Submission of Proposed Information Collection to OMB

Federal RegisterMar 3, 1994

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DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT

Office of Community Planning and Development

[Docket No. N-94-3724]

Submission of Proposed Information Collection to OMB

AGENCY: Office of Community Planning and Development, HUD.

ACTION: Notice; Request for public comments.

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SUMMARY: The proposed information collection requirement for a survey

on the use of Community Development Block Grant (CDBG) funds in

promoting the development of microenterprises, has been submitted to

the Office of Management and Budget (OMB) for review as required by the

Paperwork Reduction Act. This survey is to be used to prepare a report

directed by Congress for HUD to complete in the Housing and Community

Development Act of 1992 (Pub. L. 102-550, section 807(C)(4)).

The Department is soliciting public comments on the subject

proposal for a period of seven (7) days. An expedited comment period is

necessary to permit the collection of information needed for the report

to Congress which is due by the end of April, 1994.

DATES: Comment due date: March 10, 1994.

ADDRESSES: Interested persons are invited to submit comments regarding

this proposal by March 10, 1994. Comments should refer to this proposal

by name and should be sent to: Joseph F. Lackey, Jr., OMB Desk Officer,

Office of Management and Budget, New Executive Office Building,

Washington, DC 20503.

FOR FURTHER INFORMATION CONTACT:

Kay Weaver, Reports Management Officer, Department of Housing and Urban

Development, 451 7th Street, Southwest, Washington, DC 20410.

Telephone: (202) 708-0050 (this is not a toll-free number). Copies of

the proposed forms and other available documentation submitted to OMB

may be obtained from Mrs. Weaver.

SUPPLEMENTARY INFORMATION: The Department has submitted the proposal

for the collection of information, as described below, to OMB for

review, as required by the Paperwork Reduction Act (44 U.S.C. Chapter

350). It is also requested that OMB complete its review within 30 days.

The notice lists the following information: (1) The Title of the

information collection proposal; (2) the office of the agency to

collect the information; (3) the description of the need for the

information and its proposed use; (4) the agency form numbers, if

applicable; (5) what members of the public will be affected by the

proposal; (6) how frequently information submissions will be required;

(7) an estimate of the total number of hours needed to prepare the

information collection, including respondents, frequency of response,

and hours of response; (8) whether the proposal is new or an extension,

reinstatement or revision of an information collection requirement; and

(9) the name and telephone number of an agency official familiar with

the proposal and of the OMB Desk Officer for the Department.

Authority: Section 3507 of the Paperwork Reduction Act, 44

U.S.C. 3507, Section 7(d) of the Department of Housing and Urban

Development Act, 42 U.S.C. 35359d.

Dated: February 17, 1994.

Kenneth C. Williams,

Deputy Assistant Secretary for Grant Programs.

Submission of Proposed Information Collection to OMB

Proposal: Request for expedited approval of a survey needed to

complete a report to Congress on the use of Community Development Block

Grant (CDBG) Funds in promoting the development of microenterprises.

Office: Office of the Assistant Secretary for Community Planning

and Development.

Description of the Need for the Information and Its Proposed Use:

In the Housing and Community Development Act of 1992 (Pub. L. 102-550),

Congress directed that HUD report on the effectiveness of CDBG funds in

promoting the development of microenterprises [Section 807(C)(4)]. This

report is due to Congress the end of April, 1994 (within eighteen

months after date of enactment of the Act). The report is to contain

not only an analysis of the effectiveness of the use of CDBG funds in

promoting the development of microenterprises, but a review of any

statutory or regulatory provisions that impede such development.

A review of information available with the Department of Housing

and Urban Development indicates that insufficient information is

available to effectively respond to Congress' request. Two survey

instruments have been prepared to be administered via telephone to the

entire universe of CDBG grantees (both entitlements and states) and to

a purposive sample of microenterprise intermediary organizations. This

survey approach is expected to provide useful and usable data regarding

both entities that fund microenterprises and those that do not as well

as provide greater insights into an existing statutory and/or

regulatory impediments.

Respondents: Units of general local governments and states

receiving CDBG funds in Fiscal Year 1993 and a selected sample of 20

microenterprise intermediary organizations (taken from the 1992

Membership Directory for the Association for Enterprise Opportunity).

Frequency of Response: This is a one-time information collection

effort.

Reporting Burden:

------------------------------------------------------------------------

Estimated

No. of Estimated Total

Survey respondents time burden

hours

------------------------------------------------------------------------

Grantees............................... 897 \1/2\

hour 448.5

Microenterprise Intermediary

Organizations......................... 20 \1/2\

hour 10.0

Total respondent burden............ 917 \1/2\

hour 458.5

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Status: This is a one-time collection effort for a report to

Congress.

Contact: Barbara Neal, HUD (202) 708-1577.

Dated: February 17, 1994.

Supporting Statement for Collection of Information Community

Development Block Grant (CDBG) Microenterprise Report

Part A. Justification

1. Circumstances That Make the Collection of Information Necessary

Section 807(c)(4) of the Housing and Community Development Act of

1992 requires the Department of Housing and Urban Development (HUD) to

submit to Congress a report on the effectiveness of the use of CDBG

funds in promoting development of microenterprises, including a review

of any statutory or regulatory provision that impedes their

development. A microenterprise is defined by the 1992 Act to be a

commercial enterprise that has five or fewer employees, one or more of

whom owns the enterprise. HUD does not require grantees to report on

the size of the businesses receiving CDBG assistance and thus has only

very limited information currently available on this issue.

2. Purpose and Use of the Information

This survey is being undertaken in an effort to provide HUD with

current, relevant information regarding the actual experiences of

community and economic development practitioners in this area for the

Department's consideration in the preparation of the required report to

Congress. Such information will contribute to a more accurate appraisal

of microenterprise activities. If the survey is not conducted, the

report to Congress will clearly fail to fully address all relevant

statutory or regulatory provisions that serve to impede the effective

use of CDBG funds for microenterprise activities.

3. Use of Information Technology to Reduce Burden

HUD computerized files of Grantee Performance Report (GPR) data had

been used to determine a potential sampling frame of grantees for the

survey. However, the information provided only limited facts that

indicated a sampling frame of grantees would not provide adequate

information for the report to Congress. In order to respond most

effectively to the intent of the report, HUD needs information on

grantees that fund microenterprises, those which do not and what, if

any, impediments exist. The GPR data is not a reliable basis for

providing this data.

4. Efforts to Identify Duplication

Efforts have been made to identify possible duplication and avoid

it by reviewing GPR data files and information available in reports by

interest groups.

5. Availability of Similar Information

There is no systematic and uniform source of information about the

effectiveness of CDBG assistance in promoting the development of

microenterprises, nor about any existing statutory or regulatory

impediments. Information on type of grantee (state, urban county, unit

of general local government) and size of 1993 entitlement grant can be

obtained through HUD's existing data base. Other than that, however,

and as stated above, GPR data files provide limited information. They

are most useful in identifying grantees that are making small dollar-

value CDBG loans or grants to for-profit businesses. Such information

suggests that these activities are to assist microenterprises. The GPR

files do not, however, provide much qualitative information regarding

the nature of the activities or any statutory or regulatory impediments

that the respective grantees had to overcome in designing such

activities. Reports prepared by microenterprise interest groups provide

some information of this type, but it is limited. Perceived statutory

or regulatory impediments identified by some of these entities need to

be corroborated by obtaining information from actual practitioners.

6. Effort To Minimize the Burden for Small Entities

Most of the information collection does not involve small entities.

Some of the nonprofit intermediary organizations responding to the

survey, however, may have small staffs. Efforts have been made to

minimize the burden for such entities in the following ways:

a. By making this a one-time information-collection effort;

b. By collecting the data through telephone interviews, rather than

self-administered questionnaires. The survey is expected to take less

than 30 minutes;

c. By designing the survey in a manner that will not require

retrieving detailed activity information from case files or performing

extensive calculations or analysis of data.

The overall purpose of the survey is to provide HUD with the most

current, relevant information so that its required report to Congress

may best address any impediments to using CDBG funds for the

development of microenterprises. The input of small entities should

serve to provide invaluable input as to any existing statutory and/or

regulatory barriers that would serve to benefit all microenterprises.

7. Consequence of Less Frequent Information Collection

This is a one-time collection of information. Therefore, less

frequent collection of data is not an issue.

8. Inconsistency With 5 CFR 1320.6

The proposed data collection plan is consistent with the guidelines

set forth in 5 CFR 1320.6 (Controlling Paperwork Burdens on the

Public--General Information Collection Guidelines). There are no

circumstances that require deviation from these guidelines.

9. Consultation Outside of the Agency

HUD has discussed the type of information to be obtained through

the survey with the National Community Development Association at the

NCDA Legislative Conference on January 18, 1993. NCDA represents CDBG

entitlement grantees.

10. Assurances of Confidentiality

The data requested is not considered to be of a confidential

nature. No data on individual CDBG grantees or intermediary

organizations will be made available outside the agency without the

prior written consent of the appropriate party. The report to Congress

will analyze and aggregate the data received and will not include

identifiers linking back to individuals.

11. Questions of Sensitive Nature

There are no questions of a sensitive nature in this survey.

12. Estimated Cost to the Federal Government and to Respondents

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Average

Number of x Estimated x hourly = Total costs

respondents hours rates

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Grantees (States and Local Governments)... 897 \1/2\ hour $15.00 $6,727.50

Microenterprise Intermediary Organizations 20 \1/2\ hour 10.00 100.00

Federal Government:

Operational expenses (staff).......... .............. 20 15.00 300.00

Printing.......................... .............. ........... ........... 100.00

Postage........................... .............. ........... ........... 265.00

665.00

Survey completion and analysis........ .............. 575 15.00 8,625.00

9,290.00

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13. Respondent Burden

There will be two categories of respondents: CDBG grantees (states

and entitlement) and microenterprise intermediary organizations. Two

separate survey forms, one tailored for each group, have been designed.

Telephone surveys will be administered to all 897 CDBG entitlement and

state grantees and a selected sample of 20 respondents in the

microenterprise intermediary organization category. Most of the survey

questions are straight-forward and will not require much research or

analysis by the respondents. Those questions dealing directly with

perceived impediments to assisting microenterprises with CDBG funds

will require the most time on the part of respondents. Still, the

majority of respondents should be able to answer these questions with

minimal research and preparation. Thus, it is anticipated that the

phone survey will take each respondent approximately less than one-half

hour to answer. The surveys will be mailed to the respondents in

advance to familiarize them with the type of information being sought

to complete the report to Congress.

------------------------------------------------------------------------

Estimated

No. of Estimated Total

Survey respondents time burden

hours

------------------------------------------------------------------------

Grantees......................... 897 \1/2\ hour 448.5

Microenterprise Intermediary,

Organizations................... 20 \1/2\ hour 10.0

Total respondent burden.... 917 \1/2\ hour 458.5

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14. Reasons for Changes in Burden

This is a new information collection effort; therefore, this

section is not applicable.

15. Publication for Statistical Use

HUD will analyze the information obtained through the surveys to

determine common issues and problems encountered by community and

economic development practitioners in undertaking microenterprise

activities with CDBG funds. Data will be analyzed by grantee type,

regional identity and size of grant in determining if common issues and

problems exist. HUD will rely on the evaluation of the survey data in

preparing its required report to Congress.

Assuming approval from OMB is received no later than March 15,

1994, the surveys would be mailed no later than March 18, 1994. The

follow-up telephone survey is expected to begin March 24 and be

completed no later than April 6, 1994. Analysis of the data and

preparation of the report, pursuant to Section 807(c)(4) of the 1992

Act, would be completed by April 29, 1994 and forwarded to Congress

thereafter.

Part B. Collections of Information Employing Statistical Methods

1. Potential Respondent Universe

Two target populations are of interest to this survey: CDBG

grantees and microenterprise intermediary organizations. The data

collection approach employs two, statistical methods: A universe of 897

CDBG grantees (states and entitlements) and a purposive sample of 20

microenterprise intermediary organizations. Telephone interviews for

this group of 917 will be attempted and it is expected that 807 grantee

and 18 intermediary organization interviews will be completed for a 90%

response rate.

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Expected

Target Expected response Completed

Target population population sample rate telephone

size size (percent) interviews

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Grantees................... \1\897 897 90 807

Microenterprise

Intermediary Organizations \1\183 20 90 18

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\1\Based on 1993 CDBG funding allocations.

\2\Based on 1992 Membership Directory for the Association for Enterprise

Opportunity.

2. Procedures for Collection of Information

a. Universe/Sample Stratification and Selection. HUD intends to

survey all CDBG grantees because of the need to have information on

grantees that fund microenterprise organizations and those that do not;

there is no sampling frame that provides this information prior to

conducting the survey. For instance, if a sample of CDBG grantees was

drawn and the survey indicated that few of these grantees funded

microenterprises, it would provide little information to permit an

analysis of the effectiveness of the use of CDBG funds in promoting the

development of microenterprises.

A purposive sample of 20 intermediary organizations will be

selected from those listed in the 1992 Association for Enterprise

Opportunity Membership Directory. The sample will be selected on the

basis of type of intermediary organization (cooperatives/non-profit

enterprises, enterprise development organizations, financial

intermediaries, and technical assistance providers/consultants) and

geographic region to help ensure that the selected sample offers

representation and variability on these characteristics.

b. Estimation Procedure. Not applicable.

c. Degree of Accuracy. Assuming a 90% response rate from grantees

and that nonresponse is random, the grantee survey will yield very good

estimates even if the proportion of grantees who fund microenterprises

is small. The sample of intermediary organizations is not a statistical

sample.

d. Unusual Problems Requiring Specialized Sampling Procedures. No

specialized sampling procedures are required.

e. Use of Periodic Data Collection Cycles to Reduce Burden. This is

a one-time data collection effort.

3. Methods to Maximize Response Rates

In an effort to maximize response rates, a copy of the survey

instrument will be mailed to all respondents prior to the telephone

survey in order to familiarize them with its content.

4. Tests of Procedures to be Undertaken

Input has been received from HUD's Office of Policy Development and

Research (PD & R) in order to fine-tune the survey instrument and

permit the collection of information needed for the report to Congress.

5. Persons Involved in the Survey

Individual consulted on the statistical aspect of the survey

instrument: Kevin Neary, HUD's PD & R Program Evaluation Division (202-

708-0574).

Individual responsible for completion of report: Barbara Neal,

HUD's Office of Community Planning and Development, Entitlement

Communities Division (202-708-1577).

Grantee Survey for HUD Microenterprise Report

Section 807(c)(4) of the Housing and Community Development Act of

1992 (``1992 Act'') requires the Department of Housing and Urban

Development (HUD) to submit to Congress a report on the effectiveness

of the use of Community Development Block Grant (CDBG) funds in

promoting development of microenterprises, including a review of any

statutory or regulatory provision that impedes their development. This

survey is being undertaken in an effort to provide HUD with current,

relevant information regarding the actual experiences of community and

economic development practitioners in this area for the Department's

consideration in the preparation of the required report to Congress.

Your participation is voluntary, but failure to respond will hurt HUD's

ability to report accurately to Congress on the nature and extent of

microenterprise activity in the CDBG program. Therefore, your

participation is greatly appreciated.

This survey seeks to obtain information regarding any

microenterprise assistance activities you may be undertaking with CDBG

funds.

A ``microenterprise'' is defined by the 1992 Act to be a

commercial enterprise that has five or fewer employees, one or more of

whom owns the enterprise.

For the purposes of this survey, ``microenterprise

assistance activities'' are those that are designed to promote the

establishment and expansion of microenterprises, as such entities are

defined above. Examples of such activities include:

Provision of training for persons interested in

starting microenterprises.

Provision of technical assistance and training to

existing microenterprises.

Provision of financial assistance to new and existing

microenterprises.

Name of Grantee (Optional):--------------------------------------------

Type of Grantee (State, Urban County, Unit of Local Government):-------

Address, City, State, HUD Region:--------------------------------------

Name of Contact Person & Phone Number (Optional)-----------------------

1. Does your community use Community Development Block Grant (CDBG)

funds for microenterprise assistance activities?

Yes ______ No ______ (If No, go to Q.8)

2. What national objective(s) is/are your CDBG-funded

microenterprise assistance activities designed to meet? (Check all that

apply.)

______Low/mod Area Benefit

______Low/mod Jobs

______Slum/Blight

______Urgent Need

3. a. Are your CDBG-assisted microenterprise activities run

directly by the grantee or through a subrecipient or some other entity?

(Check all that apply.)

______Grantee

______Subrecipient

______Other (Describe)

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b. If the activities are run through a subrecipient, please identify

the nature of that entity (e.g., public non-profit agency, Community

Development Corporation (CDC), Small Business Investment Company

(SBIC), etc.). (Check all that apply.)

______Public non-profit agency

______CDC

______SBIC

______Other (Describe)

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4. What amount of CDBG funds has been budgeted in your most recent

final statement for microenterprise assistance activities? ____________

5. What percentage of your annual grant does the above amount

represent? ____________

6. Would you say the level of CDBG assistance you provide to

microenterprises is

______ To much (End of survey)

______ About right (End of survey)

______ Too little (Go to Q.7)

7. Is there anything about the CDBG statute or regulations that

prevents you from assisting as many microenterprises as you would like?

______ No

______ Yes (Please describe)

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(End of Survey)

For respondents that answered ``No'' to Q.1, please answer Q.8 and

Q.9.

8. Would you like to see your community use CDBG to support

microenterprise development?

______ No (End of survey)

______ Yes

9. If ``Yes'' to Q.8, is there anything about the CDBG statute or

regulations that prevents you from assisting microenterprises with CDBG

funds?

______ No

______ Yes (Please describe)

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This mailing has been sent to familiarize you with the survey

questions. An interviewer will contact you by telephone in the near

future to obtain you responses. If you have any questions concerning

this survey, please contact: Ms. Barbara Neal, Entitlement Communities

Division, U.S. Department of Housing & Urban Development, room 7282,

451-7th Street, SW., Washington, DC 20410. Telephone Number: (202) 708-

1577.

Survey of Intermediary Organizations HUD Microenterprise Report