2133-0010 Supporting Statement

2133-0010
SUPPORTING STATEMENT

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSIONS
UNDER 5 CFR PART 1320
Information Collection: 2133-0010
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.
Regulations pertaining to the U.S. Merchant Marine Academy (USMMA) appeared in the
Federal Register (Vol. 47, No. 98, p. 21811, dated May 20, 1982) as a final rule. Part 310.57(a)
of 46 CFR provides for the collection of information from anyone who is a prospect for
admission. It states that “all candidates shall submit an application for admission to the
Academy’s Admissions Office.” Thus, the collection of information through the use of an
application is the primary means by which selections for admission are made. The statutory
authority for continued existence of this Federally sponsored merchant marine academy is Title
XIII of the Merchant Marine Act of 1936.
This information collection supports the Secretary of Transportation's Strategic Security
Objective.
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.
The Candidate Application (KP 2-65) Part I is used to pre-screen applicants for basic eligibility
and to enter them into the Department of Defense medical system. Part I of the Application is
usually submitted to the USMMA Admissions Office approximately one month before Parts II
and III.
The information on the Candidate Application Parts II and III is used by the USMMA
admissions staff and its Candidate Evaluation Board to select the best qualified candidates for
the Academy. Part II is completed by the applicant and Part III by an official at the secondary
school where the applicant attends or has attended. The portion that the applicant completes
contains general identifying information; personal history data; participant activities and
achievements/awards earned; a biographical sketch and a statement that a Service Obligation
Contract must be signed after reporting to the Academy. The portion of the application that the
secondary school official completes contains transcript information, including standardized test
results, and a guidance counselor or principal’s evaluation of the applicant.
Selection of applicants for appointment is made in the order of merit. The order of merit is
determined by: the score on the required college entrance examination; an assessment of the
applicant’s academic background; and by other factors considered by the USMMA as effective
indicators of motivation and the probability that the applicant will complete the Academy’s

course of instruction.
If all these parts of the application were not completed, applicants would not meet an important
requirement of all candidates for admission to the USMMA and basic eligibility for an
appointment could not be determined.
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. Also describe any consideration of using information
technology to reduce burden.
All persons interested in obtaining an appointment to the USMMA are sent the entire application
form for admission (all 3 Parts). The person is urged to complete Part I immediately for a
determination of basic eligibility and to initiate the medical evaluation process. Parts II and III
are subsequently returned to the USMMA, completing an official candidate file. This file on the
candidate is maintained throughout the admissions recruiting/selection cycle. Candidates may
also apply on-line through the Academy’s website. www.usmma.edu, which has resulted in a
significant reduction in paperwork.
The Admissions Office staff uses a computerized applicant processing system that enables them
to use the information from Part I to screen applicants quickly against the admission
requirements. This immediate feedback is beneficial to the eligible and ineligible applicants,
both of whom must do next-step planning. The individualized nature of the information on all
three parts of the application and the increasing use of personal computers, FAX machines, email and answering machines by applicants has helped to reduce the shared admissions process
burden to some degree.
The Admissions Office has reduced usage of the government-printed application form by
approximately 25 – 33% by offering Part I of the application on-line (through the Academy’s
website), and with Parts II and III being printed by the applicants who apply through the website.
It is expected that the percentage will continue to increase in future years, as more students feel
comfortable with the on-line application process and have access to the tools needed to complete
the application that way.
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.
Parts I, II, and III of the Candidate Application are the only three forms used to determine basic
eligibility and selection of persons for admission to the USMMA. There are no other agency
forms collecting this same information.
5. If the collection of information impacts small businesses or other small entities (Item 5 of
OMB Form 83-I), describe any methods used to minimize burden.
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The collection of information does not involve small business or other small entities. The
collection of information on the three parts of the application is a one-time requirement for
applicants seeking admission to the USMMA. The burden to the applicant is as minimal as
statutes and regulations permit.

6. Describe the consequence 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.
Completed Parts I, II, and III of the Admissions Application are absolute requirements for
admission to the USMMA and must be obtained from each new applicant. This is a one-time
requirement. The consequences from reduced or non-collection of this information would be to
jeopardize the USMMA admissions process and the appointment of a candidate.
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 a 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 statute or regulation, that is not supported by disclosure and data
security policies that are consistent with the pledge, or which unnecessarily
impedes sharing 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.
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There are no special circumstances that require the collection of information to be conducted in a
manner described above.
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 three 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.
The Maritime Administration published a 60-day notice and request for comments on this
information collection in the Federal Register on December 11, 2007, (72 FR 70370) [copy
attached] indicating comments should be submitted on or before February 11, 2008. No
comments were received.
9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
No payments or gifts are provided to respondents.
10. Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.
The USMMA does not consult or discuss any information on any part of the application with
anyone except the candidate or other individuals expressly designated by the candidate or as
authorized by the provisions of the Privacy Act Notice. The applicant must sign an authorization
indicating to whom the Admissions Office may disclose information regarding their candidacy.
Information on a candidate is released only on a “need to know basis.” Candidate files are
retained for four years and then destroyed.
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
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private. This justification should include the reasons why the agency considers the
question 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.
Not applicable. There are no questions of a sensitive nature.
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 burden and explain the reasons for the variance.
Generally, estimates should not include burden hours for customary and usual
business 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 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.

Approximately 2,500 applicants return completed applications to the USMMA annually. Five
hours has been estimated as an average amount of time to complete all three parts of the
Candidate Application.
The first two parts (four pages) of this application are completed by the applicant, while the third
part (two pages) is completed by secondary school officials. The five-hour estimate is broken
down as follows: three hours to accurately complete Parts I and II of the application, and to
compose a biographical statement including reasons for wanting to attend the USMMA, a
discussion of curriculum preference and development of interest as a result of high school
classes, hobbies and activities; one and one-half hours to submit to the high school official the
request for secondary school transcript and that official’s time to complete the form, obtain a
transcript and compute the class rank; and, one-half hour to submit to the high school official the
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request for evaluation of candidate and the school official’s time to prepare the evaluation. No
major changes are being made to the application that will increase the respondent burden nor is
the respondent size expected to dramatically change.

Responses
Number of
per
Respondents
Respondent
2,500
x 1
=

Total
Hours
Responses
Per
Annually
Response
2,500
x
5
=

Total
Hours
Annually
12,500

A determination of the estimated number of hours required per response was made after
consultation with several respondents.
There is no cost to apply to the USMMA. There is no application fee, however, the cost to
register for the college entrance exam (SAT) is $43.00, (ACT is $44.50) as of January 31, 2007.
Approximately 50% of applicants submit only SAT scores; approximately 20% submit only
ACT scores; and approximately 30% submit both SAT and ACT scores. Thus, the total average
respondent cost of returning all three parts of the application (USMMA provides postage paid
envelopes for each part of the application) and registering for the SAT exam (Scholastic
Assessment Test) and/or ACT exam (American College Testing) is $56.65 per applicant, which
totals $141,625.00 for 2,500 applicants.
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 ranges 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
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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 rulemaking 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.

There are no capital, start-up, or operation and maintenance costs associated with 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.
The total estimated cost to the Federal Government to process the application packages (Parts I,
II, and III of the Admissions Application) of the 2,500 persons who will apply to the USMMA
each year is $625,000.00. This amount includes the annual salaries of the ten USMMA
Admissions staff persons which is $616,000.00, the cost of composition and printing of all three
parts of the Application which is $3,000.00, and the estimated annual postage cost which is
$6,000.00.
Below are the titles of the ten Admissions Office staff persons. The time that each person
devotes exclusively to the application process varies from 50% to 90%. However, the remainder
of their time is spent performing duties that relate directly to the admissions process. The
average hourly rate of pay for the ten staff persons is estimated to be $30.00 per hour. The ten
staff members are as follows.
. 1 Admissions Director
1 Admissions Assistant Director
. 3 Recruitment Specialists
. 1 Diversity Recruitment Specialist
. 1 Secretary
. 3 Admissions Assistants

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15. Explain the reasons for any program changes or adjustments reported in items 13 or
14 of OMB Form 83-I.
No change in burden is anticipated.
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.
The information on the application is not tabulated and published for public use due to Privacy
Act restrictions.
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.
Not applicable.
18. Explain each exception to the certification statement identified in Item 19,
"Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.
Not applicable. There are no exceptions to the certificate statement.

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