Supporting Statement BIP 10 2015

Supporting Statement

Biofuels Infrastructure Partnership (BIP)

OMB control number-0560-0284

FSA is requesting an extension of the currently approved information collection to support a Biofuel Infrastructure Partnership (BIP) Grants to States. The Farm Service Agency (FSA) is administrating BIP on behalf of the Commodity Credit Corporation (CCC). CCC is funding the grant.

Justification

1. Explain the circumstances that make the collection of information necessary.

This information collection is needed for FSA to identify eligible States for blender pump funding to encourage increased ethanol use. FSA requires each State interested in a grant to submit an application to FSA on a form specified by FSA. States will be required to report on the funding distribution, which may require third party reporting depending on how the States distribute the funds. FSA plans to transfer funds to the selected State applicants before September 30, 2015. Per coordination with OMB, the grants announced in the NOFA will not be subject to sequestration if the funds are obligated by CCC during fiscal year 2015. Funds for BIP are limited to $100 million.

FSA announced the availability of competitive grants to fund States, the Commonwealth of Puerto Rico, and Washington, D.C. with respect to activities designed to expand the infrastructure for renewable fuels. The goal is for grantees to provide funds on a one-to-one basis to receive matching CCC funds. The funds may be used to pay a portion of the costs related to the installation of fuel pumps and related infrastructure dedicated to the distribution of higher ethanol blends, for example, “E15,” and “E85”, at local gasoline stations, convenience stores (CS), hypermarket fueling stations (HFS), or fleet facilities. The matching contributions may be used for these items as well as for additional related costs such as marketing, education, and administrative costs associated with the application process.

The funding will be provided under the authority in section 5(e) of USDA’s CCC Charter Act (15 U.S.C. 714c(e)).

2. Indicate how, by whom and for what purpose the information is to be used. Except for new collections indicate the actual use the Agency has made of the information received from the current collection.

The information is used by FSA to determine whether participants meet the eligibility requirements to be a recipient of grant funds. Lack of adequate information to make the determination could result in the improper administration and appropriation of Federal grant funds. The participants are required to keep their records on files for more than three years for reporting purposes

The information collection requirements are described below and on the attached FSA-85-1, Reporting and Recordkeeping Requirements.

Annual Report

BIP participants will provide an annual report to FSA that includes the goals and accomplishments of the program, program activities and outcomes, and financial status report. The annual report may be provided on SF-425, but may be provided in another format as long as the information requested on SF-425 is included in the report.

In addition, information on the performance and effectiveness of the program will be reported. Lastly, the annual reports may provide any additional information the state may elect to include, such as lessons learned or anything else that may help continue to drive innovative implementation of more comprehensive approaches to marketing higher levels of ethanol for the installation of infrastructure for higher blends of ethanol in general. The time to collect and provide the information is estimated to be 2 hours per response.

Mid-year report

BIP participants will provide to FSA a mid-year report that includes information on services provided during the preceding six months. The report may include information such as: The number of dedicated E15 pumps, dedicated E85 pumps, blender bumps, and retrofitted pumps financed by the grant and associated sales volume and pricing information; however, the specific project(s) will drive what information the states report. The time to collect and provide the information is estimated to be 1 hour per response.

Objective Work Plan

The applicant will provide information to show logical connections between the different project elements so that it is clear how implementing activities will lead to achieving the objectives, and how achieving the objectives will accomplish the project goal and directly address the problem statement. The applicant will provide the following information for the work plan: Project title, goal, year, objectives, problem statement, results expected, benefits expected, criteria for results and benefits expected, activities, position performing the activity, and time period.

The reporting and recordkeeping requirements timeline for the BIP grantee to provide to FSA are in the following:

Report	Due Date
Form SF-425, Federal Financial Report (Quarterly)	January 30, 2016; April 30, 2016; July 30, 2016; October 30, 2016; January 30, 2017; and as determined by CCC until grant funds are fully expended or returned.
Form SF-425, Federal Financial Report (Final)	90 days after installation completion date.
Performance Reports	April 1, 2016; October 1, 2016; February 1, 2017; February 1, 2018; February 1, 2019; February 1, 2020; February 1, 2021; February 1, 2022.

Collections Approved under Other OMB Control Numbers

[Note: these are standard grants.gov forms.]

The following table summarizes the information collections.

Description	Approved Under
SF-424, Application for Federal Assistance	4040-0002
SF-424A, Budget Information Construction	4040-0006
SF-424D, Assurances - Construction	4040-0007
SF-425, Financial Status Report	1510-0056
SF-424C, Construction Budget Information	4040-0008
Lobby Form, SF-LLL	0348-0046
Key Contact Form	4040-0003
Project Abstract	4040-0010
Project Narrative Attachment Form	4040-0010
Project/Performance Site Location	4040-0010
SF-3881 ACH Vendor/Misc. Payment	1510-0056
RD-400-4 Assurance Agreement	0575-0018

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 decisions for adopting this means of collection. Also describe any consideration of information technology to reduce burden.

Most of the electronic forms are available at www.grants.gov.

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

There is no duplication of information.

5. Methods to minimize burden on small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods to minimize burden.

This information collection will be for the States; therefore, small businesses will not be affected in this request. Also, there are no small businesses in this collection.

6. Describe the consequences to Federal program or policy activities if the collection is not conducted or conducted less frequently, as well as any technical or legal obstacles to reducing burden.

The Notice of Funds Availability (NOFA) requires the minimum information needed to determine whether a State’s proposal for BIP is competitive for Federal Assistance, reporting requirements, and mid-year reports. This minimum reporting of information is necessary for the FSA to administer BIP in an equitable and cost-effective manner.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

1. Requiring respondents to report information more frequently than quarterly. There are no information collection requirements that require information more frequently than quarterly.

2. Requiring written responses in less than 30 days. There are no information collection requirements that require written responses in less than 30 days.

3. Requiring more than an original and two copies. There are no information collection requirements that require more than an original or single copy of a document.

4. Requiring respondents to retain records for more than 3 years. The respondents are required to retain records for more than 3 years because the respondents are still required to report to FSA until year of 2022.

5. No utilizing statistical sampling. There are no such requirements.

6. Requiring the use of statistical sampling which has not been reviewed and approved by OMB. There are no such requirements.

7. Requiring the pledge of confidentiality. If documents were requested through FOIA, participants will be contacted to determine whether should be treated as confidential.

8. Requiring submission of propriety trade secrets. There are no such requirements.

8. Describe efforts to consult with persons outside the Agency to obtain their view on the availability of data, frequency of collection, the clarity of instructions and record keeping, disclosure, or reporting format (if any), and on data elements to be recorded, disclosed, or reported.

The 60-day notice was included in the Notice of Funds Availability (NOFA);

Biofuel Infrastructure Partnership (BIP) Grants to States published on June 16, 2015 at

80 FR 34363. One comment was received, and it was not relevant to the information collection aspects.

Three persons were contacted below, and there were no comments or no changes suggested for the information collection activity:

Anthony Crooks

USDA Rural Development

202-205-9322

Shawn M. Johnson  

U.S. Department of Transportation

202-366-1762

Tony Radich

USDA Office of the Chief Economist

202-401-0463

9. Explain any decision to provide any payment or gift to respondents.

There is no payment or gift given to respondents.

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

There is no assurance of confidentially provided to respondents for the information required in this collection. The information collected pertains mostly to administering federal grant funds according to rules and regulations.

11. Provide additional justification for any question of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.

The information collected under NOFA is financial in nature. As a condition for the receipt of federal grant funds, CCC will handle financial information as part of the business operations. However, the information is required to properly administer federal funds.

12. Provide estimates of the hour burden of the collection of information.

The burden for the BIP collection of information includes both the upfront one-time application and the on-going reporting, which will include mid-year and an annual reporting. The reporting may include additional reports for projects that run longer. So, the estimate of the annual burden and costs reflects the average of the one-time and the annual information collection activities. These estimates were prepared based on the variety of forms and other information collection methods that will be used by the states.

The estimate of hour burden of the information collections is as follows:

Total Number of Unduplicated Respondents 36

Reports Filed Per Respondent 14

Total Annual Responses 504

Total Annual Burden Hours 540

Average Burden Per Collection 1.07 hour

The respondents are mainly States employees so an average wages would be around $35.00. The respondent cost would be $18,900.

Cost per hour for respondents was based on experience with other FSA grant programs to states.

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.

The information collection request places no burden costs on respondents for capital, start-up, operation, maintenance, or the purchase of services.

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

Agency employees provide guidance and assistance to State BIP participants in obtaining and reporting the information needed. In addition, they will ensure information provided is complete and accurate, and to reduce the time it takes State BIP to gather and submit the required information. Lastly, employees review the information provided to effectively administer federal grant funds according to applicable rules and regulations. The agency estimates that employees spend $65 hours on information submitted from each State BI Partnership, for a total of 1,944 hours.

The estimate of annualized cost for the information collections is as follows:

Respondent’s Cost Per Hour - Budget analyst $34.89

• Program Analyst $45.99

Total Annual Respondent Cost – Budget analyst (540 X $34.89) $18,841

• Program Analyst (540 X $45.99) $24,835

• Total $43,676

Cost per hour for respondents was derived from the OPM January, 2015 at http://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2015/general-schedule-gs-salary-calculator/.

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

There are no changes to the currrent request since the OMB approval.

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

The information collections will not be tabulated or published.

17. If seeking approval to not display the expiration date for the OMB approval of information collection, explain the reasons that display would be inappropriate.

Most of the information collected is in narrative form – information collection instruments utilized for this collection are used by multiple agencies. Therefore, displaying the expiration date on instruments used by multiple agencies that each obtains its own OMB approval will be confusing to participants.

18. Explain each exception statement to the certification statement identified in Items 19 and 20 on OMB Form 83-I.

FSA is able to certify compliance with all provisions under Item 19 of OMB Form 83-I.

19. Explain how this information collection relates to the Secretary of Agriculture’s Service Center Implementation Team initiative.

This information collection is not related to the Service Centers as they are not involved in the administration of BIP.