4-H Name & Emblem Supporting Statement

4-H Name & Emblem Supporting Statement.doc

Application for Authorization to Use 4-H Name and/or Emblem

OMB: 0524-0034

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National Institute of Food and Agriculture

U.S. Department of Agriculture

OMB No. 0524-0034

Application for Authorization to Use the 4-H Name and/or Emblem



SUBJECT: Supporting Statement for Paperwork Reduction Act Submission to Renew Information Collection OMB No. 0524-0034, Application for Authorization to Use the 4-H Club Name and/or Emblem.


A. JUSTIFICATION


1. CIRCUMSTANCES MAKING COLLECTION OF INFORMATION NECESSARY


An Act of Congress, (Pub., authorizes use of the 4-H Club Name and/or Emblem L. 772, 80th Congress, Chapter 645, 2nd Session). Use of the 4-H Club Name and/or Emblem by anyone other than Chartered 4-H Clubs and those duly authorized by representatives of the Department of Agriculture, the Land-Grant colleges and universities, and persons authorized by the Secretary of Agriculture is prohibited by the provisions of 18 U.S.C. 707. The Secretary has delegated authority to the Director of the National Institute of Food and Agriculture (NIFA) to authorize others to use the 4-H Name and Emblem. The Director has promulgated regulations at 7 CFR Part 8 that govern such use. The regulatory requirements for the use of the 4-H Name and/or Emblem reflect the high standards of 4-H and its educational goals and objectives. Therefore, anyone requesting authorization from the Director to use the 4-H Name and Emblem is asked to describe the proposed use in a formal application.


There are exceptions to submitting an application to use the 4-H Name and/or Emblem to the Administrator that are consistent with 7 CFR Part 8, 8.7 (a) (1-4) and 8.9 (a-b) and “Using the 4-H Name and Emblem.” These exceptions involve specifically authorized organizations that originate requests for materials for their own use, including fundraising, within their specified boundaries, and when vendors or others providing support are based in the geographic area being served and are not working with 4-H outside of the geographic region specified either simultaneously or consecutively. When all of these conditions are met, approval for use of the 4-H Name and Emblem on, or associated with, products and services belongs to the appropriate land-grant institution. NIFA reserves the right to review and revoke any authorization or permission for use the 4-H Name and/or Emblem at any time.


The instructions on the NIFA-01 form have been modified to clarify when and why federal level authorization is required. Clearer instructions are expected to reduce confusion over applicability and time spent by the applicants.


2. HOW, BY WHOM, AND PURPOSE FOR WHICH INFORMATION IS TO BE USED


The information is collected by NIFA using the “Application for Authorization to Use the 4-H Club Name or Emblem” (Form NIFA-01). NIFA uses this form to determine if those applying to use the 4-H Name and Emblem are meeting the requirements in 7 CFR Part 8 and national standards for quality of materials, products and/or services provided to the public.


If this information is not collected, it would not be possible to ensure that the products, services, and materials meet the high standards of 4-H and its educational goals and objectives.


3. USE OF IMPROVED INFORMATION TECHNOLOGIES


NIFA will continue to post this application (Form NIFA 01) on its web site. Funding has not been made available for this collection.


4. DESCRIBE EFFORTS TO IDENTIFY DUPLICATION.

NIFA is the only agency that collects this information.


5. METHODS TO MINIMIZE BURDEN ON SMALL BUSINESSES OR OTHER SMALL ENTITIES.


This information is collected once every three years so the burden on small businesses is minimal. NIFA does not normally ask any questions about the size of a business. We estimate that 85% are small business and 10% are non-profit organizations, government agencies or universities, and the remaining 5% are large corporations who are typically affiliated with the private partner National 4-H Council.


6. CONSEQUENCES IF INFORMATION COLLECTION WERE LESS FREQUENT.


Since information is collected every three years after the initial authorization, we feel the burden is quite small, and collection at a less frequent level could lead to inaccurate information of who is allowed to use the 4-H emblem and for what purposes.


7. SPECIAL CIRCUMSTANCES FOR INFORMATION COLLECTION.


There were no special circumstances for this collection.


8. FEDERAL REGISTER NOTICE, SUMMARIZATION OF COMMENTS.


Notice of intent to request to revise and reinstate an expired information collection was published in the Federal Register on Friday, March 22, 2019, Vol. 84, and No. 56 page 10782. There was one comment.


CONSULTATION WITH PERSONS OUTSIDE THE AGENCY.


The need for NIFA to consult with three individuals outside the agency to determine the use and relevance, and since there were no changes in burden there was not an in-depth consultation initiated. The individuals who reviewed the 4-H Name and Emblem did not provide any comments just verification that the emblem is still of value and use.


NIFA has consulted with the following individuals:


Renee McKee

Purdue University
rmckee@purdue.edu


Johnathan Despain

University of Wyoming

jdespain@uwyo.edu


Jeff King

Ohio State University

king.20@osu.edu


9. EXPLAIN ANY DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS.


Payments or gifts are not given to any respondents.


10. CONFIDENTIALITY PROVIDED TO RESPONDENTS.


Forms received for use of the 4-H Name and Emblem are maintained by the Division of Youth & 4-H, National Institute of Food and Agriculture, U.S. Department of Agriculture. All forms are electronic and kept in a password protected database on a cloud based platform, in accordance with agency responsibilities for maintenance of official records.


11. QUESTIONS OF A SENSITIVE NATURE.


Information collected from applicants is not considered sensitive.


12. ESTIMATE OF BURDEN.


Public reporting burden for this collection of information is estimated to average .5 hours per response.

Respondents are principally from the private sector.


Estimated number of respondents: 60

Estimated number of responses per respondent: 1

Estimated total annual burden on respondents: 30 hours

TOTAL ANNUAL COST BURDEN TO RESPONDENTS OR RECORDKEEPERS.


The estimate of the total annual cost burden to respondents for the collection of information is $ 1,290.00. This assumes a $43.00 per hour salary of the respondents.


There fringe benefit cost is included.


13. START UP COSTS


There are no start up costs.


14. PROVIDE ESTIMATES OF ANNUALIZED COST TO THE FEDERAL GOVERNMENT.


Estimated new application forms per year - 50

Cost estimated per computer platform license $5000 per application form - $30.20


Costs included in the above are for staff time in review of information from applicants and processing the form. To determine cost, we used an hourly rate of $47.30 x 20 minutes per application (for processing by a Program Specialist) plus an hourly rate of $86.84 x 5 minutes per application (for final review and approval by two National Program Leaders) using Salary Table 2016-DCB. This is savings of $53.13 per application or $2656.50 annually. The fringe benefit cost is included.


15. REASONS FOR CHANGES IN BURDEN


There are no changes in burden.


16. TABULATION, ANALYSIS AND PUBLICATION PLANS.


The only information published is the name and state of applicants who are approved for authorization along with the date the authorization expires. All other information collected is used solely to administer the program.


17. REASONS DISPLAY OF EXPIRATION DATE OF OMB APPROVAL IS INAPPROPRIATE.


We plan to display the expiration date on the forms.


18. EXCEPTIONS TO 83-I CERTIFICATION STATEMENT.

A certification exception is not requested.

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