AEDI PRA june 24 2014 (3) rev

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 Office of Rural Housing and Economic Development		2. OMB Control Number: a.	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 from approval date b. Other (specify)      

7. Title:

The Appalachia Economic Development Initiative Application and Semi-Annual Reporting      

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

SF 424; HUD 424CB; HUD 424-CBW; SF-LLL; HUD 2880; HUD 2990; HUD 2991; HUD 2993; HUD 2994A; HUD 27061; and HUD 27300

9. Keywords:

Housing, Economic Development, Rural areas, Appalachia, and Grant management

10. Abstract:

The purpose of this submission is for applications for the Appalachia Economic Development Initiative (AEDI) grant process. The AEDI is funded by recaptured funds from the Rural Housing and Economic Development (RHED) program. Information is required to rate and rank competitive applications and to ensure eligibility of applicants for funding. Semi-annual reporting is required to monitor grant management.

11. Affected public: (mark primary with “P” and all others that apply with “X”) a.   Individuals or households e.   Farms b.   Business or other for-profit f.   Federal Government c. P 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. P Required to obtain or retain benefils c.   Mandatory
13. Annual reporting and recordkeeping hour burden: a. Number of respondents 50 b. Total annual responses 50 Percentage of these responses collected electronically 100 % c. Total annual hours requested 502 d. Current OMB inventory 0 e. Difference (+,-) 502 f. Explanation of differen 1. Program change: 0 2. Adjustment: 502		14. Annual reporting and recordkeeping cost burden: (in thousands of dollars) Do not include costs based on the hours in item 13. a. Total annualized capital/startup costs 0 b. Total annual costs (O&M)      0 c. Total annualized cost requested      0 d. Current OMB inventory      0 e. Difference      0 f. Explanation of difference: 1. Program change:      0 2. Adjustment: 0
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.  Requlatory or compliance d. X Audit		16. Frequency of recordkeeping or reporting: (check all that apply) a. Recordkeeping b. Third party disclosure c. Reporting: 1. On occasion 2. Weekly 3. Monthly 4. Quarterly 5. Semi-annually 6. Annually 7. Biennually 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: Jackie L. Williams, Director, Office of Rural Housing and Economic Development Phone: (202) 402-4611

19. Certification for Paperwork Reduction Act Submissions

On behalf of the U.S. Department of Housing and Urban Development, 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, which 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);

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

2. 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      

Date:

Supporting Statement for Paperwork Reduction Act Submissions

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.

The Appalachia Economic Development Initiative is a collaborative effort among three federal agencies - the Department of Housing and Urban Development (HUD), the Department of the Treasury - Community Development Financial Institutions Fund (CDFI Fund) and the Department of Agriculture - Rural Development (USDA-RD). The purpose of the Appalachia Economic Development Initiative (AEDI) is to support local rural nonprofits and Federally Recognized Indian tribes serving the Appalachian Region for lending and investing activities in businesses lending and economic development, and for securing additional sources of public and private capital for these activities. Funding for the AEDI is provided by recaptured funds from the Rural Housing and Economic Development grant which is authorized by the Department of Veterans Affairs and the Department of Housing and Urban Development and Independent Agencies Appropriations Act, 1998 (Public Law 105-276, October 27, 1997).

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.

First, the information collected through the annual one-time application is essential so that HUD staff may determine the eligibility, qualification, and capability of applicants to implement HUD’s The Appalachia Economic Development Initiative (AEDI) purpose. Second, AEDI grantees must establish and maintain records to allow HUD to determine whether or not programs are being carried out in accordance with applicable laws and requirements and to facilitate the review and audit of grant management. This is a new collection. The instruments to be used are:

Instrument: Purpose:

SF-424	This is a standard form required for use as a cover sheet for submission of pre-applications and applications and related information under discretionary programs.
HUD-424CB	HUD Grant Application Detailed Budget
HUD-424CBW	HUD Grant Application Budget Worksheet
SF-LLL	DISCLOSURE OF LOBBYING ACTIVITIES
HUD-2880	Applicant/Recipient Disclosure/Update Report
HUD-2990	Certification of Consistency with the RC/EZ/EC-IIs Strategic Plan
HUD-2991	Certification of Consistency with the Consolidated Plan
HUD-2993	Acknowledgment of Application Receipt
HUD-2994A	Grant Applicant Survey
HUD-27061	Race and Ethnic Data Reporting Form
HUD-27300	Questionnaire for HUD’s Initiative on Removal of Regulatory Barriers

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.

Since FY2005, HUD has required applicants to submit applications electronically through Grants.gov. Data such as semi-annual reports will continue to be submitted in paper form.

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.

No duplication of efforts is caused by this collection.

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

The collection of information does not adversely impact small businesses or other small entities. Applicants must be local rural nonprofits or federally recognized Indian tribes.

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.

Under the HUD Reform Act of 1989, discretionary funds must be awarded on a competitive basis. Without collecting this information funds could not be awarded.

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;

* 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 secrets, 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 special circumstances that would cause any information collection to be conducted in a manner as explained in the Special Instruction. Generally, the federal grant administration requirements of 24 CFR Part 84 addresses the maintenance of the appropriate files.

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 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 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.

This information collection was announced in the Federal Register, Vol 78, Page 71635, on November 29, 2013. In response to the Proposed Information Collection HUD received no comments.

9. Explain any payments or gifts to respondents, other than reenumeration of contractors or grantees.

Information collection does not involve any payments or gifts to respondents other than renumeration of contractor or grantee.

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

Submissions are covered by the Privacy Act. Information that may be released under the Freedom of Information Act will be released in accordance with the mandates of that Act.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior and 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.

The information collected does not include information on specific individuals benefiting from the AEDI.

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. 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 desirable. 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

• If this collection uses more than one form, provide separate estimates for each form and aggregate the hour burdens in item 13 of OMB Form 83i; and

• 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 13.

Estimated Burden

	Respondents	Annual responses	Total responses	Burden per response	Total annual hours	Burden cost per instrument
HUD-424CB	50	1	50	3.2	156	3,900
HUD-424CBW	50	1	50	3.2	156	3,900
HUD-2880	50	1	50	2.0	100	2,500
HUD-2990	50	1	50	0	0	0
HUD-2991	50	1	50	0	0	0
HUD-2993	50	1	50	0	0	0
HUD-2994A	50	1	50	0.5	25	625
HUD-27061	50	1	50	1.0	50	1,250
HUD-27300	50	1	50	3.0	15.0	375
	450		450		502	$12,550

Annualized Cost @ $25/hr: $12,550

Explanation of burden hours: Number of responses is based on number of eligible applicants under the AEDI proposed guidelines. The number of burden hours is based on information gathered from RHED applicants. Application requirements and semi-annual reporting requirements for the AEDI are modeled after the requirements of the RHED program. Applicants estimated the application process takes between 80 to 120 hours total and the semi-annual reporting process takes 3 hours.

13. Provide an estimate for 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 estimate 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. The estimates should take into account costs associated with generating, maintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities. * If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collections services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate. * Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

There are no additional costs other than those shown in #12.

14. Provide estimates of annualized costs 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 not have been incurred without this collection of information. Agencies may also aggregate cost estimates from Items 12, 13, and 14 in a single table.

The annualized cost to the Federal Government for a review of AEDI applications, selection of grant recipients, and administration of oversight of the grants is an hourly estimated at $20,454. The details are provided below.

Employee Grade	Hourly Rates	Hourly Rate x 80 hours (2 weeks)
GS 12-5	$ 40.66	$3,253
GS 13-2	$ 44.08	$3,526
GS 13-6	$ 49.77	$3,982
GS 15-10	$ 74.51	$5,961
	TOTAL	$16,722

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

This is a new collection. Thus, no changes are applicable to items 13 and 14.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates, and other actions.

Results of the AEDI grantees will be accessible on the HUD website in the form of a list of awardees.

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.

Expiration date for OMB approval will be displayed.

18. Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

There are no exceptions to the certifications.

B. Collections of Information Employing Statistical Methods

No statistical methods will be used.

OMB 83-I