Supporting Statement for SF123 (2021)

Supporting Statement for Paperwork Reduction Act Submission

3090-0014 –Standard Form (SF) 123/123-A, Transfer Order-Surplus Personal Property and Continuation Sheet

A. Justification

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

The Standard Form (SF) 123/123-A is required by the Administrator of General Services to carry out her discretionary authority under 40 U.S.C. to transfer Federal surplus personal property for donation. The statutory language is as follows:

40 U.S.C. 549 - Sec. 549. Donation of personal property through state agencies. (b) Authorization. - (1) In general. - The Administrator of General Services, in the Administrator’s discretion and under regulations the Administrator may prescribe, may transfer property described in paragraph (2) to a state agency.

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.

If the forms were to be discontinued, the Government would lack a regulated legal instrument to donate its surplus property as required by law. This is not purely a document for public informational purposes, but rather, the SF 123/123-A serves as the instrument for transferring Government surplus property to eligible recipients. Initially, the form is used to make a request for donable property. When the property request is approved, the form becomes a binding agreement between the Government and the State Agency for Surplus Property (SASP) for the benefit of the recipient that spells out the terms and conditions under which the property is being transferred. The form is authorized for use by—

a. SASPs requesting transfer approval of property to public agencies for public purposes, such as conservation, economic development, education, parks and recreation, public health, public safety, programs for the homeless, and programs for the elderly; to nonprofit educational or public health activities, including programs for the homeless; and to nonprofit activities that conduct programs for the elderly;

b. Service educational activities (any educational activity designated by the Secretary of Defense as being of special interest to the armed services. Includes maritime academies or military, naval, Air Force or Coast Guard preparatory schools and the following national organizations: American National Red Cross, Armed Services YMCA of the USA, Big Brothers/Big Sisters of America, Boy Scouts of America, Boys Clubs of America, Campfire, Inc., Center for Excellence in Education, Girl Scouts of the USA, Little League Baseball, Inc., National Ski Patrol System, Inc., Naval Sea Cadet Corps, Operation Raleigh, United Service Organizations, Inc., United States Olympic Committee, and the Young Marines of the Marine Corps League); and

c. Public airport managers and State aeronautical commissions for public airport purposes.

d. Small Business Administration (SBA) 8(a) Business Development Participants (SBA 8(a)) and Veteran-owned Small Businesses (VOSB) to support and grow their business (pursuant to an MOA between SBA, GSA and the donating SASP).

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.

SF 123/123-A is now generated electronically by the property management computer system – GSAXcess®. State Agencies for Surplus Property (SASP) need only enter the quantity of the item they are requesting and verify other data that is resident in the system and it will be printed on the 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.

Duplicative forms were eliminated when the SF 123/123-A was first issued. After March 1, 1965, the SF 123/123-A replaced Form 13, Application for Donation of Surplus Personal Property (Service Educational Activities, Department of Defense); HEW Form 135, Application for Surplus Property; HEW Form 136, Notice of Determination, Surplus Personal Property; and FAA Form 3130, Application for Donation of Surplus Personal Property.

5. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

SBA 8(a)s and VOSBs can receive surplus property under 15 U.S.C. 636(j)(13)(F) and 15 U.S.C. § 657b (g), respectively through a State Agency for Surplus Property (SASP) in states that participate and have a signed GSA-SASP-SBA Memorandum of Agreement. The SASP fills out and signs the SF123 thus eliminating any burden to the SBA 8(a) or VOSB.

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.

There is no set frequency for submitting a SF 123/123-A; the form may be submitted whenever an eligible donee has a need for the property that is available for donation.

7. Explain any special circumstances.

Not applicable. No special circumstances.

8. Describe efforts to consult with persons outside the agency.

A 60-day notice published in the Federal Register at 86 FR 66564 on November 23, 2021. No comments were received. A 30-day notice published in the Federal Register at 87 FR 10796 on February 25, 2022.

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

GSA did not provide any payment or gift to the respondents.

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

This information is disclosed only to the extent consistent with prudent business practices and current regulation.

11. Provide additional justification for any questions of a sensitive nature.

No questions of a sensitive nature are asked.

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

The estimated number of responses annually is 31,202. 1% of the responses are done manually (312 forms) requiring an estimated 8 minutes (.13 hours) to prepare. The other 99% of the forms (30,890 forms) are completed electronically, requiring an estimated 1 minute to prepare (.017 hours), for a total of 565.69 burden hours. The hourly wage ($20) is an estimated average provided by the National Association of State Agencies for Surplus Property (NASASP) leadership.

Total Number of Respondents: 31,202

Respondents (manual): 312 respondents X .13 hours = 40.56 Hours Per Response

Respondents (electronic): 30,890 respondents X .017 hours = 525.13 Hours Per Response

40.56 Hours Per Response + 525.13 Hours Per Response = 565.69 Total Burden Hours

Cost Computation (SF 123/123-A)

Hourly Wage $20.00

Total Burden Hours X 565.69

Annual Hour Burden Cost to Respondents $11,313.80

The cost per response is estimated at $ .36. There is no additional cost to respondents.

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

The total number of responses is estimated to be 31,202 each year;

Reviewing and processing each response should take approximately 1.5 minutes;

31,202 X 1.5 = 46,803;

46,803 divided by 60 = 780.05 Burden Hours.

Burden Hours 780.05

Average Cost/Hr X $47.10

Total Government Cost $36,740.36

The estimated annual cost to the taxpayer is $36,740.36 using the above reference of 780.05 burden hours x $47.10 per hour (GSA Allocating Official Average Salary).

15. Explain the reasons for any program changes or adjustments reported in Items 13 & 14.

The number of SF123/123-As processed in this program is driven by the amount of property made available for donation by Federal agencies and the demand for donations experienced by the SASPs. The amount of surplus property Federal agencies make available for transfer to the States fluctuates from year to year, and the demand for such property by the States for their donation customers also fluctuates from year to year. These fluctuations are independent of each other.  GSA has no control over either of these factors, and cannot predict how they might change over time. The Total Government Cost has increased since the last submission of this justification. In addition, the average cost per hour was calculated using the GSA Allocating Official’s average salary to more accurately reflect the cost to the Government. While the number of respondents and number of burden hours has decreased over the past three years, the average salary has increased, leading to a slightly higher calculated Total Government Cost ($36,740.36). GSA could not determine how the salaries were calculated three years ago, so the current figure is an average based on existing salary wages in relevant locality pay regions.

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.

Not applicable. Results are not published for statistical use.

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.

Not applicable.

18. Explain each exception to the certification statement identified in the

“Certification for Paperwork Reduction Act Submissions”.

None.

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