1625-0020_ss

1625-0020

Supporting Statement

for

Security Zones, Regulated Navigation Areas, and Safety Zones

A. Justification

1. Circumstances which make the collection of information necessary.

a) Security Zones: Executive Order 10173 (October 20, 1950) authorized the Coast Guard to prescribe procedures for establishing and appealing security zones. These regulations are contained in 33 CFR Parts 6 and 165. Security zones are areas of land, water, or land and water designated by the Coast Guard Captain of the Port (COTP) where access is limited to authorized persons, vehicles, or vessels, or waterfront facilities. Security Zones are necessary to prevent destruction, loss or injury from sabotage or subversive activity. Under these regulations, the COTP may designate security zones in the U.S. jurisdiction, for a period of time he deems necessary to prevent damage or injury. The COTP limits access to a security zone by prohibiting the entry of unauthorized persons, vehicles, or vessels, requiring reduced speed, or setting other restrictions.

b) Regulated Navigation Areas (RNAs): The Port and Tanker Safety Act (§33 U.S.C. 1223) authorized the Coast Guard to prescribe special regulations to control vessel traffic in areas that are determined to be hazardous due to conditions of reduced visibility, adverse weather or vessel congestion. The regulations in 33 CFR 165, provide for the establishment of regulated navigation areas, which are areas of the navigable waters of the U.S. requiring special procedures to assure the safe navigation of vessels.

c) Safety Zones: The Ports and Waterways Safety Act (§33 U.S.C. 1225) authorized the Coast Guard to establish regulations to allow the designation of safety zones. These regulations are contained in 33 CFR 165. Safety zones are areas of land, water, or land and water designated by the COTP where access is limited to authorized persons, vehicles, or vessels to protect the public from a hazardous situation. The COTP may designate safety zones in the U.S. and the navigable waters of the U.S., for a period of time he deems necessary to prevent damage or injury to persons, vessels or waterfront facilities. The COTP limits access into a safety zone by prohibiting the entry of unauthorized persons, vehicles, or vessels, requiring reduced speed, or setting other restrictions.

The COTP may establish a security zone, regulated navigation area or safety zone at the request of any person or of his or her own volition.

This information collection supports the following strategic goals:

Department of Homeland Security

• Prevention

• Protection

• Response

• Recovery

Coast Guard

• Maritime Safety

• Maritime Security

• Maritime Stewardship

Prevention Directorate (CG-3P)

• Safety: Eliminate deaths, injuries, and property damage associated with commercial maritime operations.

• Security: Eliminate marine transportation and coastal security vulnerability.

• Human and Natural Environment: Eliminate environmental damage associated with maritime transportation and operations on and around the nation’s waterways.

• Economic Growth and Trade/Mobility: Reduce interruptions and impediments that restrict the economical movement of goods and people, while maximizing safe, effective, and efficient waterways for all users.

2. By whom, how, and for what purpose the information is to be used.

a), b), and c): Government agencies, industry or the public may request that the Coast Guard establish a security zone, safety zone or regulated navigation area. This information is collected only as needed. The Coast Guard uses the information to assess the need to establish a security zone, safety zone or regulated navigation area. Similar data is not available elsewhere since the information is unique to each situation and applies to a specific time, duration, place, and operation. If this information is not collected, potential threats or hazards may not be identified. If the Coast Guard is not able to identify the threat or hazard, appropriate action cannot be taken which may result in injury or damage to persons, vessels, ports or waterfront facilities.

3. Consideration of the use of improved information technology.

a), b), and c): The information provided by the respondents is particular to each request and as such, the use of any form of improved information technology would be minimal. Title 33 CFR 165 requires that requests be submitted in writing, and this can be done via mail, fax or electronic mail as well. We estimate that approx. 10% of all submissions are received electronically. Each request, regardless of the method of submission, would still be handled virtually the same way and require the same amount of time.

4. Efforts to identify duplication. Why similar information cannot be used.

a), b), and c): To date, no State or local programs have been identified that require equivalent information. No other Federal agencies have similar or equivalent regulatory requirements.

5. Methods used to minimize the burdens to small business if involved.

a), b), and c): Requests for security zones are generally made by Federal, State and local government agencies. Small businesses do not normally request establishment of a security zone. They rarely request regulated navigation areas. Occasionally, a small business may request the establishment of safety zones. In order to minimize the burden on the public, only the minimum information necessary to establish these zones is required and the information is not required in a specific time format.

6. Consequences to the Federal program if collection were not done or conducted less frequently.

a), b), and c): This information is collected only when a security zone, regulated navigation area or safety zone is requested or needed. Less frequent collection would have the same consequences as no collection.

7. Explain any special circumstances that would cause the information collection to be conducted in a manner inconsistent with guidelines.

Information is collected in a manner that is consistent with the guidelines.

8. Consultation.

A 60 day Notice was published in the Federal Register to obtain public comment on this collection. (See [USCG-2007-0045], November 15, 2007 72 FR 64233) The USCG has not received any comments on this information collection. (See [USCG-2007-xxxxx]; xxx, x, 2007; 72 FR xxxxx). The USCG has not received any comments on this information collection.

9. Explain any decision to provide payment or gift to respondents.

No payments or gifts of any kind are provided to respondents.

10. Describe any assurance of confidentiality provided to respondents.

No assurance of confidentiality is provided to respondents.

11. Additional justification for any questions of a sensitive nature.

There are no issues of a sensitive nature involved in this information collection.

12. Estimates of reporting and recordkeeping hour and cost burdens of the collection of information.

• The estimated annual number of respondents is 236.

• The estimated annual number of responses is 236.

• The estimated annual hour burden is 295 hours.

• The estimated annual cost burden is $24,544.

For all calculations, we use the wage rate of $92/hour for management personnel, and a wage rate of $48/hour for clerical personnel.¹ We found in 2007 that there were 75 Security Zone requests, 11 RNA requests and 150 Safety Zone requests.

The annual cost for Security Zone requests is estimated to be $7,800 and 93.75 burden hours as calculated and shown in Table 1.

Table 1: Costs for Security Zone Requests

Personnel involved	Wage/hour	Time taken (hrs.) to draft and review, and type response	Cost
Management – reviews request/appeal	$92	1.0	$92
Clerical – types response	$48	0.25	$12
Total Cost per Security Zone Request		1.25 burden hours	$104
Total Annual Cost for all 75 Security Zone Requests		93.75 burden hours	$7,800

The annual cost for RNA requests is estimated to be $1,144 and 13.75 burden hours as calculated and shown in Table 2.

Table 2: Costs for Regulated Navigation Area (RNA) Requests

Personnel involved	Wage/hour	Time taken (hrs.) to draft and review, and type response	Cost
Management – reviews request/appeal	$92	1.0	$92
Clerical– types response	$48	0.25	$12
Total Cost per RNA Request		1.25 burden hours	$104
Total Annual Cost for 11 RNA Requests		13.75 burden hours	$1,144

The annual cost for Safety Zone requests is estimated to be approximately $15,600 and 187.5 burden hours as calculated and shown in Table 3.

Table 3: Costs for Safety Zone Requests

Personnel involved	Wage/hour	Time taken (hrs.) to draft and review, and type response	Cost
Management – reviews request/appeal	$92	1.0	$92
Clerical– types response	$48	0.25	$12
Total Cost per Safety Zone Requests		1.25 burden hours	$104
Total Annual Cost for all 150 Safety Zone Requests		187.5 burden hours	$15,600

13. Estimates of annualized capital and start-up costs.

There are no annualized capital and start-up costs.

14. Estimates of annualized Federal Government costs.

Requests are infrequent but usually involve unique problems requiring considerable Coast Guard review and evaluation. Frequently, trips to the scene and considerable command level liaison with other government agencies and marine industries are necessary before a decision is made. Costs are detailed in the table below.

The annualized cost to the Federal Government is estimated to be $144,432. The burden hours involved are approximately 2,124 hours. Calculations are shown in Table 4.

Table 4: Annualized Costs to the Federal Government

Personnel involved	Wage/hour	Time taken (hrs.) to draft and review, and type response	Cost
Senior Officer (O-5 government rank) – reviews request/appeal	$80	3	$240
Junior Officer (O-3 government rank) – reviews request/appeal	$62	6	$372
Total cost per request		9 burden hours	$612
Total Annual Cost for all 236 Requests		2,124 burden hours	$144,432

15. Explain the reasons for the change in burden.

a), b), and c): The change (i.e., increase) in hour burden is an ADJUSTMENT and is strictly due to an increase in the annual number of requests for Security Zones, Regulated Navigation Areas, and Safety Zones. The methodology for estimating hour burden per response per year remains unchanged.

The change in the number of responses is strictly due to an increase in the annual number of requests for Security Zones, Regulated Navigation Areas, and Safety Zones. The methodology for estimating responses per year remains unchanged.

16. For collections of information whose results are planned to be published for statistical use, outline plans for tabulation, statistical analysis and publication.

There is no plan to use statistical analysis or to publish this information.

17. Approval to not display expiration date.

We are not seeking such approval. The OMB Number will appear on appropriate PRA disclosure information.

18. Explain each exception to the certification statement.

There are no exceptions to the certification statement.

2. Collection of Information Employing Statistical Methods

This information collection does not employ statistical methods.

1 Derived from Enclosure (2) to COMDTINST 7310.1K. For management personnel we used an O-4 wage equivalent and for clerical personnel we used an E-5 wage equivalent.

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