1205-0439SupportStatement05112010 ChartRvs0514

Supporting Statement, OMB Control No. 1205-0439, National Emergency Grants
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 of 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.

The information collection is necessary for the U.S. Department of Labor’s (DOL’s) award of
National Emergency Grants (NEGs) which are discretionary grants intended to temporarily
expand the service capacity at the state and local area levels by providing funding assistance in
response to significant dislocation events for workforce development and employment services
and other adjustment assistance for dislocated workers and other eligible individuals as defined
in sections 101, 134 and 173 of the Workforce Investment Act (WIA) (P.L. 105-220); sections
113, 114 and 203 of the Trade Adjustment Assistance (TAA) Reform Act of 2002 (P.L. 107210), as amended by the Trade and Globalization Adjustment Assistance Act (TGAAA) of 2009;
and 20 CFR 671.140.
Funds are available for obligation by the Secretary under Sections 132 and 173 of the
WIA, and Section 203 of the TAA Reform Act of 2002. Applications will be accepted on an
ongoing basis as the need for funds arises at the state and local level.
The provisions of WIA and the Regulations define four NEG project types:
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REGULAR, which encompasses plant closures, mass layoffs, and multiple layoffs in a
single community.
DISASTER, which includes all eligible Federal Emergency Management Agency
(FEMA)-declared natural and manmade disaster events.
TAA–WIA DUAL ENROLLMENT, which provides supplemental funding to ensure that
a full range of services is available to individuals eligible under the TAA program
provisions of the TAA Reform Act of 2002, as amended by the TGAAA.
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►

TAA HEALTH INSURANCE COVERAGE ASSISTANCE, which provides specialized
health coverage, support services, and income assistance to targeted individuals defined
in the TAA Reform Act of 2002, as amended by the TGAAA.

Nine electronic forms are employed by the NEG program :
ETA 9103-1, Cumulative Planning Form (sometimes a customized variation is
used – ETA 9103-2a, ETA 9103-2b, ETA 9103-3 or ETA 9103-4);
ETA 9104, Quarterly Report;
ETA 9105, Employer Data Form;
ETA 9106, Project Synopsis; and
ETA 9107, Project Operator Data Form.
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.

For the application information collection, the purpose is to judge whether to approve an
application requesting grant funds. Specifically, the purpose of the grant application forms is to
provide the grant officer with the necessary information during the application review process to
make consistent and objective funding decisions based on the stated funding request evaluation
criteria.
For the quarterly reports information collection, the purpose is to assure accountability and to
measure actual project performance to date.
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.

In compliance with the Government Paperwork Elimination Act, the information collection is
fully in an electronic format. Electronic applications allow for ease of completion and timeliness
of submission by the applicant, and timely processing of the application by the grant officer.
These electronic applications are, of course, compliant with Section 508 of the Rehabilitation
Act (29 U.S.C. 794d), as amended by the Workforce Investment Act of 1988 (P.L. 105-220).
E-applications are made through the DOL/ETA Grantee Reporting System Internet website for
NEGs at http://etareports.doleta.gov. An instructional User’s Guide has been prepared for the eapplication system. Moreover, in order to reduce the reporting burden for the applicants, as well
as in order to ensure the completeness and consistency of the information provided, automated
edit checks are programmed into the e-application system. The authorized signatory of the
applicant is issued a unique Personal Identification Number (PIN). The entry of this PIN
constitutes the authorized signature.

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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.

The information collection avoids duplication because, although the eligible circumstances for
NEG funding are of a recurring nature, the specific applications are unique. Therefore, the
collected information will differ for each application. Moreover, the information collection will
constitute the sole source of information for funding decisions regarding this assistance.
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.

The information collection does not significantly impact small businesses or other small entities.
NEG grantees are all States or local entities.
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.

Pursuant to the WIA statutory rules and regulations relevant to the NEG program, if the
information collection is not performed, NEG funds cannot be awarded or disbursed. The
requested information collection has been designed in order to achieve compliance with those
WIA statutory rules and regulations.
7.

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

requiring respondents to report information to the agency more often than
quarterly;

Š

requiring respondents to prepare a written response to a collection of information
in fewer than 30 days after receipt of it;

Š

requiring respondents to submit more than an original and two copies of any
document;

Š

requiring respondents to retain records, other than health, medical, government
contract, grant-in-aid, or tax records for more than three years;

Š

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;

Š

requiring the use of a statistical data classification that has not been reviewed and
approved by OMB;
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Š

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

Š

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.

There are no special circumstances concerning the information collected.
Although there is no fixed deadline for the information collection, we do request that
applications for NEGs be completed and submitted as early as possible, in order to provide
timely workforce development and employment services and other assistance to eligible
individuals under the NEG program.
8.

If applicable, provide a copy and identify the data 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.

In accordance with 5 CFR 1320.5, a Federal Register Notice was published on February 2, 2010
(Vol. 75, page, 5326), to provide a 60-day period for commenting on the proposed extension of
this information collection. No comments pertinent to the information collection request were
submitted.
9.

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

There will be no payments made, or gifts given, to respondents in association with the NEG
program.
10.

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

The information collection does not include confidential information, and therefore no
assurances of confidentiality need to be provided to respondents.
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,
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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 private, sensitive nature asked in the information collection.
12.

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

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.

Š

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.

Š

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 14.

The forms for this collection are:


ETA 9103/Planning Form which provides cumulative quarterly estimates on
project scope (e.g. number of participants, exits), design (e.g., mix of enrollments
in activities), and use of funds (e.g. planned expenditures by type of program
activity. [Most applicants will complete the ETA 9103-1. To accommodate
specialized circumstances it is necessary to use a customized version of the 91031 instead, which take the same amount of time to complete: ETA-9103-2a, ETA9103-2b, ETA-9103-3, or ETA-9103-4.]



ETA 9105/Employer Data Form provides employer and dislocation site-specific
information needed to validate the eligibility of the dislocation event(s) and of the
target group of workers affected for NEG assistance.



ETA 9106/Project Synopsis Form summarizes key aspects of he proposed project,
such as project type, type of eligible event, key contact information, planned
number of participants, performance goals and historical and planned cost per
participant levels.
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

ETA 9107/Project Operator Data Form includes key contact and project scope
information (e.g., number of participants, total budget, service area) for each
project operator.



ETA 9104 /Quarterly Reporting Form provides the Grant Officer with a quarterly
record of actual project performance to date.



Certification Regarding Eligibility To Apply for Worker Adjustment Assistance
and Alternative Trade Adjustment Assistance identifies the trade certification
number(s) for the workers included in the target group for the project.

A reporting burden estimate table is shown below:
Estimated Total Annualized Hour Burden
Reference
Expected Total Frequency
Expected
Respondents*
Total
Responses*
Narrative
Summary
150
1 per project
150
ETA 9103-1
70
1 per project
70
ETA 9103-2a
11
1 per project
11
ETA 9103-2b
4
1 per project
4
ETA 9103-3
50
1 per project
50
ETA 9103-4
15
1 per project
15
ETA 9105
135
1 per project
135
ETA 9106
150
1 per project
150
ETA 9107
150
1 per project
150
Reports:
150
quarterly
600
ETA 9104
per project
TAA
50
1 per project
50
Certification
Report
Grant
150
1 per project
150
Modifications
Annualized
1,535
TOTAL
responses

Avg. Time
per Response

Expected
Burden*

1 hour
90 minutes
90 minutes
90 minutes
90 minutes
90 minutes
30 minutes
1 hour
15 minutes
30 minutes

150 hours
105 hours
16.5 hours
6 hours
75 hours
22.5 hours
68 hours
150 hours
38 hours
300 hours

30 minutes

25 hours

30 minutes

75 hours

345 minutes
1,031 hours
or 5.75 hours
total divided
by 1,535
responses =
.2247 minutes
per response
* Actual number will vary, because the information collection is required to obtain a benefit.
Estimates of the total annualized hour burden and the annualized costs for the collection of this
information are based upon the experience to date with NEGs.
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Mean hourly rate: $20.09
(Source: BLS Occupational Employment Statistics, “Employment and wages by major
occupational groups, 2008, “Community and social services occupations”)
Annualized cost of hour burden: $20.09/hour x 1,144 hours = $22,982.96
13.

Provide an estimate of 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).
Š

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.

Š

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 collection 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.

Š

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 is no cost burden for reporting.
The amount of funding used for administrative costs for NEGs, including operating and
maintaining systems, is expected to vary among the NEG recipients. In the NEG application
procedures, the Department provides that up to ten percent of the NEG may be used for
administrative costs.
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
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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 also may aggregate cost estimates from Items 12, 13, and 14 in a
single table.
Estimates of annualized cost to the Federal government for this collection are based upon
experience to date with NEGs. Operational expenses will include staff support, which is
estimated to require an equivalent of one FTE at the GS-15 level, one FTE at the GS-14 level,
five FTE at the GS-13 level, two FTE at the GS-12 level, one FTE at the GS-11 level and one
FTE at the GS-7 level. These costs would total approximately $780,000 per year. There will be
no need for additional equipment, overhead or printing costs to support this collection.
15.

Explain the reasons for any program changes or adjustments.

There were no program changes or adjustments; however, the previous submission inadvertently
included the SF 424 in the calculations for estimated total annualized hour burden (150
respondents, 113 burden hours). ETA excluded these figures, thus reducing the number of total
respondents and burden hours despite the slight increase in the currently estimated number of
annual submissions of some forms and subsequent increase in the hour burden. Specifically,
ETA 9105 respondents increased from 75 to 135, ETA 9107respondents, from 100 to 150, and
grant modification submissions from 140 to 150, for a total increase of 120 respondents and 40
burden hours. The net difference is 30 fewer respondents and 73 fewer burden hours.
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 the information collection will not be published.
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.

ETA will display the OMB control number and expiration date on the e-application and reporting
forms ETA 9103, 9104, 9105, 9106 and 9107.
18.

Explain each exception to the certification statement identified in Item 19, "Certification
for Paperwork Reduction Act Submission," of OMB 83-I.

There are no exceptions to the certification statement.

B. Collection of Information Employing Statistical Methodology
This collection does not employ statistical methodology.
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