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EDICS Tracking and OMB Number: ( 0493 9 ) 1845 - 009 7 v2 Revised: 09 /2 6 /2012 RIN Number: XXXX - XXXX (if applicable)

**SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSION**  **Student Assistance General Provisions**
**– Annual Fire Safety Report**  **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 collection (new, revision, extension, reinstatement with change, reinstatement without change) . If revised, brie fl y specify the changes. If a rulemaking is involved, make note of the sections or changed sections, if applicable. As provided b y Section 488(g) of the Higher Education Opportunity Act (HEOA) (Pub. L. 110 - 315) , and the Department of Education regulations at 34 CFR 668.49 requir e institutions to collect statistics on fires in on - campus student housing facilities, including the number and cause of each fire, the number of injuries related to each fire that required treatment at a medical facility , the numbe r of deaths related to each fire, and the value of propert y damage caused by each fire. Institutions must also publish an annual fire safet y report containing the institution’s policies regarding fire safet y and the fire statistics information. Further the HEOA requires institutions to maintain a fire log that records the date, time, nature, and general location of each fire in on - campus student housing facilities. This request is for extending approval of reporting requirements contained in the regulat ions related to the administrative requirements of the annual fire safety report . The information collection requirements in the regulations are necessary to prevent fraud and abuse of program and for reporting to Congress . Section 668. 49 (b)

– Annual fire safet y report The regulation s identify

the minimum information that must be included in the annual fire safet y report for institutions that have on - campus housing, beginning on October1, 2010 . Section 668. 49 (c)

– Fire statistic s 1 Please limit pasted text to no longer than 3 paragraphs.2

EDICS Tracking and OMB Number: ( 0493 9 ) 1845 - 009 7 v2 Revised: 09 /2 6 /2012 RIN Number: XXXX - XXXX (if applicable) The regulation s identify

the required stat istics and the time frame that must be reported for the specified data . Section 668.49(d)

– Fire log The regulations specify

the information that must be included in the fire log, how it must be maintained and provid es for its accessibility to the public. 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. Und er the final regulations, institutions that maintain on - campus housing are required to gather and distribute the required fire safet y information to both inform current and prospective students and employ ees of incidences meeting the fire reporting require ments. This can be achieved through appropriate publications mailed or directl y provided or posted to the Internet or an Intranet web site. This annual fire safet y reporting information will inform the campus community and be provided to the Secretary to be disseminated to the public as well as being reported to Congress. 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 i nformation technology , e.g. permitting electronic 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. The institution may

provide this information to the general public via an Internet or Intranet web site. The Secretary must make this information available to the general public as well as providing an annual report to Congress . 4. Describe efforts to identify duplication. Show specif icall 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. There is no duplication of data as a result of the collection of this information. 5. If the collection of information impacts small businesses or other small entities, describe an y 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 independently owned and operated and is not dominant in its field; or (3) a small government jurisdiction, which is a government of a city , count y, town, township, school district, or s pecial district with a population of less than 50,000. No small businesses are impacted b y this collection.3

EDICS Tracking and OMB Number: ( 0493 9 ) 1845 - 009 7 v2 Revised: 09 /2 6 /2012 RIN Number: XXXX - XXXX (if applicable) 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. Per statute, the information must be collected annually . 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 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 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; 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 information collection requirements require no special circumstances. 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 av ailability

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 those 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 ci rcumstances that may preclude consultation in a specific situation. These circumstances should be explained.4

EDICS Tracking and OMB Number: ( 0493 9 ) 1845 - 009 7 v2 Revised: 09 /2 6 /2012 RIN Number: XXXX - XXXX (if applicable) This is the 60 day

comment period request. There has been no change to the regulations since 2009 when these regulations were last reviewed thro ugh negotiated rulemaking. 9. Explain any

decision to provide any

pay ment or gift to respondents, other than remuneration of contractors or grantees with meaningful justification . There are no pay

ments or gifts to respondents. 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 included 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 confidentiality should be provided. 2 If th e collection is subject to the 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 . The Department requirements do not cover an y confidential information. 11. Provide additional justification for an y questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considere d private. The justification should include the reasons wh y 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 an y steps to be t aken to obtain their consent. The Department is not requesting an y s ensitive data. 12. Provide estimates of the hour burden of the collection of information. The statement should:

 Indicate the number of respondents by affected public ty

pe (federal gove rnment, 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 wa s estimated, including identification of burden t ype: recordkeeping, reporting or third party disclosure. All narrative should be included 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 respondents is exp ected to vary widel y because of differences in activity , size, or complexity , show the range of estimated
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

– Guid elines 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

– Safegu arding Personally Identifiable Information, OM : 6 - 104

– Privacy Act of 1974 (Collection, Use and Protection of Personally Identifiable Information)5

EDICS Tracking and OMB Number: ( 0493 9 ) 1845 - 009 7 v2 Revised: 09 /2 6 /2012 RIN Number: XXXX - XXXX (if applicable)

hour burden, and explain the reasons for the variance. Generall y, estimates should not include burden hours for customary and usual business practice s.  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 categorie s. 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. We estimate the hours required for institutions with on - campus housing to meet the regulatory

requirements to report this fire safet y information will be approximately 2 hours per institution annually . Affected Entities and Burden : Establishing/maintaining required fire log

– # of # of # of Respondents Responses Burden Hours Institutions: Public 1, 902 1, 902 X .5 hours = 951 hours Private 1, 747 1, 747 X .5 hours = 874 hours SUB TOTAL 3 , 649 3,649 1,825 hours Gathering data for and creating annual fire safet y report

– # of # of # of Respondents Responses Burden Hours Institutions: Public 1,902 1,902 X 1.5 hours = 2,853 hours Private 1, 747 1, 747 X 1.5 hours = 2,621 hours SUB TOTAL 3,649 3,649 5,474 hours TOTAL 3,649 7,298 7,299 hours Current Burden Inventory : # of # of # of Respondents Responses Burden Hours 3,641 7,282 7,283 Revised Burden Inventory : # of # of # of Respondents Responses Burden Hours 8 16 166

EDICS Tracking and OMB Number: ( 0493 9 ) 1845 - 009 7 v2 Revised: 09 /2 6 /2012 RIN Number: XXXX - XXXX (if applicable) 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 p roviding 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 incurr ed. 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 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 in formation collection, as appropriate.  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 inform ation 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 : The Department estimates that the cost to the institutional respondents will be: # of Est. $/ Est. $ of Respondents Hour Burden Institutions: Public 1, 902 X $24.61 X 2 hours = $ 93,616 Private 1, 747 X $24.61 X 2 hours = $ 85,987 TOTAL 3,649 $179,603 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 that7

EDICS Tracking and OMB Number: ( 0493 9 ) 1845 - 009 7 v2 Revised: 09 /2 6 /2012 RIN Number: XXXX - XXXX (if applicable) 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. There is no new sy stem start - up costs associated with these proposed regulations. 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 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 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) . This request is to extend the current information collection. There has been no revision to the regulations regarding the specific fire safet y reports . The change to the burden hours is due to the minimal increase in the number of institutions required to report such information. 16. For collections of information whose results will be published, outline plans for tabu lation 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 oth er actions. This information is required under statute and regulation to be reported to the general public and Congressional committees or subcommittees. 17. If seeking approval to not display the expiration date for OMB approval of the information colle ction, explain the reasons that display would be inappropriate. The Department is not seeking this approval. 18. Explain each exception to the certification statement identified in the Certification of Paperwork Reduction Act. The Department is not requesting an y exceptions to the “Certification for Paperwork Reduction Act Submissions” of OMB Form 83 - 1.