National Arboretum Supporting Statement for Paperwork Reduction Act Submission U

2011 Supporting Statement – OMB 0518-0024

U.S. National Arboretum

Use of Grounds and Facilities as well as

Commercial Photography & Cinematography

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.

The mission of the U.S. National Arboretum (USNA) is to conduct research, provide education, and conserve and display trees, shrubs, flowers, and other plans to enhance the environment. The USNA is a 446 acre public facility. The grounds of the USNA are available to the general public for purposes of education and passive recreation.

Horticulture and gardening are very important aspects of American life. The USNA receives approximately 550,000 visitors each year. Additionally, societies like the Herb Society of America, and the Orchid Society like to use the USNA grounds to showcase their activities (shows and sales). The National Capital Area Federation of Garden Clubs (of which there are 3,600 members) is headquartered at the USNA.

The USNA has many spectacular features and garden displays which are very popular to visitors and photographers. One feature, the old sandstone columns from the east facade of the Capitol, is considered to be the most photographed feature at the USNA and is very popular with commercial photographers.

Section 890 (b) of the Federal Agriculture Improvement and Reform Act of 1996, Pub. L. 104-127 ("FAIR ACT") provided statutory authorities regarding the United States National Arboretum ("USNA"). These authorities include the ability to charge fees for temporary use by individuals or groups of USNA facilities and grounds for any purpose consistent with the mission of the USNA. Also, the authority was provided to charge fees for the use of the USNA for commercial photography and cinematography.

In order to administer the use of the USNA facilities (i.e., determine needs and availability) as well as determine if the request to use USNA facilities is "consistent with the mission of the National Arboretum", it is necessary for the USNA to obtain information from the requestor.

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.

This information is collected by USNA officials using applications in the form of questionnaires. The information is used by USNA management to determine if the requestor's need can be met and (if applicable) the request is consistent with the mission and goals of the USNA.

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 submissions 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 applications are available in hard-copy format as well as offered on our website.

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 primary need for the use of USNA facilities is expected to be for one time event use only. Additional requests will still require an application in order for USNA managers to determine if needs can be met (i.e., if the room is available or not). This information is not available anywhere else.

5. If the collection of information impacts small businesses or other small entities (Item 5
of OMB Form 83-1), describe any methods used to minimize burden.

The collection of information does not impact small businesses or other 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.

If basic information (i.e., name, time, and dates required, rooms required, expected number to attend) is not collected, USNA officials will not be able to determine if the requestor's needs can be met. If information relating to how this event/request fits within the mission of the USNA is not gathered, USNA managers will not be able to ensure that the requirements of Pub. L. 104-127 are met.

7. Explain any special circumstances relating to Guidelines 5 CFR 1320.5.

USNA management requires a minimum two week notice in order to approve or disapprove an application. This may require the respondent to complete the application in less than 30 days. All other requirements mentioned above are not applicable.

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 comments response to the Federal Register notice and efforts to consult outside the agency. Consultation with representative of those from who 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.

A Federal Register notice was published in the Federal Register on August 26, 2011 on page numbers 53397-533981, Vol 76, Number 166. Two comments were received, but it did not have any bearing on this information collection.

9. Explain any decision to provide any payment or gift t respondents, other than remuneration of contractors or grantee.

No gifts or payments are provided to the respondents.

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

There is no requirement to assure confidentially to respondents.

11. Provide additional justification for any questions of a sensitive nature.

Due to the United States Department of Agriculture Homeland Security requirements, declaration of citizenship will be required for the use of the facilities or grounds.

12. 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.

The USNA is estimating approximately 420 requests for the use of the facilities and 25 for photography/cinematography. Each request will require the completion of an application (see attached). The applications are simple and require information readily available to the requestor.

It is estimated that 445 responses will be received annually. The estimate time of completion of the facilities application and photography applications is 30 minutes. See copy of spreadsheet.

Description	Number of	Responses/	Total	Hours/	Burden Hours
	respondents	Respondents	Responses	Responses
Request for use of	420	1	420	.5	210
USNA facilities
application and
agreement.

Description	Number of Respondents	Responses/ Respondents	Total Responses	Hours/ Responses	Burden Hours
Permission to photograph	25	1	25	.5	12.5
Total	445		445		222.5

Cost to respondents is 222.5 hours at $23.60 per hour for a total of $5,251.00. The estimate of $23.60 per hour is based on a salary of a GS-7.

13. Estimate of other total annual cost burden to respondents or record – keepers.

There are no capital and start-up, or operation, maintenance and purchase costs associated with this information collection.

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

It is anticipated that the approval or disapproval of each photography application received will require approximately 60 minutes of processing by an Administrative Technician (GS-7, $23.60/hour) and 5 minutes by the Administrative Officer, USNA (GS-12, $37.07/hour). If 25 applications are received, that correlates to $590 per year for Administrative Technician and $77.50 for the Administrative Officer for a total of $667.50 per year cost the Federal government. If the application is approved, additional costs will be incurred by the government. These are costs related to support staff, utilities, and overhead required to support the approved event. These costs were used to develop the fee rates identified in the Federal Register publications.

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

The number of hours to fill out the National Arboretum applications increased from 15 minutes to 30 minutes. This change increased the requested burden hours from 109 to 222.5, with the adjustment of 113.50. This increase was based on the comments that were received from customers who filled out the forms over the last three years.

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

The information collected will 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 USNA is not seeking approval to exempt display of the expiration date for OMB approval.

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork reduction Act Submissions”.

There are no exceptions to item 19 of OMB from 83-I.