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Supporting
Statement for Paperwork Reduction Act Submissions
HUD
Multifamily Energy Assessment
OMB Control Number 2502–0568
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. Include a statement regarding the
changes for this submission. (Example: The changes for this
submittal is as follows or the difference between this submission
and the last is as follows....)
Section
154 of the Energy Policy Act of 2005 directs Housing Urban
Development (HUD) to develop and implement an integrated strategy
to reduce utility expenses through cost-effective energy
conservation and efficiency measures in design and construction
of public and assisted housing. The chapter supports HUD’s
Energy Strategy as reported to Congress in August 2016 and the
Memorandum of Understanding entered into by HUD, The United
States Environmental Protection Agency, and the United States
Department of Energy in 2002.
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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.
This
information will be used by owners and managers of multifamily
housing projects to assist with determining reasonable and
necessary upgrades to their property to meet cost-effective
energy efficiency standards.
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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.
Automation
of this information collection is not feasible. The energy
assessment to reduce utility expenses requires management staff
to physically walk through the project and determine energy
improvement needs.
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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.
There
is no duplication of other sources for this information, and the
information collected on form HUD-9614 by the owner is not
directly provided to HUD.
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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 burden.
This
collection of information does not impact small businesses or
other small entities, with the exception of certain nonprofit
owners and owners of small multifamily housing projects. The
information collected on form HUD-9614 by the owner is not
directly provided to HUD.
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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.
Owners
are expected to certify that they are in compliance with the
requirements and recommendations of Chapter 12 “Energy
Conservation” of HUD Handbook 4350.1 Multifamily Asset
Management. HUD would be in noncompliance with Section 154 of the
Energy Policy Act of 2005 by failing to encourage the efficient
use of energy in multifamily properties.
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7.
Explain any special circumstances that would cause an information
collection to be conducted in a manner: (PLEASE ANSWER EACH
BULLET SEPARATELY)
*
requiring respondents to report information to the agency more
often than quarterly;
There
is no requirement for respondents to report the information more
than quarterly
*
requiring respondents to prepare a written response to a
collection of information in fewer than 30 days after receipt of
it;
There
is no requirement for respondents to prepare a written response
to a collection in fewer than 30 days. HUD does not require use
of the form for any other purpose. The information collected on
form HUD-9614 by the owner is not directly provided to HUD.
Owners are expected to certify that they are in compliance with
the requirements and recommendations of Chapter 12 “Energy
Conservation” of HUD Handbook 4350.1 “Multifamily
Asset Management and Project Servicing”.
*
requiring respondents to submit more than an original and two
copies of any document;
There
is no requirement for respondents to submit more than an original
of any document.
*
requiring respondents to retain records, other than health,
medical, government contract, grant-in-aid, or tax records, for
more than three years;
There
is no requirement for respondents to retain records other than
health, medical, government contract, grant-in-aid, or tax
records for more than three years.
*
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;
*
requiring the use of a statistical data classification that has
not been reviewed and approved by OMB;
This
collection is not made in connection with a statistical survey.
*
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; or
There
is no pledge of confidentiality that is not supported by
authority established in statute or regulation.
*
requiring respondents to submit proprietary trade secrets, 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.
There
is no requirement for respondents to submit proprietary trade
secrets, or other confidential information.
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8.
If applicable, provide a copy and identify the date and page
number of publication in the Federal Register of the agency's
notice, required by 5 CFR 1320.8(d), 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.
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. Consultation
with representatives of those from whom information is to be
obtained or those who must compile records should occur at least
once every 3 years - even if the collection of information
activity is the same as in prior periods. There may be
circumstances that may preclude consultation in a specific
situation. These circumstances should be explained.
In
accordance with 5CFR 1320.8(d), this information collection
soliciting public comments was announced in the Federal
Register
on August
30, 2022,
Volume 87,
No. 167,
Pages 52990.
(0) Comment received.
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9.
Explain any decision to provide any payment or gift to
respondents, other than remuneration of contractors or grantees.
There
are no payments or gifts to respondents.
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10.
Describe any assurance of confidentiality provided to respondents
and the basis for the assurance in statute, regulation, or agency
policy.
The
document contains no personally identifying information subject
to privacy requirements.
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11.
Provide additional justification for any questions 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.
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12.
Provide estimates of the hour burden of the collection of
information. The statement should:
*
Indicate the number of respondents, frequency of response, annual
hour burden, and an explanation of how the burden was estimated.
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 desirable. 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.
*
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.
*
Provide estimates of annualized cost to respondents for the hour
burdens for collections of information, identifying and using
appropriate wage rate categories. The cost 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.
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Information
Collection
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Number
of Respondents
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Frequency
of Response
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Responses
Per Year
|
Average
Burden
Hours Per Response
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Annual
Burden Hours
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Hourly
Cost per Response
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Total
Annual Cost
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HUD-9614
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12,270
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1
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12,270
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8.00
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98,159.00
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27.00
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2,677,758.00
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Certification
of Compliance
|
6,809
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1
|
6,809
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0.25
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1,702.00
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27.00
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46,437.00
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TOTALS
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19,079
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19,079
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99863.03
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2,724,195
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Estimated
number of responses for Certification of Compliance is based on 5% of
total respondents that may request a budget based rent increase and
as a result will be required to provide a certification of compliance
with HUD Handbook 4350.1, Chapter 12.
Hourly
cost is based on an estimate of the owner or owner’s staff to
perform the energy assessment and prepare the necessary documents if
developing an energy conservation plan or requesting a utility
conversion. Estimated hourly costs were obtained from payscale.com.
0.6859115
13.
Provide an estimate for the total annual cost burden to
respondents or record-keepers resulting from the collection of
information. (Do not include the cost of any hour burden shown in
Items 12 and 14).
*
The cost estimate should be split into two components: (a) a
total capital and start-up cost component (annualized over its
expected useful life) and (b) a total operation and maintenance
and purchase of services component. The estimates should take
into account costs associated with generating, maintaining, and
disclosing or providing the information. Include descriptions of
methods used to estimate major cost factors including system and
technology acquisition, expected useful life of capital
equipment, the discount rate(s), and the time period over which
costs will be incurred. Capital and start-up costs include, among
other items, preparations for collecting information such as
purchasing computers and software; monitoring, sampling, drilling
and testing equipment; and record storage facilities.
*
If cost estimates are expected to vary widely, agencies should
present ranges of cost burdens and explain the reasons for the
variance. The cost of purchasing or contracting out information
collections services should be a part of this cost burden
estimate. In developing cost burden estimates, agencies may
consult with a sample of respondents (fewer than 10), utilize the
60-day pre-OMB submission public comment process and use existing
economic or regulatory impact analysis associated with the
rulemaking containing the information collection, as appropriate.
*
Generally, estimates should not include purchases of equipment or
services, or portions thereof, made: (1) prior to October 1,
1995, (2) to achieve regulatory compliance with requirements not
associated with the information collection, (3) for reasons other
than to provide information or keep records for the government,
or (4) as part of customary and usual business or private
practices.
There
are no additional costs to respondents.
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14.
Provide estimates of annualized costs 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 not have been incurred
without this collection of information. Agencies may also
aggregate cost estimates from Items 12, 13, and 14 in a single
table.
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Information
Collection
|
Number
of Respondents
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Frequency
of Response
|
Responses
Per Year
|
Burden
Hours Per Response
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Annual
Burden Hours
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Hourly
Cost per Response
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Total
Annual Cost
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HUD-9614
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12,270
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1
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12,270
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1
|
12,270
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30
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368,095
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Certification
of Compliance
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6,809
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1
|
6,809
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0.25
|
1,702
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30
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50,659
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TOTALS
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19,079
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19,079
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13,972
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418,754
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Estimated
cost per hour for HUD staff (GS-12) to review and process the
documents for this collection
15.
Explain the reasons for any program changes or adjustments
reported in Items 13 or 14 of the OMB Form 83-I.
This
is a reinstatement, without change, of previously approved
collection for which approval has expired. The change in inventory
in item 13 of page 1 reflects project owners that paid or prepaid
their mortgage and no longer have a requirement to submit energy
usage estimates to the Department, and newly insured projects that
have been added to the portfolio since last report.
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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.
The
results of this collection will not be published.
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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.
HUD
is not requesting approval to not display the expiration date.
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18.
Explain each exception to the certification statement identified
in Item 19, "Certification for Paperwork Reduction Act
Submissions," of OMB Form 83-I.
There
are no exceptions to the certification statement identified in
Item #19 on form OMB 83i, “Certification for Paperwork
Reduction Act Submissions”.
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B.
Collections of Information Employing Statistical Methods
The
agency should be prepared to justify its decision not to use
statistical methods in any case where such methods might reduce
burden or improve accuracy of results. When Item 17 on the Form OMB
83-I is checked, "Yes," the following documentation should
be included in the Supporting Statement to the extend that it applies
to the methods proposed:
1.
Describe (including a numerical estimate) the potential respondent
universe and any sampling or other respondent selection methods to be
used. Data on the number of entities (e.g., establishments, State and
local government units, households, or persons) in the universe
covered by the collection and in the corresponding sample are to be
provided in tabular form for the universe as a whole and for each of
the strata in the proposed sample. Indicate expected response rates
for the collection as a whole. If the collection had been conducted
previously, include the actual response rate achieved during the last
collection.
2.
Describe the procedures for the collection of information including:
*
Statistical methodology for stratification and sample selection,
*
Estimation procedure,
*
Degree of accuracy needed for the purpose described in the
justification,
*
Unusual problems requiring specialized sampling procedures, and
*
Any use of periodic (less frequent than annual) data collection
cycles to reduce burden.
3.
Describe methods to maximize response rates and to deal with issues
of non-response. The accuracy and reliability of information
collected must be shown to be adequate for intended uses. For
collections based on sampling, a special justification must be
provided for any collection that will not yield "reliable"
data that can be generalized to the universe studied.
4.
Describe any tests of procedures or methods to be undertaken. Testing
is encouraged as an effective means of refining collections of
information to minimize burden and improve utility. Tests must be
approved if they call for answers to identical questions from 10 or
more respondents. A proposed test or set of test may be submitted for
approval separately or in combination with the main collection of
information.
5.
Provide the name and telephone number of individuals consulted on
statistical aspects of the design and the name of the agency unit,
contractor(s), grantee(s), or other person(s) who will actually
collect and/or analyze the information for the agency.
There
are no statistical methods used in this collection.
File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
File Modified | 0000-00-00 |
File Created | 2023-09-07 |