1660-0068 - Supporting Statement A - 2025 03 27 clean

March 27, 2025

Supporting Statement for Paperwork Reduction Act Submissions

OMB Control Number: 1660-0068

Title: Federal Hotel and Motel Fire Safety Declaration Form

Form Number(s): FF-USFA-FY-21-112 (formerly FEMA Form 516-0-1), Federal Hotel and Motel Fire Safety Declaration Form

General Instructions

A Supporting Statement, including the text of the notice to the public required by 5 CFR 1320.5(a)(1)(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 or 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. Provide a detailed description of the nature and source of the information to be collected.

The Hotel and Motel Fire Safety Act of 1990 (“Hotel Safety Act”)(Pub. L. 101-391) requires the

U.S. Fire Administration (USFA)¹ to establish and maintain a National Master List (NML) of hotels, motels, and similar places of public accommodation (see 15 U.S.C. § 2224(b)).

The purpose of collecting the information and compiling it into a list is to identify lodging establishments that offer travelers, including Federal employees on government business, a level of life-safety from fire. The collection information is public and available through the USFA website. The nature of the information collected is that it is voluntary, consists only of basic identifying information related to the business, and a declaration that every guestroom has a hard-wired, single- station smoke alarm, as well as the existence of an automatic fire sprinkler system if there are four or more stories.

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. Provide a detailed description of: how the information will be shared, if applicable, and for what programmatic purpose.

The Federal Hotel and Motel Fire Safety Declaration Form, FF-USFA-FY-21-112 (formerly FEMA Form 516-0-1), is used to collect basic information on life-safety systems related directly to fire-safety in hotels, motels, and similar places of accommodation applying for inclusion on the NML. In completing the form, applicants—property owners, lodging managers, or their delegates—provide basic information including identification of the owner(s) of the property, the business’s Employer Identification Number (EIN), and provisions for life-safety from fire.

The form requests specific responses from applicants as to the installation of smoke alarms in all guestrooms of properties submitted for listing on the NML. In addition, applicants must indicate if the lodging establishment has an automatic fire sprinkler system where the building is four stories or higher. Once approved for the NML, the database record for each lodging establishment is assigned a unique identification number (FEMA ID).

The information is collected and distributed through an on-line, electronic database accessed through the USFA website. Information submitted voluntarily by lodging establishments is reviewed and if the criteria meet the requirements of the Hotel Safety Act, they are given a FEMA ID number and listed in the NML database. Federal travelers and the public seeking public accommodation with provisions for life-safety from fire access the NML through the on- line database and identify lodging establishments in the area to which they are traveling.

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.

The prevailing trend has been and continues to be away from the use of paper form and toward the on-line submission and retrieval of the NML information collected by applicants and users. The number of forms submitted by mail, email, or facsimile has steadily declined and now averages 10 per year. The number submitted through an online form has increased.

Submitting on-line requires a computer and an Internet connection. Completing and submitting the application form on-line takes less time for final approval and issuance of a FEMA ID number. The USFA Hotel-Motel webpage https://apps.usfa.fema.gov/hotel/ has a link that leads to the form https://apps.usfa.fema.gov/hotel/register, and where applicants may login and enter the required information for requesting or updating a listing on the NML. The information provided on-line is the same information as requested on FF-USFA-FY-21-112 (formerly FEMA Form 516-0-1). In submitting the completed form, the applicant declares under penalty of law that the information presented is not false or fraudulent.

Information submitted is reviewed and if the criteria of the Hotel Safety Act are met, the property is listed on the NML. The NML is a web-based relational database allowing instant updating as information is added, edited, or deleted. This is the most cost-effective method of making the information current and accessible to any traveler seeking guest accommodation in a property offering basic life-safety protection from fire.

Usability testing was conducted by observing four USFA employees from other lines of business while they navigated the application process. The testers were either observed in person or electronically shadowed by sharing their screen while navigating the application process. All four testers were able to complete the application without needing additional guidance from the observer. All four testers felt the application form was concise, easy to follow, easy to understand, and able to be completed in 10 minutes or less.

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.

This information is not collected in any form, and therefore, is not duplicated elsewhere.

5. If the collection of information impacts businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize.

This information collection has an impact on small entities, however, USFA mitigates that impact. Of the over 57,000 properties that have participated in the completion of the Hotel and Motel Safety Declaration Form, the USFA estimates that approximately 5,000 or 10 percent are considered small entities. The USFA mitigates the impact of this information collection by providing two options for submitting information—fully web-based entry or paper forms entry which reduces the burden to all properties that are voluntarily completing the registration. Properties inclusion in the NML consists of a onetime initial registration. The online database allows properties to access previously submitted data to provide additional updates, so the initial registration information does not need to be resubmitted.

6. Describe the consequence to Federal/FEMA program or policy activities if the collection of information is not conducted, or is conducted less frequently as well as any technical or legal obstacles to reducing burden.

Without this collection there would be an undue burden on a traveler seeking guest accommodations that meet the requirements of the law. The HMFSA requires this list be created and maintained. Initially, the list was published annually in the Federal Register. With the advent of web-based data collection and public access, the NML is updated daily.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner (See 5 CFR 1320.5(d)(2)):

1. Requiring respondents to report information to the agency more often than quarterly.

This information collection does not require respondents to report information more than quarterly

2. Requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

This information collection does not require respondents to prepare a written response in fewer than 30 days after receipt of it.

3. Requiring respondents to submit more than an original and two copies of any document.

This information collection does not require respondents to submit more than an original and two copies of any document.

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

This information collection does not require respondents to retain records (other than health, medical, government contract, grant-in-aid, or tax records) for more than three years.

5. 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.

This information collection does not include a statistical survey.

6. Requiring the use of a statistical data classification that has not been reviewed and approved by OMB.

This information collection does not use a statistical data classification that has not been reviewed and approved by OMB.

7. That includes a pledge of confidentiality that is not supported by authority established in statue 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.

This information collection does not include a pledge of confidentiality that is not supported by established authorities or policies.

8. 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.

This information collection does not require respondents to submit trade secrets or other confidential information.

8. Federal Register Notice:

1. Provide a copy and identify the date and page number of publication in the Federal Register of the agency’s notice 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.

A 60-day Federal Register Notice inviting public comments was published on December 11, 2024, at 89 FR 99889. FEMA received zero public comments.

A 30-day Federal Register Notice inviting public comments was published on March 27, 2025,at 90 FR 13868. The 30-Day public comment period closes on April 28, 2025.

2. 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.

The USFA consulted with representatives from 21 States and U.S. territories as well as Property Managers to obtain their reviews on this information collection. This year’s consultation included representatives from the State Fire Marshal’s Offices in Colorado, Florida, Nebraska, Puerto Rico, West Virginia, as well as 16 others. In addition, daily contact is made with Property Managers to update records on the NML. No comments were received on FF-USFA- FY-21-112 (formerly FEMA Form 516-0-1).

3. Describe consultations with representatives of those from whom information is to be obtained or those who must compile records. Consultation should occur at least once every three years, even if the collection of information activities is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

The USFA consults with representatives from the U.S. States and territories at least once a year or more as needed. The Property Managers consult USFA daily as records need to be updated. No comments were received on FF-USFA-FY-21-112 (formerly FEMA Form 516-0-1).

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

FEMA does not provide payments or gifts to respondents in exchange for a benefit sought.

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

The updated Privacy Threshold Analysis (PTA) was approved by the Department of Homeland Security’s (DHS’s) Privacy Office on January 19, 2024.

Privacy Impact Assessment (PIA) coverage is provided by DHS/ALL/PIA-006 DHS General Contacts Lists. (January 19, 2024).

System of Records Notice (SORN) coverage is provided by DHS/ALL-004 General Information Technology Access Account Records System of Records. (January 19, 2024).

Participation in the Hotel and Motel Fire Safety Program is voluntary. The information is business-related (hotel or motel entity) and involves only point of contact for the business. It does, however, require the Employer Identification Number (EIN) of the business applying to the NML. Participants are aware of the voluntary nature of registration and the intended publication of limited (non-critical or non-essential) information on the USFA website of the information contained in the NML. There are no assurances of confidentiality provided to the respondents for this information collections.

11. Provide additional justification for any question of a sensitive nature (such as sexual behavior and attitudes, religious beliefs and other matters that are commonly considered private). This 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 sensitive nature.

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

1. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated for each collection instrument (separately list each instrument and describe information as requested). Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consolation with a sample (fewer than 10) of potential respondents is desired. 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.

FF-USFA- FY-21-112 (formerly FEMA Form 516-0-1), Federal Hotel and Motel Fire Safety Declaration Form is estimated that 2,000 lodging managers (Business or other For-

Profit) will complete one (1) FEMA Form FF-USFA-FY-21-112 (formerly FEMA Form 516-0- 1) per each lodging establishment they seek to register and that the average burden per response will be 15 minutes (0.25 hours), for a total of 500 burden hours.

It is estimated that 21 State fire inspectors will review an average of 30 responses from hotels and motels, and that the total time per response will be 20 minutes (0.3333 hours) to review each FF- USFA-FY-21-112 (formerly FEMA Form 516-0-1) for a total of 209.98 burden hours (rounded up to 210 burden hours).

2. 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.

Please see our response for 12a above and 12c below.

3. Provide an estimate of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. NOTE: The wage-rate category for each respondent must be multiplied by 1.45 (1.61 for State and local government employees)² and this total should be entered in the cell for “Avg. Hourly Wage Rate.” The cost to the respondents of contracting out to paying outside parties for information collection activities should not be included here. Instead this cost should be included in Item 13.

Estimated Annualized Burden Hours and Costs
Type of Respondent	Form Name / Form No.	No. of Respondents	No. of Responses per Respondent	Total No. of Responses	Avg. Burden per Response (in hours)	Total Annual Burden (in Hours)	Avg. Hourly Wage Rate	Total Annual Respondent Cost
Business or other For- Profit	Federal Hotel and Motel Fire Safety Declaration Form / FEMA Form FF-USFA-FY-21-112 (formerly 516-0-1)	2,000	1	2,000	0.2500	500	$53.53	$26,765
State, Local, or Tribal Government	Federal Hotel and Motel Fire Safety Declaration Form / FEMA Form FF-USFA-FY-21-112 (formerly 516-0-1) (Review)	21	30	630	0.3333	210	$63.87	$13,413
Total		2,021		2,630		710		$40,178

Note: The “Avg. Hourly Wage Rate” for each respondent include a wage multiplier to reflect a fully-loaded wage rate.

“Type of Respondent should be entered exactly as chosen in Question 3 of the OMB Form 83-I.

Instruction for Wage-rate category multiplier: Take each non-loaded “Avg. Hourly Wage Rate” from the BLS website table and multiply that number by 1.45. For example, a non- loaded BLS table wage rate of $42.51 would be multiplied by 1.45, and the entry for the “Avg. Hourly Wage Rate” would be $61.64.

According to the U.S. Department of Labor, Bureau of Labor Statistics³, the May 2023 Occupational Employment and Wage Estimates wage rate for Lodging Managers (SOC Code 11- 9081) is $36.92. Including the wage rate multiplier of 1.45, the fully-loaded wage rate is $53.53 per hour. Therefore, the annual burden hour cost is estimated to be $26,765 annually ($53.53 x 500 hours = $26,765).

The wage rate for Fire Inspectors and Investigators (SOC Code 33-2021) is $39.67. Including the wage rate multiplier of 1.61, the fully-loaded wage rate is $63.87 per hour. Therefore, the annual burden hour cost is estimated to be $13,413 annually ($63.87 x 210 hours = $13,413 (rounded up)).

The total estimated burden hour cost to respondents is estimated to be $40,178 annually.

13. Provide an estimate of the total annual cost burden to respondents or recordkeepers resulting from the collection of information. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. (Do not include the cost of any hour burden shown in Items 12 and 14.)

Annual Cost Burden to Respondents or Recordkeepers
Data Collection Activity/Instrument	*Annual Capital Start- Up Cost (investments in overhead, equipment, and other one-time expenditures	*Annual Operations and Maintenance Costs (such as recordkeeping, technical/professional services, etc.)	Annual Non-Labor Cost (expenditures on training, travel, and other resources)	Total Annual Cost to Respondents
N/A
Total	$0	$0	$0	$0

The cost estimates should be split into two components:

1. Operation and Maintenance and purchase of services component. These estimates should take into account cost associated with generating, maintaining, and disclosing or providing information. Include descriptions of methods used to estimate major cost factors including systems and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time period over which costs will be incurred.

There are no operation or maintenance costs associated with this information collection.

2. Capital and Start-Up Cost should include, among other items, preparations for collecting information such as purchasing computers and software, monitoring sampling, drilling and testing equipment, and record storge facilities.

There are no capital or start-up costs associated with this information collection.

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 have been incurred without this collection of information. You may also aggregate cost estimates for Items 12, 13, and 14 in a single table.

Annual Cost to the Federal Government
Item	Cost ($)
Contract Costs	$0
Staff Salaries: 1 GS 11, step 5 employee in Washington DC spending approximately 75% of their time annually for data collection. [1 x $95,878 x 0.75 x 1.451 = $104,267]	$104,267
Facilities [cost for renting, overhead, etc. for data collection activity]	$0
Computer Hardware and Software [cost of equipment annual lifecycle]	$0
Equipment Maintenance [cost of annual maintenance/service agreements for equipment]	$0
Travel	$0
Total	$104,267
1 Office of Personnel Management 2025 Pay and Leave Tables for the Washington-Baltimore-Arlington, DC-MD-VA-WV- PA locality. Available at https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2025/DCB.pdf. Accessed January 13, 2025. 2 Wage rate includes a 1.45 multiplier to reflect the fully-loaded wage rate.

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of OMB Form 83-I in a narrative form. Present the itemized changes in hour burden and cost burden according to program changes or adjustments in Table 5. Denote a program increase as a positive number, and a program decrease as a negative number.

A “Program increase” is an additional burden resulting from a Federal Government regulation action or directive (e.g., an increase in sample size or coverage, amount of information, reporting frequency, or expanded use of an existing form). This also includes previously in-use and unapproved information collection discovered during the ICB process, or during the fiscal year, which will be in use during the next fiscal year.

A “Program decrease” is a reduction in burden because of: (1) the discontinuation of an information collection, or (2) a change in an existing information collection by a Federal Agency (e.g., the use of sampling (or smaller samples), a decrease in the amount of information requested (fewer questions), or a decrease in reporting frequency).

An “Adjustment” denotes a change in burden hours due to factors over which the government has no control, such as population growth, or in factors which do not affect what information the government collects or changes in the methods used to estimate burden or correction of errors in burden estimates.

Itemized Changes in Annual Burden Hours
Data Collection Activity/Instrument	Program Change (hours currently on OMB inventory)	Program Change (new)	Difference	Adjustment (hours currently on OMB inventory)	Adjustment (new)	Difference
Federal Hotel and Motel Fire Safety Declaration Form / FEMA Form FF-USFA-FY-21-112 (formerly 516-0-1)	0	0	0	628	500	-128
Federal Hotel and Motel Fire Safety Declaration Form / FEMA Form FF-USFA-FY-21-112 (formerly 516-0-1) (Review)				208	210	2
Total	0	0	0	836	710	-126

Explain: The burden hours have decreased based on the reduced estimated number of respondents and responses mitigated by a slight increase in the average time per response for State review from 0.33 burden hours to 0.3333 burden hours. The current annual hour burden is 836 hours, the new hours burden is 710 for a decrease of 126 annual burden hours.

Itemized Changes in Annual Cost Burden
Data Collection Activity/Instrument	Program Change (cost currently on OMB inventory)	Program Change (new)	Difference	Adjustment (cost currently on OMB inventory)	Adjustment (new)	Difference
Federal Hotel and Motel Fire Safety Declaration Form / FEMA Form FF-USFA-FY-21-112 (formerly 516-0-1)				$28,574	$26,765	-$1,809
Federal Hotel and Motel Fire Safety Declaration Form / FEMA Form FF-USFA-FY-21-112 (formerly 516-0-1) (Review)				$10,290	$13,413	$3,123
Total	$0	$0	$0	$38,864	$40,178	$1,314

Explain: The annual cost burden for this collection is reduced by the reduction of 126 burden hours, mitigated by the increase in wage rates for an overall net increase of $1,314.

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.

There are no outline plans for tabulation and publication of data for this information collection.

17. If seeking approval no to display the expiration date for OMB approval of the information collection, explain reasons that display would be inappropriate.

This collection does not seek approval to not display the expiration date for OMB approval.

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

This collection does not seek exception to Certification for Paperwork Reduction Act submissions.

1 The USFA is a Directorate under the Federal Emergency Management Agency (FEMA) and the Department of Homeland Security (DHS).

2 Bureau of Labor Statistics, Employer Costs for Employee Compensation, Table 1. Available at https://www.bls.gov/news.release/archives/ecec_03132024.pdf. Accessed March 13, 2024. The national wage multiplier is calculated by dividing total compensation for all workers of $45.42 by wages and salaries for all workers of $31.29 per hour yielding a benefits multiplier of approximately 1.45. For State and local government employees the wage multiplier is calculated by dividing total compensation for State and local government workers of $60.56 by Wages and salaries for State and local government workers of $37.53 per hour yielding a benefits multiplier of approximately 1.61.

3 Information on the mean wage rate from the U.S. Department of Labor, Bureau of Labor Statistics is available online at: https://www.bls.gov/oes/2023/may/oes_nat.htm.

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