9000-0157 Supporting Statement 12.22.2020

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

9000-0157, Architect-Engineer Qualifications

(SF-330)

FAR section affected: SF 330

1. Justification.

1. Administrative requirements. This clearance covers the information that offerors must submit to comply with the following Federal Acquisition Regulation (FAR) requirement:

• Standard Form (SF) 330, Architect-Engineer Qualifications. As specified in FAR 36.702(b), an architect-engineer firm must provide information about its qualifications for a specific contract when the contract amount is expected to exceed the simplified acquisition threshold. Part I of the SF 330 may be used when the contract amount is expected to be at or below the simplified acquisition threshold, if the contracting officer determines that its use is appropriate. Part II of the SF 330 is used to obtain information from an architect-engineer firm about its general professional qualifications.

The SF 330 accomplishes the following:

• Expands essential information about qualifications and experience data including:

• An organizational chart of all participating firms and key personnel.

• For all key personnel, a description of their experience in 5 relevant projects.

• A description of each example project performed by the project team (or some elements of the project team) and its relevance to the agency’s proposed contract.

• A matrix of key personnel who participated in the example projects. This matrix graphically illustrates the degree to which the proposed key personnel have worked together before on similar projects.

• Reflects current architect-engineer disciplines, experience types and technology.

• Permits limited submission length thereby reducing costs for both the architect-engineer industry and the Government. Lengthy submissions do not necessarily lead to a better decision on the best-qualified firm. The proposed SF 330 indicates that agencies may limit the length of firm’s submissions, either certain sections or the entire package. The Government’s right to impose such limitations was established in case law (Coffman Specialties, Inc., B-284546. N-284546/2, 2000 U.S.Comp.Gen.LEXIS 58, May 10, 2000).

2. Uses of information. The contracting officer uses the information provided on the SF 330 to evaluate firms to select an architect-engineer firm for a contract.

Part I—Contract-Specific Qualifications. The information on the form is reviewed by a selection panel composed of professionals and assists the panel in selecting the most qualified architect-engineer firm to perform the specific project. The form is designed to provide a uniform method for architect-engineer firms to submit information on experience, personnel, and capabilities of the architect-engineer firm to perform along with information on the consultants they expect to collaborate with on the specific project.

Part II—General Qualifications. The information obtained on this form is used to determine if a firm should be solicited for architect-engineer projects. Architect-engineer firms are encouraged to update the form annually.

3. Consideration of information technology. We use improved information technology to the maximum extent practicable. Where both the Government agency and contractors are capable of electronic interchange, the contractors may submit this information collection requirement electronically.

4. Efforts to identify duplication. This requirement is issued under the FAR which has been developed to standardize Federal procurement practices and eliminate unnecessary duplication.

5. If the collection of information impacts small businesses or other entities, describe methods used to minimize burden. The burden applied to small businesses is the minimum consistent with applicable laws, Executive orders, regulations, and prudent business practices.

6. Describe consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently. Collection of information on a basis other than solicitation-by-solicitation is not practical.

7. Special circumstances for collection. Collection is consistent with guidelines in 5 CFR 1320.6.

8. Efforts to consult with persons outside the agency.

1. A 60-day notice was published in the Federal Register at 85 FR 66983, on October 21, 2020. No comments were received.

2. A 30-day notice was published in the Federal Register at 85 FR 85640, on December 29, 2020.

9. Explanation of any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees. Not applicable.

10. Describe assurance of confidentiality provided to respondents. This information is disclosed only to the extent consistent with prudent business practices, current regulations, and statutory requirements.

11. Additional justification for questions of a sensitive nature. No sensitive questions are involved.

12 & 13. Estimated total annual public hour burden.

Subject matter experts have determined that the public reporting burden for this collection of information is estimated to average 29 hours (25 hours for Part I and 4 hours for Part II) per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. Because of the tailoring required by the form for each project submittal, there are virtually no savings in burden hours by repeat submittals. The annual average number of new Architectural Services contracts (NAICS code 541310) awarded in the Federal Procurement Data System between Fiscal Years 2017 through 2019 was 411. The annual reporting burden is estimated as follows:

Estimated respondents/yr............................. 411

Responses/respondent................................. x 4

Total annual responses.............................. 1,644

Estimated hrs/response............................... x 29

Estimated total burden hrs.......................... 47,676

Hourly rate*......................................... x $67

Estimated annual cost to the public............. $3,194,292

* Based on the OPM GS-13/step 5 salary ($49.54 an hour) plus 36.25% fringe and overhead burden rate, the one mandated by OMB memorandum M-08-13 for use in public-private competition, rounded to the nearest dollar, or $67 an hour. Reference Salary Table 2020-RUS, Effective January 2020, found at www.opm.gov.

14. Estimated cost to the Government. Time required to review information is estimated at 4 hours per response.

Total annual responses............................... 1,644

Review time per response (hours).................... x 4

Review time per year (hours)........................ 6,576

Hourly rate*....................................... x $67

Estimated Government Cost ....................... $440,592

15. Explain reasons for program changes or adjustment reported in Item 13 or 14. The decrease of responses from 13,024 to 1,644 and the associated decrease in estimated burden hours from 377,696 to 47,676 is an adjustment due to use of the most current data available.

16. Outline plans for published results of information collection. Results will not be tabulated or published.

17. Approval not to display expiration date. Not applicable.

18. Explanation of exception to certification statement. Not applicable.

B. Collections of Information Employing Statistical
Methods.

Statistical methods are not used in this information collection.