1205-0439 Statement 6 20 2013

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. 107-210), as amended.

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, as amended. 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:

► 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.

► 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.

Five 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;

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 e-application 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.

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.

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:

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

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

• requiring respondents to submit more than an original and two copies 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;

• 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;

• 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

• 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.

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.

In accordance with 5 CFR 1320.5, a Federal Register Notice was published on May 29, 2013 (Vol 78, p 32277), to provide a 60-day period for commenting on the proposed extension of this information collection. No comments were received.

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, 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:

• 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 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 customized versions of the 9103-1, which take the same amount of time to complete: ETA-9103-2a, ETA-9103-2b, 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 the 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.

• 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.

A reporting burden estimate table is shown below:

Estimated Total Annualized Hour Burden
Reference	Expected Total Respondents*	Frequency	Expected Total Responses*	Avg. Time per Response	Expected Burden*
Narrative Summary	150	1 per project	150	60minutes	150 hours
ETA 9103-1	70	1 per project	70	90 minutes	105 hours
ETA 9103-2a	11	1 per project	11	90 minutes	16.5 hours
ETA 9103-2b	4	1 per project	4	90 minutes	6 hours
ETA 9103-3	50	1 per project	50	90 minutes	75 hours
ETA 9103-4	15	1 per project	15	90 minutes	22.5 hours
ETA 9105	135	1 per project	135	30 minutes	68 hours
ETA 9106	150	1 per project	150	60 minutes	150 hours
ETA 9107	150	1 per project	150	15 minutes	38 hours
Reports: ETA 9104	150	quarterly per project	600	30 minutes	300 hours
Grant Modifications	150	1 per project	150	30 minutes	75 hours
Annualized TOTAL			1,485 responses	315 minutes (5.25) hours total divided by 1,485 responses = .2121 minutes per response	1,006 hours
* 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.

Mean hourly rate: $21.27(Source: BLS Occupational Employment Statistics, “Employment and wages by major occupational groups, 2012, “Community and social services occupations”)

Annualized cost of hour burden: $21.27/hour x 1006 hours = $21,397.62

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).

• 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 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.

• 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, generally, 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 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 maintaining and improving functionality of the electronic system for respondents. These costs would total approximately $350,000 per year, which would include staff level costs for GS-15, GS-13, and contractor staff.

15. Explain the reasons for any program changes or adjustments.

There were minor program changes or adjustments which are explained below:

The previous submission inadvertently included the TAA Certification Report as part of the annualized burden hour total. This report is not a form that is generated by the NEG program. As a result, the expected total responses, average time per response, and expected burden hours have been reduced as a result of the removal of this report from the Estimated Total Annualized Hour Burden chart. The NRP Processing line on the ETA 9103-2a has also been removed, since participants in this NEG type are not eligible to receive NRPs. The Contact Person line was omitted from the ETA 9107 Project Operator Data Form in the previous submission, and that line has been re-inserted. Additionally, four lines were added to the ETA 9103-1 for On-the-Job Training NEGs: Enrolled in OJT Only, Entering OJT Employment at Exit, Entering OJT-Related Employment at Exit, and OJT Training Employer Reimbursement. Since Grantees already have this data, there is no added collection burden. Also, on the ETA 9105, a request for a description of the event and activities to be provided was added to the form. Grantees nearly always include these descriptions voluntarily in Narrative Statements or attachments, so no additional collection burden is being incurred as a result of this addition.

Lastly, the On-the-Job Training NEG Implementation Plan was also removed from the burden calculations. Most of these grants have expired and, of the few remaining, in the event that any modifications/updates need to be made to their existing Implementation Plans, that minor effort is easily covered within the burden estimate provided under Grant Modifications in the burden estimate table above.

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.

8