Supporting statement

SUPPORTING STATEMENT FOR REQUESTS FOR APPROVAL UNDER

THE PAPERWORK REDUCTION ACT AND 5 CFR 1320

Safety Harbors and Safety Landings Assessment, Tennessee River

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.
   
   

1. The Tennessee Valley Authority, in conjunction with the U. S. Army Corps of Engineers, is assessing the status of the safety harbors and safety landings located along the Tennessee River and its tributaries. This type of assessment was performed approximately ten years ago. However, due to the changing river conditions and uses over the past several years, along with the growing demand for lake access, it is important to identify and preserve the most essential and useful safety harbors and landings that are currently designated.

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.

1. The Tennessee Valley Authority and the U. S. Army Corps of Engineers will use the collected information to support the justification of preserving stretches of shoreline for commercial navigation uses. The safety harbors and safety landings that are considered unusable and nonessential by the towing industry will be determined by tallying the collected information.

3. Describe whether, and to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology, e.g. permitting electronic submission of responses, and the basis for the decision for adopting this means of collection. Also, describe any consideration of using information technology to reduce burden.

1. The assessment will be administered via electronic mail. Responses can be submitted via electronic mail or U. S. mail. By doing so, the assessment can be conducted in a more timely manner, while reducing the costs for mailing and printing.

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.
   
   

1. This type of information has not been collected in over ten years. The Tennessee Valley Authority is responsible for obtaining this type of information.

5. If the collection of information impacts small business or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.
   
   N/A

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.

1. Safety harbors and safety landings are designated stretches of shoreline to be used by vessels during inclement weather, mechanical failure, or other emergency. These stretches of shoreline are designated for commercial use in each reservoir land plan, and private development is not permitted. Without this information, it will become increasingly difficult to justify preserving stretches of shoreline for commercial navigation uses, resulting in the loss of safe pull-over areas for towboats and barges.

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
   that can be generalized to the universe of study;
   - requiring the use of 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 statue
   or regulation, that is not supported by disclosure and data security policies that are consistent
   with the pledge, or which unnecessarily impedes sharing of data with other agencies for
   compatible confidential use; or
   - requiring respondents to submit proprietary trade secret, 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.

N/A

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 instructions 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.

1. FR Notice published April 13, 2007; page 18723 (copy attached).

The format of this assessment was coordinated with the U. S. Army Corps of Engineers.

9. Explain any decision to provide any payment or gift to respondents, other than reenumeration of contractors or grantees.
   
   N/A

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

N/A

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. This 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.

N/A

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.

a)Number of respondents: 80

b) Frequency of response: one time

c) Number of responses: 80

d) Hours per response: 0.5 hours

e) Annual burden 40 hours

- 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 13 of OMB Form 83-I.

- Provide estimates of annualized cost to respondents for 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.

The estimated hourly wage (including benefits) for the TVA service area is $19.00; therefore, the estimated respondent cost is $760.00 ($19.00 x 40 hours). The hourly wage information was obtained from the PEW Center on the States, a research organization administered by the University of Richmond. A sixty percent load for benefits was added to the $12.00 from the PEW Center to reach the estimated hourly wage of $19.00.

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 record storage facilities.
    
    - If cost estimates are expected to vary widely, agencies should present rates of cost burdens and
    explain the reasons for the variance. The cost of purchasing or 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 rule making containing the information 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 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.

N/A

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.
    
    

N/A

15. Explain the reasons for any program changes or adjustment reported in Items 13 or 14 of the OMB Form 83-I.
    
    

N/A

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.

N/A

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.

N/A

18. Explain each exception to the certification statement identified in Item 19, “Certification for Paperwork Reduction Act Submissions,” of OMB Form 83-I.

N/A

B. Collection of Information Employing Statistical Methods

The agency should be prepared to justify its decision not to use statistical methods in any case where such methods might reduce burden or improve accuracy of results. When Item 17 on the Form OMB 83-I is checked, "Yes," the following documentation should be included in the Supporting Statement to the extend that it applies to the methods proposed:

1. Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection methods to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons) in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the collection as a whole. If the collection had been conducted previously, include the actual response rate achieved during the last collection.

2. Describe the procedures for the collection of information including:

* Statistical methodology for stratification and sample selection,

* Estimation procedure,

* Degree of accuracy needed for the purpose described in the justification,

* Unusual problems requiring specialized sampling procedures, and

* Any use of periodic (less frequent than annual) data collection cycles to reduce burden.

3. Describe methods to maximize response rates and to deal with issues of non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield "reliable" data that can be generalized to the universe studied.

4. Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of test may be submitted for approval separately or in combination with the main collection of information.

5. Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency.