0397 ss 102308rev

SUPPORTING STATEMENT
APPLICATION FORM FOR MEMBERSHIP ON A NATIONAL MARINE
SANCTUARY COUNCIL
OMB CONTROL NO. 0648-0397
A. JUSTIFICATION
1. Explain the circumstances that make the collection of information necessary.
Section 315 of the National Marine Sanctuaries Act (16 U.S.C. 1445a) allows the
Secretary of Commerce to establish one or more advisory councils to provide advice to
the Secretary regarding the designation and management of national marine sanctuaries.
Councils are individually chartered for each sanctuary to meet the needs of that specific
site; fourteen councils are established as of September 4, 2008. Once a council has been
chartered, the sanctuary superintendent starts a process to recruit members for that
council by providing a notice to the public and asking interested parties to apply for the
available seats. An application form has been developed to help ease the application
process for the public and facilitate the review process for the sanctuary superintendent.
This request is for renewal of this information collection.
2. Explain how, by whom, how frequently, and for what purpose the information
will be used. If the information collected will be disseminated to the public or
used to support information that will be disseminated to the public, then explain
how the collection complies with all applicable Information Quality Guidelines.
The availability of seats on a council is announced by the appropriate sanctuary through
various public channels, including a Federal Register Notice, local press releases,
announcements at local meetings, and posting on the sanctuary’s web page. Interested
persons can request the application kit (containing the application form, a copy of the
council’s charter, the council handbook and some information about the sanctuary itself)
by phone, fax or email. The applicant then completes and returns the form to the
sanctuary office, by mail, fax or electronically. Several sanctuaries per year will have to
fill some vacancies on existing councils; new councils may be created if new sites are
proposed for designation.
The specific information requested by the application will be used in the following
ways:
•

Seat applying for (applicants are asked to check a box for the seat for which they are
applying): This information is used to determine which seat on the council the
applicant is interested in holding.

•

Name, addresses and phone numbers: This is basic contact information that is
necessary in order to notify the applicant about whether he or she will serve on the
council; if the applicant becomes a member of the council, this information is used to

keep them informed of meeting dates, upcoming events, etc.
•

Question 1: Reasons for interest in serving on the council: This information is
used to help the sanctuary superintendent determine the nature of the applicant’s
views on the protection and management of marine and/or Great Lakes resources.

•

Questions 2 – 8: This information is used to determine the qualifications of the
applicant for the seat for which he or she is applying, relative to those of other
applicants for the same seat.

•

Question 9: Other qualifications or information. This information allows the
applicant to provide additional information about his or her qualifications for the
seat that might not be readily apparent elsewhere in the application.

As explained in the preceding paragraphs, the information gathered has utility. The
Office of National Marine Sanctuaries (ONMS) will retain control over the information
and safeguard it from improper access, modification, and destruction, consistent with
NOAA standards for confidentiality, privacy, and electronic information. See response to
Question 10 of this Supporting Statement for more information on confidentiality and
privacy. The information collection is designed to yield data that meet all applicable
information quality guidelines. Should NOAA decide to disseminate information other
than members’ names and addresses, it will be subject to the quality control measures and
pre-dissemination review pursuant to Section 515 of Public Law 106-554.
3. Describe whether, and to what extent, the collection of information involves the
use of automated, electronic, mechanical, or other technological techniques or
other forms of information technology.
The ONMS provides a broad opportunity for the public to apply for membership on
councils. Application kits are available by mail or electronically on the individual
sanctuary’s web page or in the Council Handbook,at
http://sanctuaries.noaa.gov/management/ac/acref.html, and can be submitted through the
mail, by fax or email.
4. Describe efforts to identify duplication.
Sanctuary advisory councils are bodies unique to the ONMS; no other collection of
information meets the needs of the ONMS for the purpose of selecting members of
councils.
5. If the collection of information involves small businesses or other small entities,
describe the methods used to minimize burden.
N/A.

6. Describe the consequences to the Federal program or policy activities if the
collection is not conducted or is conducted less frequently.
Councils serve an important function in the management of sanctuaries, by providing
advice to the sanctuary superintendent (from a variety of different perspectives and
interests) and helping link the sanctuary to the community. Congress understood this
importance and deliberately provided the ONMS with its own authority to have councils,
making the councils exempt from the Federal Advisory Committee Act. Being able to
collect this information allows the ONMS to choose the best applicants to serve as
members of the council. Without this information collection, council work would not be
done effectively.
7. Explain any special circumstances that require the collection to be
conducted in a manner inconsistent with OMB guidelines.
The collection is consistent with OMB guidelines.
8. Provide information on the PRA Federal Register Notice that solicited public
comments on the information collection prior to this submission. Summarize the
public comments received in response to that notice and describe the actions taken
by the agency in response to those comments. Describe the 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 recordkeeping, disclosure, or
reporting format (if any), and on the data elements to be recorded, disclosed, or
reported.
A Federal Register Notice published on August 12, 2008 (73 FR 46873) solicited public
comment. No comments were received.
9. Explain any decisions to provide payments or gifts to respondents,
other than remuneration of contractors or grantees.
Applicants are not given payment or gifts. If selected to serve on a council,
members are eligible for invitational travel expenses (e.g., per diem) for costs
associated with official meetings (per the National Marine Sanctuaries Act).
10. Describe any assurance of confidentiality provided to respondents and the
basis for assurance in statute, regulation, or agency policy.
If chosen to serve on a council, members are informed that their names and business
contact information (or other contact information as the member prefers) are made
available so that constituents from the segment of the community the member represents
can contact him or her. Applicants are also informed on the application that other parts

of the application may be subject to release under a request from the Freedom of
Information Act, through a court order, or in response to a Congressional inquiry.
Protection of applications (for both selected and non-selected applicants) is as follows:
•

Council Applications for Selected Applicants: These are retained and filed in a secure
location inaccessible to non-staff. When no longer needed, they are shredded. For
record-keeping purposes, applications are retained for 5 years beyond the expiration
of their seat term.

•

Council Applications for Non-Selected Applicants: These applications are retained
and filed in a secure location as described above. Applications are filed according to
the seat applied for. It is useful to have this information to solicit qualified nonselected applicants to apply again when council seats are vacated. When no longer
needed, they are shredded. For record-keeping purposes, these applications are
retained for 5 years beyond their application date.

.
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.
No questions of a sensitive nature are asked.
12. Provide an estimate in hours of the burden of the collection of information.
The ONMS expects to have an average of 500 applicants per year, with an estimated
time per applicant of one hour for obtaining, completing and returning the application,
for a total annual response time of 500 hours.
13. Provide an estimate of the total annual cost burden to the respondents or
record-keepers resulting from the collection (excluding the value of the
burden hours in Question 12 above).
There are no capital or start-up costs. No special equipment will need to be obtained for
this information collection. The ONMS expects applications to cost about $2 per person
for the cost of a phone call or email request for the application and the cost of
electronically returning or mailing the completed application, for a total annual cost to the
public of $1000.

14.

Provide estimates of annualized cost to the Federal government.

The estimated annual costs to the federal government would include:
• Copying = $200 (5000 pages at $.04 a page for copying applications,
council charters, and other information for application packages)
• Mailing = $700 (mailing 700 applications* at $1 each)
•

Labor = $28,000 (2 hours per application requested to cover responding to request
for application, mailing, copying for review, conducting the review, and
responding to applicant; estimate 2 hours/application x 700 applications x
$20/hour).

Total = $28,900.
15. Explain the reasons for any program changes or adjustments.
There are no program changes or adjustments.
16. For collections whose results will be published, outline the plans for
tabulation and publication.
Only the name and contact information for each successful applicant would be published.
Such information would likely appear in the individual sanctuary’s web page,
newsletters, and other usual information outlets for that sanctuary. New council members
are usually announced about a month after the deadline for accepting applications has
passed. Annually the ONMS also prints a directory of all council members across the
program and their contact information.
17. If seeking approval to not display the expiration date for OMB approval
of the information collection, explain the reasons why display would be
inappropriate.
No exemptions are being sought.
18. Explain each exception to the certification statement identified in Item 19
of the OMB 83-I.
There are no exceptions.
B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL
METHODS
This collection does not employ statistical methods.
* Approximately 700 applications are sent out, with an estimated 500 to be completed and returned.