, 2010, Vol. 75, No. 192, page 61412. The Forest Service did not receive comments.

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 form, and on the data elements to be recorded, disclosed, or reported.

Persons consulted outside the agency:

1. Jim Karels, Florida Dept of AG, Division of Forestry – 850-488-6111

2. John Shannon, Arkansas Forestry Commission – 501-296-1941

3. John Burwell, Oklahoma Forestry Service – 405-522-2295

Overview of comments: The Forest Service contacted Accountable Officers across the country requesting comments on this collection of information and the proposed agreements in this request. In summary, the Accountable Officers acknowledged the need for cooperative agreements to participate in the FEPP and FFP programs and believed that the proposed agreements are sufficient for the cooperative agreement. The individuals thought that the agreements are both clear and concise as well as request the necessary information from the state agency and the USDA Forest Service. There were no objections to the use of the forms. They also agreed for the need to updated the FEPP or FFP agreement when a signatory changes or within a five (5) year period.

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

No financial incentive, payment or gift, will be used to garner responses.

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

Requests for the information collection will be processed under the Freedom of Information Act and associated exemptions and is public knowledge. When not in use, the information is stored in a locked filing cabinet, with access limited to Federal employees that need access to the information.

10. 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, such as those pertaining to sexual behavior, attitudes, religious beliefs, or other matters commonly considered private.

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. 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.

Table 1: Estimated Burden Hours

(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)
Federal Firefighter Property (FFP)	FS- 3100-10	10	1	10	1 hour	10
Federal Excess Personal Property (FEPP)	FS-3100-11	10	1	10	1 hour	10
Record Keeping			1	20	2 hour	40
Totals	---	20	---	20	---	60

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

Table 2: Estimated Annualized 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
Federal Excess Personal Property (FEPP)	30	$28.38	$851.40
Federal Firefighter Property (FFP)	30	$28.38	$851.40
Totals	60		$1,702.80

* Department of Labor, Occupational Employment and Wages, May 2009 (State Government Employees, mean hourly wage- $28.81). http://www.bls.gov/oes/current/oes131199.htm

13. 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.

14. Provide estimates of annualized cost to the Federal government. Also, 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.

Table 3 – Estimated Annual Cost to the Government

Action Item	Personnel	Number of Employees	GS Level	Hourly Rate1	Total Hours	Cost to Govt.
Employee labor for developing, printing, storing forms	Program Manager	1	GS-12/Step 5	$42.55	602	$2,553.00
Employee labor for collecting information	Program Managers	1	GS-12/Step 5	$42.55	303	$1,276.50
Employee labor for analyzing, evaluating, summarizing, and/or reporting on the collected information	Program Managers	1	GS-12/Step 5	$42.55	504	$2,127.50
Total Cost to Government						$5,957.00

¹ Taken from OPM: http://www.opm.gov/oca/10tables/pdf/gs_h.pdf, Cost to Government calculated at hourly wage multiplied by 1.3: $32.73 (GS 12/step 5) x 1.3 = $42.55

² 3 hrs per employee x 20 Agreements = 60 hours

³ 1.5 hours per employee x 20 Agreements = 30 hours

⁴ 2.5 hours per employee x 20 Agreements = 50 hours

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-1.

This is a new information collection request.

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

There are no plans for the information to be published.

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 OMB number and expiration date will be displayed on all forms listed in this information collection request.

18. Explain each exception to the certification statement identified in Item 19 "Certification for Paperwork Reduction Act."

There are no exceptions to the certification statement.

(This information collection does not employ statistical methods.)