IA Decs Final Rule 1660-0009 Supporting Statement (March 2019)

March 21, 2019

Supporting Statement for

Paperwork Reduction Act Submissions

OMB Control Number: 1660 - 0009

Title: The Declaration Process: Requests for Preliminary Damage Assessment (PDA), Requests for Supplemental Federal Disaster Assistance, Appeals, and Requests for Cost Share Adjustments

Form Number(s): FEMA Form 010-0-13; FEMA Form 009-0-140

General Instructions

A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(i)(iv) and its actual or estimated date of publication in the Federal Register, must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified in Section A below. If an item is not applicable, provide a brief explanation. When Item 17 or the OMB Form 83-I is checked “Yes”, Section B of the Supporting Statement must be completed. OMB reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

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. Provide a detailed description of the nature and source of the information to be collected.

The Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. §§ 5121-5207 (the Stafford Act), requires that all requests for a declaration by the President that a major disaster or emergency exists shall be made by the Governor of the affected State or the Chief Executive of an affected Indian tribal government. Section 401(a) of the Act stipulates that such a request shall be based on a finding that the disaster is of such severity and magnitude that effective response is beyond the capabilities of the State and the affected local government, and that Federal assistance is necessary. Section 401(a) further stipulates that as a part of such request, and as a prerequisite to major disaster assistance under this Act, the Governor shall take appropriate response action under State law and direct the execution of the State’s emergency plan and shall furnish specific information that must be included in a request for a major disaster declaration. Section 401(a) stipulates that the request must include specific information on the nature and amount of State and local resources which have been or will be committed to alleviate the results of the disaster. Section 501(a) requires the same information to be provided in requests for declarations of an emergency. The processes for requests for emergency or major disaster declarations are set forth in further detail in 44 C.F.R. §§ 206.35 and 206.36. Section 403(c) of the Act stipulates that in the aftermath of an incident that may qualify under title IV of this Act, the Governor may request the President to direct the Secretary of Defense to utilize resources of the Department of Defense for the purposes of performing on public and private lands any emergency work which is essential to save lives and protect property. Information required to process a request under this section is set forth in 44 C.F.R. § 206.34. In the event that a Governor’s request for supplemental Federal assistance is denied, the Governor may appeal this denial under the provisions set forth in 44 C.F.R. § 206.46. Pursuant to 44 C.F.R. § 206.47, a Governor may request an adjustment of the 75 percent Federal share of the eligible cost of permanent restorative work under Section 406 of the Stafford Act and for emergency work under Section 403 and Section 407 of the Stafford Act.

As a result of passage of Section 1110 of the Sandy Recovery Improvement Act of 2013 (P.L. 113-2), Federally recognized Tribes may also submit requests for disaster declarations. The same form is used for both States and Tribes. Previously, a State could make requests on behalf of Tribes.

Section 1109 of SRIA also requires FEMA, in cooperation with State, local, and Tribal emergency management agencies, to review, update, and revise through rulemaking the factors found at 44 CFR 206.48(b) for Individual Assistance that FEMA uses to measure the severity, magnitude, and impact of a disaster, including 44 CFR 206.48(b)(2) related to trauma and the specific conditions or losses that contribute to trauma. This information collection’s burden hour is being slightly increased because of the required rulemaking that FEMA must complete to comply with Section 1109 of SRIA.

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. Provide a detailed description of: how the information will be shared, if applicable, and for what programmatic purpose.

This collection includes FEMA Form 010-0-13, Request for Presidential Disaster Declaration Major Disaster or Emergency, which asks for the same data that were stated and required in the previous narrative Governor’s requests to the President requesting supplemental Federal assistance, through the appropriate Regional Administrator, combined with the findings of a joint FEMA, State and local Preliminary Damage Assessment (PDA). The PDA is analyzed and provides the basis for a Regional Summary, Analysis, and Recommendation, which is submitted to the Assistant Administrator of the Disaster Assistance Directorate. The information is reviewed and evaluated and the Administrator formulates a recommendation which is submitted to the President for consideration of a disaster or emergency declaration. The FEMA form eliminates the need for follow-up communications and reporting during a declaration request.

FEMA Form 010-0-13 was approved for use in September 2016 via a normal processing request.

Information gathered for the PDA is done primarily by State employees with the assistance of FEMA. Most of the information gathered for and comprising the PDA is observations of damages and statistics gathered by the state for other purposes such as number of people without electricity or water. The State already gathers this information irrespective of its PDA and declaration request. Information related to Public Assistance and Individual Assistance is collected through separate damage assessments teams and processes. The Preliminary Damage Assessment (PDA) for Individual Assistance is a part of this collection but is not subjected to the Paperwork Reduction Act and there is no burden on the public. There are four (4) official FEMA PDA forms:

FEMA Form 009-0-140 (Damage Assessment Tool)

Detailed Street Sheet – To be used during a windshield/foot PDA when the inspectors have the capability of capturing addresses and surveying the damage on the ground.

Summary Sheet – To be used in conjunction with the Street Sheet to add multiple pages into one total result.

Tick Sheet – To be used during an aerial PDA or when the volume of homes is such that the street sheet is unnecessarily time consuming.

Narrative Report – To be used during the briefing with the State, Tribal, and local officials to capture information that paints the full picture of the disaster. This form is just as important as recording the hard count numbers.

All four of these forms will be completed by FEMA personnel or contractors only. See attached document title: Preliminary Damage Assessment for Individual Assistance Operations Manual.

The information contained in the Regional Summary, Analysis, and Recommendation, is only releasable to the extent it contains factual information; all opinions, recommendations, conclusions and otherwise deliberative information are protected under FOIA Exemption 5, 5 U.S.C. § 552(b) (5).  Documents that are inter-agency or intra-agency, which would not be available by law to a party other than an agency in litigation with the agency, are exempt from disclosure.  These records are part of the deliberative process in that they are pre-decisional in nature.

Pursuant to 44 C.F.R. § 206.46 the Governor may appeal the denial of a major disaster or emergency request.  The appeal must be submitted, in writing, within 30 days of the date of the letter denying the original request.  This is a one-time request for reconsideration which follows the same process as the original declaration request: the Governor submits the appeal, including any additional relevant information, to the Regional Administrator, the RA makes a recommendation to FEMA HQ, and FEMA HQ makes a recommendation to the President.

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.

Information in the Request for Presidential Disaster Declaration Major Disaster or Emergency form is received electronically via e-mail. All documentation is submitted in PDF format. Original signatures are required to be maintained for each request, and are mailed in separately.

The Damage Assessment mobile application (FEMA Form 009-0-140) enables more efficient collection, aggregation and transmission of supporting data captured by Individual Assistance and Public Assistance forms described in Question #2.

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. 

This information is not collected in any form, and therefore is not duplicated elsewhere.

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.

This information collection does not have an impact on small businesses or other small entities.

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

If the information stipulated is not provided in FEMA Form 010-0-13, Request for Presidential Disaster Declaration Major Disaster or Emergency for supplemental Federal assistance, the process of declaring a disaster is delayed until such time as the required information is provided through clarification or an amended Governor or Tribal Chief Executive’s request. Any amendments are submitted in a follow-up letter/narrative. With the use of the form, we anticipate less need for amendments.

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

1. Requiring respondents to report information to the agency more often than quarterly.

2. Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

When a disaster or emergency occurs in a State, the Governor or Tribal Chief Executive may request that the President declare an emergency. The request should be submitted to the appropriate Regional Director and must be submitted within five days after the need for assistance, but no more than 30 days after the occurrence of the incident, in order to be considered.

2. Requiring respondents to submit more than an original and two

copies of any document.

2. Requiring respondents to retain records, other than health,

medical, government contract, grant-in-aid, or tax records for more than three years.

2. 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.

 (f) Requiring the use of a statistical data classification that has not

been reviewed and approved by OMB.

 (g) 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.

 (h) 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.

The special circumstances, a. and c.-h., contained in item 7 of the supporting statement are not applicable to this information collection.

8. Federal Register Notice: 

 a. 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. Specifically address comments received on cost and hour burden.

A notice inviting public comments on the collection published on November 12, 2015, 80 FR 70116 in a notice of proposed rulemaking.

Notice that FEMA submitted the collection for OMB review and approval published on March 21, 2019, 84 FR 10632 in a final rule.

 b. 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.

Consultations with officials of the State or Tribe seeking a declaration for their particular disaster at various levels of government occur as a result of disaster activity. All information collected as a result of these consultations is used to monitor the effectiveness of the declaration process.

c. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

Consultation with Federal, State, Tribal, and local officials’ takes place each and every time a request for a PDA is submitted by a State or Tribe. This is necessary to obtain accurate information about the incident and affected areas in order to prepare for and conduct the joint PDA. With the use of the form, we anticipate less of a need for follow-up consultation.

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

FEMA does not provide payments or gifts to respondents in exchange for a benefit sought.

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

A Privacy Threshold Analysis (PTA) was completed by FEMA and adjudicated by the DHS Privacy Office on February 10, 2016.

This collection is covered by an existing Privacy Impact Assessment (PIA), DHS/FEMA/PIA-013 – Grant Management Programs, approved by DHS on February 19, 2015.

SORN coverage is not required.

There are no assurances of confidentiality provided to the respondents for this information collection.

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). 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.

 12. Provide estimates of the hour burden of the collection of information. The statement should:

 a. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated for each collection instrument (separately list each instrument and describe information as requested). 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 desired. 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.

Based on the average number of requests FEMA receives in a given year, FEMA estimates that 56 States will complete 6 requests a year. This totals 336 State requests.

As a result of Section 1109 of SRIA, federally recognized tribal governments will also submit declaration requests. However, these numbers are much lower on an annual basis. There are 567 tribes that could theoretically request a declaration as a result of passage of section 1110 of the Sandy Recovery Improvement Act of 2013 (P.L. 113-2). However, our data suggests that in an average year, only 20 declaration requests will come from tribes. We calculated this based on damage incurred from disasters on federal Indian tribal lands in a given year over a five year period that met the damage threshold to request a declaration. The form is the same for tribes. Thus, they will expend the same amount of time to fill out a declaration request as states.

FEMA calculated the number of responses per respondent by multiplying 56 States by 6 (56 x 6 = 336) and then adding 20 responses from Federally Recognized Tribal governments for a total of 356 responses (336 + 20 = 356). Then FEMA divided the resulting 356 responses by the total number of respondents (623), 56 States plus 567 Federally Recognized Tribal governments. The resulting number of responses per respondent was 0.571 rounded to nearest thousandth (356/623 = 0.571428571).

It is estimated that it will take the equivalent of a State Government Chief Executive approximately 9 hours to complete the FEMA Form 010-0-13 (Request for Presidential Disaster Declaration Major Disaster or Emergency). In addition, it is estimated that a State Administrative Support Worker would spend approximately 24.126 hours gathering information for the Governor’s request. This value has increased by 0.8 hours per State to account for new time burden associated with providing State fiscal capacity information in accordance with the Factors Considered When Evaluating a Governor’s Request for Individual Assistance for a Major Disaster Final Rule. The estimated increased annual burden of 0.8 per State equates to a total annual increase burden of 44.8 hours (0.8 hours x 56 States). This value is then divided by total number of responses which equates to 0.126 hours per response rounded to the nearest thousandth (44.8 / 356 = 0.125842697). This incremental time increase will not affect Indian Tribal government declarations requests because the Final Rule only applies to States.

This results in an average total response burden of 33.126 hours. The estimated total annual burden will be 11,792.8 hours.

 b. 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.

c. Provide an estimate of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. NOTE: The wage-rate category for each respondent must be multiplied by 1.4 and this total should be entered in the cell for “Avg. Hourly Wage Rate”. The cost to the respondents 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 Annualized Burden Hours and Costs
Type of Respondent	Form Name / Form Number	No. of Respon-dents	No. of Respon-ses per Respon-dent	Total No. of Responses	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate	Total Annual Respondent Cost
State, Local or Tribal Government	Request for Presidential Disaster Declaration Major Disaster or Emergency / FEMA Form 010-0-13	623	0.571	356	9 (hours)	3,204	$79.22	$253,820.88
State, Local or Tribal Government	Initial Data Gathering for Governor’s Request / No Form	623	0.571	356	24.126 (hours)	8,588.8	$39.89	$342,607.23
Total		623		356		11,792.8		$596,428.11

• Note: The “Avg. Hourly Wage Rate” for each respondent includes a 1.46 multiplier to reflect a fully-loaded wage rate.

• Note: Numbers in the table are rounded up due to rounding in ROCIS. Also "Initial Data Gathering for Governor's Request / No Form" total burden hours is rounded to 8,588.8 to align with Factors Considered When Evaluating a Governor’s Request for Individual Assistance for a Major Disaster Final Rule. (See 84 FR 10632.)

FEMA assumed the equivalent of a State Government Chief Executive would prepare the Request for Presidential Disaster Declaration Major Disaster or Emergency / FEMA Form 010-0-13. FEMA retrieved the average hourly wage rate, $54.26 for a State Government¹ Chief Executive from the U.S. Department of Labor, Bureau of Labor Statistics’ data. FEMA applied a 1.46 multiplier², to account for benefits, which resulted in a fully loaded wage rate of $79.22.

FEMA assumed State Administrative Support Workers would gather the initial data for the Governor’s request. FEMA assumes the equivalent of a First-Line Supervisors of Office and Administrative Support Workers with an hourly wages of $27.32 would gather such information.³ FEMA then multiplied the hourly wage by 1.46 to account for benefits resulting in a fully loaded hourly wage of $39.89 for State Administrative Support Workers.

To estimate the number of hours to fill in the Governor’s request for a declaration, FEMA multiplied the number of respondents (623) by the responses per respondent (0.571) and rounded up to the nearest whole number (356). This is multiplied by the hours per response (9) which resulted in 3,204 total hours. FEMA multiplied 3,204 hours by the fully loaded hourly wage rate of $79.22 for State Chief Executives to calculate the cost to fill in the Governor’s request, which is $253,820.88 (356 x 9 hours x $79.22).

To estimate the number of hours to gather information in support of a Governor’s request for a declaration, FEMA multiplied the number of responses (356) by the hours per response (24.126) which results in 8,588.8 hours.⁴ FEMA multiplied the 8,588.8 hours by the fully loaded hourly wage rate of $39.89 for State Administrative Support Workers to calculate the cost to retrieve information for the Governor’s request which is $342,607.23 (356 x 24.126 hours x $39.89).

The total respondent cost is $596,428.11 ($253,820.88 + $342,607.23 = $596,428.11) annually.

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. (Do not include the cost of any hour burden shown in Items 12 and 14.)

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

14. Provide estimates of annualized cost 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 have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.

Annual Cost to the Federal Government

Item	Cost ($)
Contract Costs [Describe]	0
Staff Salaries* 5 FEMA Headquarter Senior Officials (GS 15 Step 5) earning $100.10 ($68.56 base salary times 1.46 multiplier) per hour with an average of 48 hours of review for each response. There are a total of 356 responses (56 respondents times 6 responses per respondents + 20 Tribe Requests = 356). The total cost to the Federal government is 356 responses times 48 hours per response to review times $100.10 per hour wage equaling $1,710,508,.80. [356 responses x 48 x $100.10 = $1,710,508.80] PDA for Individual Assistance Staff Salaries [For the workload of 50 Joint IA PDA performed annually, 11 FEMA Reservists earning $29.13 per hour ($19.96 average salary times 1.46 multiplier) spending approximately 48 hours to perform an IA Joint PDA, and 6 hours to travel, for a total of 54 hours.] [FEMA Preliminary Disaster Assessment Specialist has an average pay range from $15.98 to $23.93 or $19.96 hourly.] The cost is calculated by multiplying the fully loaded hourly rate of a FEMA Disaster Assistance Employee Level B ($29.13) by the number of staff (11) by the time associated with completing a PDA (54 hours) the average Joint IA PDA (50). Total Cost = $865,161. [50 Joint IA PDA x 54 hours x 11 staff x $29.13 = $865161.00] The cost to the Federal Government is $2,575,669.80. ($1,710,508,80 + $865,161.00 = $2,575,669.80).	$2,575,669.80
Facilities [cost for renting, overhead, etc. for data collection activity]	0
Computer Hardware and Software [cost of equipment annual lifecycle]	0
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]	0
Travel - PDA for Individual Assistance Staff [FEMA estimate travel to be about $1,115 per FEMA employee per deployment. The total cost for travel expenses is 50 IA Joint PDAs times 11 staff per assessment times $1,115 per person travel equals $613,250.]	$613,250
Printing [number of data collection instruments annually]	0
Postage [annual number of data collection instruments x postage]	0
Other	0
Total	$3,188,919.80

* Note: The “Salary Rate” includes a 1.46 multiplier to reflect a fully-loaded wage rate.

 15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I in a narrative form. Present the itemized changes in hour burden and cost burden according to program changes or adjustments in Table 5. Denote a program increase as a positive number, and a program decrease as a negative number.

A "Program increase" is an additional burden resulting from a federal government regulatory action or directive. (e.g., an increase in sample size or coverage, amount of information, reporting frequency, or expanded use of an existing form). This also includes previously in-use and unapproved information collections discovered during the ICB process, or during the fiscal year, which will be in use during the next fiscal year.

A "Program decrease", is a reduction in burden because of: (1) the discontinuation of an information collection; or (2) a change in an existing information collection by a Federal agency (e.g., the use of sampling (or smaller samples), a decrease in the amount of information requested (fewer questions), or a decrease in reporting frequency).

"Adjustment" denotes a change in burden hours due to factors over which the government has no control, such as population growth, or in factors which do not affect what information the government collects or changes in the methods used to estimate burden or correction of errors in burden estimates.

Itemized Changes in Annual Burden Hours
Data collection Activity/Instrument	Program Change (hours currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (hours currently on OMB Inventory)	Adjustment (New)	Difference
Request for Presidential Disaster Declaration Major Disaster or Emergency / FEMA Form 010-0-13				3,204	3,204	0
Initial Data Gathering for Governor’s Request / No Form	8,544	8,588.8
Total(s)	8,544	8,588.8	+44.8	3,204	3,204	0

Explain:

Due to the changes in the Final Rule, the time burden on respondents and potential respondents is changed by 0.8 hours for each State request for a major disaster declaration that authorizes IA. The total time for the information collection burden change is 44.8 additional hours. Tribal governments’ requests for major disasters declarations that authorize IA are not subject to change in the time burden.

Itemized Changes in Annual Cost Burden
Data collection Activity/Instrument	Program Change (cost currently on OMB Inventory)	Program Change (New)	Difference	Adjustment (cost currently on OMB Inventory)	Adjustment (New)	Difference
Request for Presidential Disaster Declaration Major Disaster or Emergency / FEMA Form 010-0-13
Initial Data Gathering for Governor’s Request / No Form
Total(s)

Explain:

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.

FEMA does not intend to employ the use of statistics or the publication thereof for this information collection.

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

This collection does not seek approval to not display the expiration date for OMB approval.

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

FEMA does not request an exception to the certification of this information collection.

1 U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment Statistics, May 2015 National Industry-Specific Occupational Employment and Wage Estimates, NAICS code 999200, State Government excluding schools and hospitals, and Standard Occupational Classification (SOC) code 11-1011 for Chief Executives. https://www.bls.gov/oes/tables.htm. May 2015, National (XLS) file. Accessed and downloaded, October 12, 2016.

2 Base hourly wage rate of $54.26 multiplied by a 1.46 benefits factor. ($54.26 x 1.46 = $79.22)

Bureau of Labor Statistics, Employer Costs for Employee Compensation, Table 1. Employer Costs Per Hour Worked for Employee Compensation and Costs as a Percent of Total Compensation: Civilian Workers, by Major Occupational and Industry Group, June 2015.” Calculated by dividing total compensation for all workers of $34.05 by wages and salaries for all workers of $23.35 per hour (yields a benefits multiplier of approximately 1.46 × wages). https://www.bls.gov/web/ecec/ececqrtn.pdf. Accessed and downloaded, October 12, 2016.

3 U.S. Department of Labor, Bureau of Labor Statistics, Occupational Employment Statistics, May 2015 National Industry-Specific Occupational Employment and Wage Estimates, NAICS code 999200, State Government excluding schools and hospitals, and Standard Occupational Classification (SOC) code 43-1011 for First-Line Supervisors of Office and Administrative Support Workers. https://www.bls.gov/oes/tables.htm. May 2015, National (XLS) file. Accessed and downloaded, October 12, 2016.

4 Data gathering hour burden is rounded to 8,588.8 due to rounding average burden per response to align with Factors Considered When Evaluating a Governor’s Request for Individual Assistance for a Major Disaster Final Rule. (See 84 FR 10632.)

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