AMVER - 2009 Supporting Statement - Annual

SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT
SUBMISSIONS UNDER 5 CFR PART 1320
Information Collection 2133-0025
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 of each regulation mandating or
authorizing the collection of information.
In 1975, the Maritime Administration, at the request of the Department of Navy,
established the U.S. Merchant Vessel Locator Filing System (USMER) to enable the
Navy and the Maritime Administration to maintain a current plot of U.S.-flag, and certain
non U.S.-flag ships, in order to facilitate immediate marshaling of ships for national
defense purposes.
Concurrently, the U.S. Coast Guard (USCG) operated the Automated MutualAssistance Vessel Rescue System (AMVER) receiving reports from ships of all nations
for the purpose of maintaining a plot for Search and Rescue (SAR) for safety of life at
sea. Participation in AMVER was voluntary, except for Norway which required its ships
to report.
Subsequently, the Maritime Administrator and the Commandant of the U.S. Coast
Guard, with the concurrence of the Chief of Naval Operations, agreed that the
objectives of USMER and AMVER should be met by a single reporting system. This
merger was accomplished in 1986, eliminating the need for separate reports to two
different agencies and effectively reducing reporting requirements by 50 percent. The
new rule and reporting instructions was published in 46 CFR Subchapter F Part 307
as "Establishment of Mandatory Position Reporting System for Vessels."
Safety, in terms of a reduction in transportation-related deaths and injuries, is a
Department of Transportation (DOT) strategic goal. This AMVER information collection
supports the DOT's strategic goal on safety at sea by providing the U.S. Coast Guard
with a vessel plot for Search and Rescue (SAR), including the medical evacuation of
injured seamen.
Authority: Section 204(b), 212(A), 1203(a) - Merchant Marine Act 1936, as
amended (46 U.S.C. 1114(b), 1122.a, 1283; Public Law 9731 (95 Stat. 157 August 6,
1981); Regulation: 46 CFR Part 307 (51FR 18329 May 19, 1986); 49 CFR 1.66
(46FR 47458 September 28, 1981). Search and Rescue (14 U.S.C. 2, 88, 90, 92, 93,
141, 142, 147, 149, 764, 821-832; 42 U.S.C. 249; 46 U.S.C. 721-731; P.L. 95-61; T.S.
502 (1908); T.S. 576.

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.
AMVER's primary purpose is to assist the U.S. Coast Guard in directing ocean-going
ships to come to the aid of other ships which are in danger of sinking or experiencing
other life-threatening situations. By maintaining a worldwide system of vessel positions,
vessels can be diverted to come to the assistance of a near-by vessel that is in
distress. In 2008, 139 ships from 28 countries were diverted to assist other vessels
which resulted in 197 survivors rescued. Please see attached "2008 AMVER Business
Report".
The Maritime Administration (MARAD) makes use of AMVER in a limited way
in that we access information only on U.S.-flag vessels or those foreign-flag
vessels which request that their position reports be made available to MARAD.
The different purposes for which MARAD uses this information are: (1) To
keep track of 60 U.S.-flag vessels which are part of the Maritime Security
Program. The ship owners of these military useful vessels receive an annual
payment from MARAD to keep these vessels sailing commercially under U.S.
registry and to make them available to the government in time of national
emergency. (2) In the event of a localized area of danger (for example mines in
a particular body of water) U.S. ships in the vicinity could be notified of the area
to avoid. (3) A worldwide plot of U.S.-flag vessels under the Voluntary Intermodal
Sealift Agreement (VISA) would assist with the possible use of these ships for
national defense purposes.

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.

In recent years, the available means for vessels to transmit AMVER messages has
greatly evolved due to the technical improvements and innovations in shipboard
communications and satellite technology. Presently the preferred method for ships to
send AMVER message to the U.S. Coast Guard is by electronic mail to the following
internet address: [email protected]. Electronic mail may be sent via satellite or via HF
radio, depending on the ship's equipment and arrangements with communications
providers ashore. AMVER messages can also be combined with the National
Oceanic and Atmospheric Administration (NOAA) weather reports. This system
became functional in November 1998 under a cooperative agreement between NOAA
and the U.S. Coast Guard. AMVER/SEAS software was developed for submitting
both AMVER and weather reports. A ship can reduce reporting requirements since
AMVER position reports are created from each weather message and automatically
forwarded to the U.S. Coast Guard. Typically NOAA weather reports are sent from
ships at sea every six hours whereas AMVER reports are sent every 48 hours. The e-

mail path on shore to the AMVER center is at no-cost, but the communications service
provider may still charge from ship-to-shore.
The Coast Guard continues to test the feasibility of using passive satellite polling in
order to plot vessels for AMVER. The advantage of which is that it would not
require any messaging input from the vessel other than having the satellite terminal
on. However, since AMVER is a Coast Guard managed system, any future technical
improvements in the collection of vessel reporting will be directed by the Coast
Guard.
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.

MARAD and USCG do not maintain duplicate systems as MARAD is a user of
the USCG system. The DOD Office of Naval Intelligence (ONI) and certain law
enforcement agencies operate a highly-classified locator system for military
intelligence and drug enforcement purposes which cannot be used for AMVER
purposes.
There are no other collections of current at-sea position location information or sources
of real-time, worldwide data available to the government. There are commercial
organizations in the U.S. that collect position information from vessels subscribing to
their services such as weather routing and chartering. However, this information is
not for search and rescue or national security, and is not available to outside parties
except on a contractual basis.
5.

If the collection of information impacts small businesses or other small entities,
describe any methods used to minimize the burden.
The rule only affects ocean ship operators in foreign trade whose businesses usually have
annual receipts far in excess of a small business entity.

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 the burden.
The continuous movement of ships at sea makes collection of positions any less
frequently than every 48 hours impractical for maintaining the timely plots required for
search and rescue and national security.

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 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;

With the exception of the 48-hour reporting requirement applicable to the first item,
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 recordkeeping, 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.

MARAD published a 60-day notice and request for comments on this information
collection in the Federal Register, 74 FR 26268, June 1, 2009, indicating comments
should be submitted on or before July 31, 2009. No comments were received.
In carrying out their responsibilities, MARAD and USCG maintain continuous contact
with U.S.-flag shipping companies and industry groups relative to AMVER and have
been responsive to suggestions and improvements. The Coast Guard cooperates with
other national and international agencies concerned with search and rescue, such as
the Interagency Committee on Search and Rescue (ICSAR), as well as with foreign
governments.
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 USCG has a policy statement that the information collected under
AMVER will be released only to recognized SAR authorities during a bonafide
emergency or used to make advance notice to other USCG activities of arrivals in U.S.
ports. This is stated in the Commandant Instruction "COMINST 16122 Series" and 46
CFR Part 307. Ship location information from AMVER is used by MARAD only
with proper safeguards, and when used jointly with the Department of Defense may
be classified at Confidential or higher levels during military exercises or actual
national security situations.

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.
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 83-1.



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.

Number of
Respondents

Responses
Per
Respondent

Total
Responses
Annually

Hours
Per
Response

Total
Hours
Annually

183

160

29,280

.07

2,050

There are no record keeping requirements for respondents and no burden hour costs
associated with this collection of information.
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).
0

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.

0

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
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.
0

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.

The annual cost burden to respondents per response is as follows:
(a)

Total Capital and Start-Up Costs Estimate:

There are no capital or start-up costs associated with this information collection.
(b) Total Operation and Maintenance and Purchase of Services Estimate:

Ship's crew time spent on preparing and transmitting the message occurs during
regular watch and thus no cost is identified. On most vessels the deck officer on
watch processes the report as part of his routine watch standing duties.
There is no cost for radio equipment as this is the same as required by the Federal
Communication Commission (FCC), USCG and International Maritime Organization
(IMO) maritime regulations.
There are no other overhead or administrative expenses known to be incurred by
respondents.
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 annual cost to the Federal Government for processing the collection is
estimated as follows:
One-time Costs: None
Annual Costs:
$17,568. This is the estimated annual communication cost for the U.S. Coast Guard for
AMVER messages. Cost per message is estimated at $.60; total responses annually are
29,280.

Maximum Total Annual Cost to Federal Government: $17,568
15.

Explain the reasons for any program changes or adjustments reported in items 13 or
14 of OMB Form 83-I
The total number of U.S.-flag ships reporting to MARAD remains 183 since the last
Paperwork Reduction Act Submission three years ago. The amount of time required to
respond decreased.

16.

For collections of information whose results are planned lobe 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.
Information collected will not be published.

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.