**SUPPORTING STATEMENT**

A.  **Justification:**

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1.  **Explain the circumstances that make the collection of information
    necessary. Identify any legal or administrative requirements that
    necessitate the collections. Attach a copy of the appropriate
    section of each statute and of each regulation mandating or
    authorizing the collection of information.**

> The purpose of this information collection is to reinstate Information
> Collection approval for the Native American Career and Technical
> Education (NACTEP). The NACTEP program was originally approved under
> OMB Control Number 1830-0542.
>
> The Perkins Act expired on October 1, 2003. Given the recently
> authorized Perkins IV, the OVAE is planning to conduct a grant
> competition in the spring of 2007.
>
> The Carl D. Perkins Career and Technical Education Improvement Act of
> 2006 (Act) (PL 109-270) (20 U.S.C.2301, et seq.), was signed into law
> on August 12, 2006. Section 116 (a) -- (g) of Perkins authorized the
> Native American Career and Technical Education Program.
>
> In the Act, Congress has expanded and added elements to the statement
> of purpose, most significantly by stating that, among other statutory
> purposes, programs should build on the efforts of States and
> localities to develop challenging academic and technical standards,
> and to assist students in meeting such standards, including student
> academic achievement standards, especially in preparation for the high
> skill, high wage, or high demand occupations in emerging or
> established professions. (20 U.S.C. 2301 (1)) Congress has added to
> the statement of purpose the requirement that programs should provide
> technical assistance that promotes leadership, initial preparation,
> and professional development, improve the quality of career and
> technical education teachers, faculty, principals, administrators, and
> counselors. (20 U.S.C. 2302 (5)) Additionally, the Act's purpose
> section has been amended to include supporting partnerships among
> schools, postsecondary institutions, baccalaureate degree granting
> institutions, area career technical centers, local workforce
> investment boards, business and industry, professional associations,
> and intermediaries, as well as providing career and technical
> education students with opportunities throughout their lives, in
> conjunction with other education and training programs, to attain the
> knowledge and skills needed in this competitive National economy. (20
> U.S.C. 2301 (6) and (7))
>
> The collection of this information is necessary to (1) make new awards
> with FY 2006/2007 funds and (2) manage and monitor future NACTEP
> grantees.

-   The Office of Vocational and Adult Education (OVAE) is requesting
    the reinstatement of the OMB clearance under collection number
    1830-0542 for the following Native American Career and Technical
    Education Program (NACTEP) documents and program requirements:

(a) Selection Criteria

(b) Budget Instructions for NACTEP (including budget form and budget
    narrative)

(c) Program Narrative

(d) Guidelines for the Appeals Process

-   The Office of Vocational and Adult Education is also requesting OMB
    clearance under collection number 1830-0542 for the following Native
    American Career and Technical Education Program (NACTEP) program
    requirements.

(a) Performance/Statistical Reports

(b) Evaluation Reports

(c) Government Performance Results Act (GPRA) Submissions

> 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 collection is seeking to reinstate specific
> components of the currently approved information collection under OMB
> Control Number 1830-0542. The original collection was for a Notice
> Inviting Applications to award discretionary grants under Perkins III
> of 1998. Due to the reauthorization of Perkins IV, OVAE will conduct a
> new grant competition in the spring of 2007 for the NACTEP.
>
> The data collected on the application form will be used in various
> ways leading to the award of a grant. First, enough information must
> be available to determine the eligibility of the applicant and to
> determine whether the project proposed can be funded under the
> provisions of the appropriate statutes or regulations. Second, field
> reviewers use the information provided to rate the applications
> against published technical review
>
> The NACTEP will expend FY 2006/2007 funds to award new grants. In
> order to evaluate performance, program staff will need to collect
> proposed goals and objectives, narratives, budget information,
> performance/statistical reports, evaluation reports and GPRA
> submissions.
>
> The data collected from the program requirements must relate to the
> goals and objectives that will be included in the approved project
> application. NACTEP program staff will scrutinize grantees' budgets
> and reports to ensure that the grantees meet program objectives.

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.**

> NACTEP applicants may submit applications electronically, via
> Grants.Gov, and OVAE estimates that approximately twenty-five percent
> of applicants will submit their applications, electronically.

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 requested does not exist elsewhere.

5.  **If the collection information impacts small businesses or other
    small entities (Item 5 of 014B Form 83-1), describe any methods used
    to minimize burden.**

    Respondents are not small businesses.

6.  **Describe the consequence of 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.**

> The frequency of collection is key to the appropriation cycle. If the
> collection were conducted less frequently, eligible recipients would
> not be able to receive Federal funds to support Career and Technical
> Education programs.

7.  **Explain any special circumstance that would cause an information
    collection to be conducted in a manner.**

> No such circumstances exist.

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.**

> A 30-day Federal Register Notice will be published allowing for the
> public to comment on this collection.

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

> The respondents will not be receiving a payment nor a gift for
> completing the information collection. The information collection is
> required as part of receiving additional funding.

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

> Confidentiality concerns are handled in accordance with the Privacy
> Act and the Freedom of Information Act. No other pledges of
> confidentiality are made.

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.

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 make special surveys
    to obtain information on which to base burden estimates.
    Consultation with a sample of potential respondents is desirable. If
    the burden on respondents is expected to vary widely because of
    differences in activity, size, or complexity, show the range of
    estimated burden and explain the reason for the variance. Generally,
    estimates should not include burden hours for customary and usual
    business practices.**

> We estimate that the Department will receive approximately 80 new
> applications for
>
> awards under the Native American Career and Technical Education
> Program
>
> (NACTEP). Additionally, it is estimated that the applicants will spend
> 120 hours
>
> developing their grant applications, and the total respondent burden
> will be
>
> 9,600 hours. Based on the average preparation time of 120 hours per
> response, it is
>
> estimated that 100 hours would be used for review, research, gathering
> information,
>
> etc. The remaining 20 hours would be used for typing, xeroxing, and
> submission.
>
> Once the five-year grants are awarded, the burden hours will be
> significantly reduced,
>
> because grantees will only need to submit narrative goals and
> objectives, budget
>
> information, performance data, GPRA, and evaluation reports. As a
> result, the
>
> amount of time for grantees and program staff will be significantly
> decreased.

+------------+------------+--------------+-------------+--------------+
| **[Program | **         | **[Type of   | *           | **[Total     |
| Year]{.un  | [Estimated | Staff]{.     | *[Estimated | Estimated    |
| derline}** | Number of  | underline}** | Number of   | Number of    |
|            | Resp       |              | Burden      | Burden       |
|            | onses]{.un |              | Hours Per   | Hours]{.     |
|            | derline}** |              | R           | underline}** |
|            |            |              | esponse]{.u |              |
|            |            |              | nderline}** |              |
+------------+------------+--------------+-------------+--------------+
| 2007-2008  | 80         | Professional | 100         | 8,000        |
|            |            |              |             |              |
|            |            | Clerical     | 20          | 1,600        |
|            |            |              |             |              |
|            |            | TOTAL        | 120         | 9,600        |
+------------+------------+--------------+-------------+--------------+
| 2008-2009  | 30         | Professional | 30          | 900          |
|            |            |              |             |              |
|            |            | Clerical     | 20          | 600          |
|            |            |              |             |              |
|            |            | TOTAL        | 50          | 1,500        |
+------------+------------+--------------+-------------+--------------+
| 2009-2010  | 30         | Professional | 30          | 900          |
|            |            |              |             |              |
|            |            | Clerical     | 20          | 600          |
|            |            |              |             |              |
|            |            | TOTAL        | 50          | 1,500        |
+------------+------------+--------------+-------------+--------------+
| **TOTAL**  | **140**    |              | **220**     | **12,600**   |
+------------+------------+--------------+-------------+--------------+
| **ANNUAL** | **47**     |              | **73**      | **4,200**    |
|            |            |              |             |              |
| *          |            |              |             |              |
| *AVERAGE** |            |              |             |              |
+------------+------------+--------------+-------------+--------------+

-   **If the request for approval is for more than one form, provide
    separate burden estimates for each form and aggregate the hour
    burdens in Item 13 of OMB Form 83-1.**

> The request for approval is for one form.

-   **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 estimated cost to respondents to develop applications, in response
to the Notice

Inviting Applications, is approximately \$219,200 based upon an average
hourly rate

of \$25.00 per professional and \$12.00 per clerical. Based on the
average preparation

time of 120 hours per response, it is estimated that 100 hours would be
used for review,

research, gathering information, etc. The remaining 20 hours would be
used for typing,

formatting, and copying.

The estimated cost to respondents, to submit semi-annual and annual
performance

reports, is approximately \$29,700 based upon an average hourly rate of
\$25.00 per

professional and \$12.00 per clerical. Based on the average preparation
time of 50 hours

per response, it is estimated that 30 hours would be used for review,
research, gathering

information, etc. The remaining 20 hours would be used for typing,
formatting, copying,

and submitting the performance reports through the Department's
e-Reports system.

13. **Annual Costs to Respondents (capital/start-up & operation and
    maintenance).**

> The total for the capital and start-up cost components for this
> information collection is zero. The information collection will not
> require the purchase of any capital equipment nor create any start-up
> costs. Computers and software used to complete this information
> collection are part of the respondents\' customary and usual business
> or private practices, and therefore is not included in this estimate.
>
> The total operation and maintenance and purchase of service components
> for this information is zero. The information collection will not
> create costs associated with generating, maintaining, and disclosing
> or providing the information that is not already identified in
> question 12 of this supporting statement.

14. **Provide estimates of annualized cost to the Federal government.**

> The Federal costs are estimated to be approximately \$146,067. This
> includes the salaries and expenses of program staff that manage the
> grants and other Department staff to support the grant competitions.
> The method used to estimate the cost is as follows:
>
> Program Office Staff
>
> 2 GS-12 X 46 weeks = \$49,067

TOTAL = \$49,067

Other Department Staff = \$ 7,000

Outside Review Cost = \$90,000

TOTAL ESTIMATED FEDERAL COST = \$146,067

15. **Explain the reasons for any program changes or adjustments
    reported in Items 13 or 14 of the OMB Form 83-I.**

> Per the instructions for completing OMB Form 83-i, given the passage
> of reauthorized federal legislation, this is considered a
> reinstatement of a previously approved collection. Consequently, the
> entire 9,600 hours will be considered new burden and recorded as a
> program change.
>
> The extension and clearance of 1830-0542 will allow for the
> development and submission of new applications, holding a peer review,
> conducting clarification activities for the and Native American Career
> and Technical Education Program, as well as the appeals process for
> the NACTEP. The current OMB inventory is \$0. We estimate the cost to
> respondents to be \$219,200.
>
> Additionally, OVAE is requesting the extension and clearance of
> 1830-0542 to collect semi-annual and annual performance data,
> including GPRA and evaluation reports.

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 information, completion of report, publication dates, and
    other actions.**

> There are no plans for publication of data from this collection.

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.**

> We are not seeking this approval.

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

#  \"Certification for Paperwork Reduction Act Submissions,\" of OMB Form 83-I

> This request is in compliance with 5 CFR 1320.9.

B.  **[Collections of Information Employing Statistical
    Methods]{.underline}:**

> Not applicable