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SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

OMB No. 1810-0687

Impact Aid Program – Application for Section 8003 Assistance

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 U.S. Department of Education is requesting approval for the Application for Assistance under 

Section 8003 of Title VIII of the Elementary and Secondary Education Act (ESEA) as amended by No Child 

Left Behind (NCLB). This application is for a grant program otherwise known as Impact Aid Basic Support 

Payments. Local Educational Agencies (LEAs) whose enrollments and revenues are adversely impacted

by Federal activities use this form to request financial assistance. Regulations for the Impact Aid 

Program are found at 34 CFR 222.

The statute and regulations for this program require a variety of data from applicants annually to 

determine eligibility for the grants and the amount of grant payment under the statutory formula. The 

least burdensome method of collecting this required information is for each applicant to submit these 

data through a web-based electronic application hosted on the Department of Education’s G5 website. 

This application was previously approved under OMB 1810-0687. There are no substantive changes to 

this application. The Department of Education is requesting renewal of its three-year clearance under 

the same collection number.

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.

The Impact Aid Program, authorized by Title VIII of the Elementary and Secondary Education Act (ESEA), 

provides financial assistance to local educational agencies (LEAs) whose enrollment or revenues are 

adversely affected by Federal activities. 

The statute and implementing regulations (34 CFR Part 222) require information from applicants 

annually to determine eligibility for and the amount of payments. The least burdensome method of 

collecting this required information is for each applicant to submit it as part of its annual Impact Aid 

application, previously approved under OMB 1810-0687. 

ED is now requesting renewal of its three-year clearance under this regular collection. There are no 

substantive changes to this previously-approved collection. 

3. Describe whether, and to what extent, the collection of information involves the use of automated, 
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electronic, mechanical, or other technological collection techniques or forms of information 

technology, e.g. permitting electronic submission of responses, and the basis for the decision of 

adopting this means of collection. Also describe any consideration given to using technology to 

reduce burden.

Impact Aid Program Section 8003 applications are prepared and submitted through an electronic 

application system. E-application offers recurring LEA applicants significant advantages in preparing the 

application because it pre-populates the e-application with much of the LEA’s identifying information 

and Federal property codes. The e-application automatically checks for completion of all necessary 

items and includes arithmetic checks for table subtotals and the application total. This software reduces 

the number of errors in applications submitted to ED. 

The e-application is used only by LEAs to submit their Section 8003 applications, not by the respondents 

to the LEAs. As a result, the percentage of responses collected electronically is less than one percent.

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 under these collections is not duplicated in any other data collection, is 

unique to this program and the particular applicants, and is intended to serve specific purposes 

mandated by the statute.

5. If the collection of information impacts small businesses or other small entities (Item 8b of IC Data 

Part 2), describe any methods used to minimize burden.

Small businesses are not impacted by this data collection.

6. Describe the consequences 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.

The statute requires applicants to apply for funds annually and authorizes the payment of funds based 

upon those annual applications. Without the annual information, the Department would not be able to 

disburse these funds efficiently and accurately. In addition, some information collected through the 

application is used to monitor that recipient LEAs are meeting statutory requirements.

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;
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 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 than 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 that unnecessarily impedes sharing of data with other 

agencies for compatible confidential use; or

 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.

The regulations do not require the information collection to be conducted in a manner inconsistent with 

the requirements of 5 CFR 1320.5.

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 instruction and record keeping, 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.

The Impact Aid Program Director regularly consults formally and informally with applicant LEAs, as well 

as with the leaders of the National Association for Federally Impacted Schools (NAFIS), the National 

Council of Impacted Schools (NCIS), the National Indian Impacted Schools Association, and the Military 

Impacted Schools Association. These consultations have yielded insight into the difficulties that school 

officials may have in completing the applications. The Department attempts to mitigate these problems 

whenever possible. 

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

The information collection does not require gifts or payments to be made to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance 

in statute, regulation, or agency policy.

The information collection requires no assurance of confidentiality.

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. The 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.

The information collection does not include any 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 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 16 of IC Data Part 1.

Provide estimates of annualized cost to respondents of 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.

As presented in greater detail below, we estimate that it will require 12.41hours per LEA applicant to 

collect, organize and prepare the application for Impact Aid Section 8003 assistance. This include the 

burden hours for approximately half of the LEAs that contact a local Federal official to collect residence 

information related to the collection of source check data. Additionally, we estimate approximately 15 

 

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There is a total of 15,666 burden hours for the LEA. There are 1,264 applicants in the FY 2014 

application cycle. The average is calculated by dividing the total LEA burden hours by the number of 

applicants (15,666 total LEA hours ÷ 1,264 LEAs = 12.4). 
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minutes per parent respondent to fill out the survey required by the LEA to complete the application2. 

These estimates were developed by program staff with prior experience in the administration of the 

Impact Aid Program. The summary tables contain a fuller explanation of the calculations. 

Annual Burden Hours 

By regulatory section or subsection Total Annual Burden Hours

34 CFR 222.35, 34 CFR 222.50-52

Tables 1-5

 139,140

34 CFR 222.37, Table 6 1,264

34 CFR 222.53 Table 7 217

34 CFR 222.141-143 Table 8 5

Table 10 40

Housing Official Certification Form 3

TOTAL 140,669

Annual Task: Counting and Reporting Numbers of Federally-Connected Children on Tables 1-5

Data Collection Task Respondents Average Hours 

per Respondent

Total 

Hours

Explanation

Parent-pupil survey 500,000 

parents

0.25 125,000 Assumes 500,000 federallyconnected children 

identified through a survey 

form completed by a 

parent

Source check with 

Federal official to 

document children 

living on Federal 

property

500 LEAs 3 1,500 Assumes 500 officials with 

information on the 

residence status of 

federally-connected 

children complete a source 

check

Collecting and 

organizing data to 

report on Tables 1-5

1,264 LEAs 10 12,640 Assumes time to complete 

and organize survey/source 

check data on federallyconnected children 

averages ten hours

Total 139,140

 

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An estimated 500,000 parents complete the parent-pupil survey form. 500,000 *.25= 125,000 

parental burden hours.
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Additional LEA Annual Reporting Tasks – Tables 6-10 and Supplemental Forms

Task Respondents3 Average Hours 

per Respondent

Total 

Hours

Explanation

Reporting enrollment 

and attendance data 

on Table 6

1,264 LEAs 1 1,264 Assumes each applicant 

uses data already collected 

and reported to its state 

education agency

Collecting and 

reporting 

expenditure data for 

federally-connected 

children with 

disabilities on Table 7

896 LEAs .25 224 The burden hours in the 

previous collection were 

duplicated here and on 

Tables 1-5. The removal of 

the duplication reduces the 

total burden hours by 

1,569.

Reporting children 

educated in federallyowned school 

buildings on Table 8

5 LEAs 1 5 Assumes applicants 

maintain data on children 

housed in the small 

number of schools owned 

by ED but operated by LEAs

Reporting 

expenditures of 

Section 8007 funds 

on Table 10

159 LEAs 0.25 40 Assumes these applicants 

have ready access to 

financial reports to retrieve 

and report these data

Indian Policies and 

Procedures (IPPs)

625 0 0 The LEA does not have to 

collect any new 

information to meet this 

requirement, so the time 

associated with this form is 

too small to calculate (<5 

minutes per applicant)

Contact Form for 

Housing Undergoing 

Renovation or 

Rebuilding

34 0 0 The LEA does not have to 

collect any new 

information to meet this 

requirement, so the time 

associated with this form is 

too small to calculate (<5 

minutes per applicant)

Housing Official 

Certification Form

20 Non-Federal 

Housing 

Officials

.50 10 Amount of time for the 

housing official to estimate 

the number of school-age 

children that would have 

resided in the housing had 

it not been unavailable due 

to renovation or rebuilding

 

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FY 2014 application cycle.
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Estimates of annualized cost to respondents: 

Parent Respondents

Estimating respondent cost at an average of $10/hour for parents completing the survey forms would 

be:

 $10/hour x 500,000 parents x 0.25 hours = $1,250,000 per year

LEA Respondents

Estimating respondent costs at an average of $12/hour for school staff collecting the survey forms,

populating source check forms, organizing the data, and completing the application:

 $12/hour x 15,666 hours = $187,992 per year

Annual Total Costs

Total estimated annual cost to the public of this collection is $ 1,443,992.

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 only costs to respondents are those shown above for staff time for data collection and reporting. 

There should be no record-keeping costs beyond those covered under customary and usual business 

practices. 

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.

Federal costs associated with this collection of information are generally those normally associated with 

Department staff conducting program monitoring. 

Application Receipt and Logging

Signed Assurances 

Received

Hours per 

Application

Total Staff Hours Wage Rate for 

Personnel4

Total Receipt and 

Logging Cost

1,264 0.25 hours 316 $35.88 $ 11,338

Application Review

 

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2013 Pay rate for a GS-12/1 = $35.88
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Applications Time in 

Property Review 

per Application

Total 

Hours

Wage Rate for 

Personnel5

Total 

Personnel 

Cost

Other

Costs

Total Cost of 

Review

1,264 4 hours 5,056 $46.64 $ 235,811 0 $235,811

Applications Time in 

Application 

Review 

per Application

Total 

Hours

Wage Rate for 

Personnel

Total 

Personnel 

Cost

Other

Costs

Total Cost of 

Review

1,264 24 hours 30,336 $46.64 $ 1,414,871 0 $1,414,871

Total $ 1,662,020

15. Explain the reasons for any program changes or adjustments to #16f of the IC Data Part 1 Form.

By using the actual numbers of respondents for each part of the application, rather than an estimate, we 

were able to be more precise about the total time required. There was a duplication of hours for Tables 

1 & 2 in the prior collection, which when removed, reduces the number of burden hours. Finally, the 

legislative change to the previous Tables 9 & 11 also reduced the burden hours for this information 

collection tool. Previously, each LEA had to report the individual address, the number of school-age

children, and the date the unit was vacated for renovation or rebuilding. The number of units reported 

annually totaled more than 5,000 for approximately 40 LEAs. A technical amendment passed as part of 

the National Defense Authorization Act of 2013, significantly simplified the process by requiring the 

housing official to provide only the aggregate number of school-age children that would have resided in 

the units had they not been undergoing renovation or rebuilding and the date the construction project

began. This change completely eliminated any burden associated with Tables 9 & 11. 

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 collection of information does not require publication of the information or use of complex 

analytical techniques.

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.

The OMB approval number will be displayed on the forms.

18. Explain each exception to the certification statement identified in the Certification of Paperwork 

 

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2013 Pay rate for a GS-12/10 = $46.64
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Reduction Act.

There are no proposed exceptions to the certifications.