1

OMB Number: 1810-0657 Revised: 4/17/2014

SUPPORTING STATEMENT

FOR PAPERWORK REDUCTION ACT SUBMISSION

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 hard copy of the 

appropriate section of each statute and regulation mandating or authorizing the collection of 

information, or you may provide a valid URL link or paste the applicable section1. Specify the 

review type of the collection (new, revision, extension, reinstatement with change, reinstatement 

without change). If revised, briefly specify the changes. If a rulemaking is involved, make note 

of the sections or changed sections, if applicable.

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 program statute was 

amended and reauthorized on October 30, 2000, by the Impact Aid Reauthorization Act of 2000, 

which was part of the Floyd D. Spence National Defense Authorization Act for Fiscal Year (FY) 

2000 enacted by P.L. 106-398. That reauthorization authorized a new Discretionary Construction 

Grant program under Section 8007(b). Further amendments to Section 8007(b) were enacted as 

part of the ESEA reauthorization in January 2002.

The Impact Aid Discretionary Construction Program provides grants to eligible Impact Aid 

school districts to assist in addressing their school facility emergency and modernization needs. 

The eligible Impact Aid school districts have a limited ability to raise revenues for capital 

improvements because they have large areas of Federal land within their boundaries. As a result, 

these districts find it difficult to respond when their school facilities are in need of emergency

repairs or modernization. This information collection is a renewal of the grant application for this 

program. 

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 Department will use the information collected in the application to determine whether 

applicants meet the basic eligibility requirements of section 8007(b), to determine whether the 

 

1

Please limit pasted text to no longer than 3 paragraphs.
2

OMB Number: 1810-0657 Revised: 4/17/2014

applicant is requesting an emergency or modernization grant, and to determine which of the four 

priorities described in the statute applies to the individual application. Among the criteria the 

Secretary is required to consider are the applicant’s total assessed value of real property that may

be taxed for school purposes, its use of bonding capacity, and the nature and severity of its need 

for funds. In addition, information on the application will be used to rank applications within 

each of the four priorities. The Department has used this information to make grant awards in 

past fiscal years. 

3. Describe whether, and to what extent, the collection of information involves the use of 

automated, 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.

In 2012 the Department of Education developed an electronic application for this grant program, 

which has been in use since that time. The software populates certain data fields for applicants 

that submitted an Impact Aid section 8003 application, and has built-in checks for completion of 

all necessary items. This software reduces the burden on applicants of organizing and entering 

data that were already submitted to the Impact Aid Program, helpings the applicants to determine 

whether their LEAs meet the program’s eligibility requirements, and reduces the number of 

errors in applications.

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.

As noted above, eligibility for this grant program relies partially on data that were already

submitted in previous Impact Aid applications for section 8003. Many of our applicants are 

returners. The Department has developed an electronic application that allows certain data that 

are necessary for this application, but that were already submitted by an Impact Aid applicant, to 

be populated in the application. These data items include the applicant’s identifying information 

and DUNS number, the applicant’s Impact Aid survey date, and the Federal property codes that 

the applicant used on Tables 1 through 5 of the application. This will increase the accuracy of the 

information submitted in the applications and eliminate duplication of effort on the part of the 

applicants. Further, the eligibility requirements for this competitive grant are complex. 

Populating these data for the applicants will assist them in determining whether their LEAs may

be eligible, thus possibly helping certain applicants avoid the burden of completing an 

application that could not be successful.

5. If the collection of information impacts small businesses or other small entities, describe any

methods used to minimize burden. A small entity may be (1) a small business which is deemed 

to be one that is independently owned and operated and that is not dominant in its field of 

operation; (2) a small organization that is any not-for-profit enterprise that is independently
3

OMB Number: 1810-0657 Revised: 4/17/2014

owned and operated and is not dominant in its field; or (3) a small government jurisdiction, 

which is a government of a city, county, town, township, school district, or special district with a 

population of less than 50,000.

The respondents are LEAs and local officials. Small businesses are not impacted by this 

collection of information. Additionally, small entities, to include small school districts, are less 

burdened due to the automated collection system, which is described in the answer to question 4. 

This collection system decreases the burden of these LEAs by limiting the information they need 

to provide the Department. 

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. The Department would not be able to award 

these funds without the application to collect the required information.

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 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
4

OMB Number: 1810-0657 Revised: 4/17/2014

 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.

This application is consistent with all of the guidelines in 5 CFR 1320.5.

8. As applicable, state that the Department has published the 60 and 30 Federal Register notices 

as 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.

In accordance with 5 CFR 1320.8(d) a 30-day Federal Register Notice will be published 

providing the public opportunity to comment on the Impact Aid Discretionary program specific 

application forms.

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

of contractors or grantees with meaningful justification.

No gifts or payments will be made to respondents other than the funds awarded under the statute.

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

assurance in statute, regulation, or agency policy. If personally identifiable information (PII) is 

being collected, a Privacy Act statement should be included on the instrument. Please provide a 

citation for the Systems of Record Notice and the date a Privacy Impact Assessment was 

completed as indicated on the IC Data Form. A confidentiality statement with a legal citation that 

authorizes the pledge of confidentiality should be provided.2If the collection is subject to the 

 

2

Requests for this information are in accordance with the following ED and OMB policies: Privacy Act of 1974, 

OMB Circular A-108 – Privacy Act Implementation – Guidelines and Responsibilities, OMB Circular A-130 

Appendix I – Federal Agency Responsibilities for Maintaining Records About Individuals, OMB M-03-22 – OMB 

Guidance for Implementing the Privacy Provisions of the E-Government Act of 2002, OMB M-06-15 –

Safeguarding Personally Identifiable Information, OM:6-104 – Privacy Act of 1974 (Collection, Use and Protection 

of Personally Identifiable Information)
5

OMB Number: 1810-0657 Revised: 4/17/2014

Privacy Act, the Privacy Act statement is deemed sufficient with respect to confidentiality. If 

there is no expectation of confidentiality, simply state that the Department makes no pledge 

about the confidentially of the data.

There is no assurance of confidentiality provided to the respondents concerning these collections 

of information.

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.

There are no questions of a sensitive nature in these collections of information.

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

 Indicate the number of respondents by affected public type (federal government, 

individuals or households, private sector – businesses or other for-profit, private 

sector – not-for-profit institutions, farms, state, local or tribal governments), 

frequency of response, annual hour burden, and an explanation of how the burden was 

estimated, including identification of burden type: recordkeeping, reporting or third 

party disclosure. All narrative should be included in item 12. 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 the ROCIS IC Burden 

Analysis Table. (The table should at minimum include Respondent types, IC activity, 

Respondent and Responses, Hours/Response, and Total Hours)

 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.

Based on applications previously received, Impact Aid requests to maintain the previously

approved OMB inventory burden of 1080 total burden hours. 
6

OMB Number: 1810-0657 Revised: 4/17/2014

Cost estimates of the hour burden of the collection requirements. 

Burden data estimates 

Collection Number of

Respondents Frequency Number of Responses

Average

Hours Total

Section 8007(b) application 180 1 180 5.25 945 

Health/Safety Emergency Certification 

Letter 180 1 180 .75 135 

TOTAL 360 1 360 3 1,080 

The annual number of responses for this collection totals 180. The average number of 

hours/response is 4.5hours, a total of 1,080 annual burden hours. 

Burden cost of collections: At an average cost of $25 per hour, the cost per response is estimated 

to be: 

-- Section 8007(b) application $ 131.25 

-- Health/Safety Emergency Certification Letter $ 18.75 

________ 

Total $ 150.00

The total annualized cost for this collection is $27,000.00.

*(180 applications x $150/application = 27,000.00)

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 acquiring and maintaining 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 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.
7

OMB Number: 1810-0657 Revised: 4/17/2014

 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. Also, these estimates should not include the hourly 

costs (i.e., the monetization of the hours) captured above in Item 12

Total Annualized Capital/Startup Cost : 

Total Annual Costs (O&M) : 

____________________

Total Annualized Costs Requested : 

There are no start-up costs for this 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 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.

Analysis and processing (5 hrs./app. x $32.09 hr. x 150 apps.) 24,067.50

Peer Review: 12 reviewers x $1,500 (travel and stipend) 18,000.00

TOTAL 42,067.50 

15. Explain the reasons for any program changes or adjustments. Generally, adjustments in 

burden result from re-estimating burden and/or from economic phenomenon outside of an 

agency’s control (e.g., correcting a burden estimate or an organic increase in the size of the 

reporting universe). Program changes result from a deliberate action that materially changes a 

collection of information and generally are result of new statute or an agency action (e.g., 

changing a form, revising regulations, redefining the respondent universe, etc.). Burden changes 

should be disaggregated by type of change (i.e., adjustment, program change due to new statute, 

and/or program change due to agency discretion), type of collection (new, revision, extension, 

reinstatement with change, reinstatement without change) and include totals for changes in 

burden hours, responses and costs (if applicable).

No changes or adjustments. 

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 information collected will not be published.
8

OMB Number: 1810-0657 Revised: 4/17/2014

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 expiration date will be displayed on the applications.

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

Paperwork Reduction Act.

There are no exceptions to the certification statement.