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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 cop y 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 section 1
. Specify the review t ype of the collectio n (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, briefl y 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 adversel y affected b y Federal activities. The program statute was amended and reauthoriz ed 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 b y P.L. 106 - 398. That reauthorization authorized a new Discretionary Construct ion 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 a ssist 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. A s 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 f

or 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
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OMB Number: 1810 - 0657 Revised: 4/17/2014 applicant is requesting an emergency or modernization grant, and to de termine 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, i ts use of bonding capacity , and the nature and severit y 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 i n 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 electron ic submission of responses, and the basis for the decision of adopting this means of collection. Also describe an y 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 populate s certain data fields for applicants that submitted an Impact Aid section 8003 application, and ha s built - in checks for completion of all necessary

items. This software reduce s the burden on applicants of organizing and entering data that were alread y submitted to the Impact Aid Program, h elp ings the applicants to determine whether their LEAs meet the program’s eligibility requirements, and reduce s the number of errors in applicatio ns. 4. Describe efforts to identify duplication. Show specificall y wh y an y similar information alread y 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 p artially on data that were already submitted in previous Im pact Aid applications for section 8003. Man y of our applicants are returners. The Department has developed an electronic application that allow s certain data that are necessary

for this application , but that were alread y 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 propert y 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 entit y 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 independently3

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 , co unt y, 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 b y this collection of information. Additionally , small entities, to include s mall school districts, are less burdened due to the automated collection s ys tem, which is described in the answer to question 4. This collection sy stem decreases the burden of these L EAs 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 frequentl y, as well as an y 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 quarterl y;
 requiring respondents to prepare a written response to a collection of information in fewer than 30 day s 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 y ears;
 in connection with a statistical survey , that is not designed to produce valid and reliabl e 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 b y 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 unnecessaril y i mpedes sharing of data with other agencies for compatible confidential use; or4

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

 requiring respondents to subm it 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 b y 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 b y 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 an y), and on the data elements to be recorded, disclosed, or reported. Consultation with representatives of thos e from whom information is to be obtained or those who must compile records should occur at least once every 3 y ears – even if the collection of information activity

is the same as in prior periods. There may be circumstances that may preclude consultatio n 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

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification . No gifts or pay

ments will be made to respondents other than the funds awarded under the statute. 10. Describe an y 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 in cluded on the instrument. Please provide a citation for the Sy stems of Record Notice and the date a Privacy I mpact Assessment was completed as indicated on the I C Data Form . A confidentiality statement with a legal citation that authorizes the pledge of co nfidentiality should be provided. 2 If 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 Maint aining 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 Protec tion 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 . I f there is no expectation of confidentiality , simply state that the Department make s no pledge about the confidentiall y of the data. There is no assurance of confidentiality provided to the respondents concerning these collections of information. 11. Provide additional justification for an y questions of a sensitive nature, such as sexu al behavior and attitudes, religious beliefs, and other matters that are commonly considered private. The justification should include the reasons wh y t he 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 an y 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 col lection of information. The statement should:

 Indicate the number of respondents by affected public ty

pe (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 t ype: recordkeeping, reporting or third party disclosure. All narrative should be inclu ded in item 12. Unless directed to do so, agencies should not conduct special survey s 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 re spondents is expected to vary widel y because of differences in activity , size, or complexity , show the range of estimated hour burden, and explain the reasons for the variance. Generall y, estimates should not include burden hours for customary and usual b usiness 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 ROCI S IC Burden Analy sis 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 categor ies. 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 c omponents: (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, m aintaining, and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including s ys tem 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 maintainin g record storage facilities.

 If cost estimates are expected to vary widel y, 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 anal ys is 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 requireme nts 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 hourl y 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 an y 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 materiall y changes a collection of information and g enerally 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 t ype of change (i.e., adjustment, program change due to new statute, and/or program change due to agency discretion) , ty

pe of collection (new, revision, extension, reinstatement with change, reinstatement without change) and include totals for changes in burden hours , responses and cost s (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 analy

tical 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 approv al of the information collection, explain the reasons that display would be inappropriate. The expiration date will be display ed 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.