1625-0072_SS_r1_2011

1625-0072

Supporting Statement

for

Waste Management Plans, Refuse Discharge Logs,

Letters of Instruction for Certain Persons-in-Charge (PIC) and Great Lakes Dry Cargo Residue Recordkeeping

A. Justification.

1) Circumstances that make the collection of information necessary.

This collection is a combination of the following four approved information requests.

• (a) Waste Management Plans.

• (b) Refuse Discharge Logs.

• (c) Letter of Instruction for Persons-in-Charge (PIC) on Uninspected Vessels.

• (d) Dry Cargo Residue (DCR) Recordkeeping

(a) and (b) The International Convention for the Prevention of Pollution from Ships, 1973, as modified by the Protocol of 1978 (MARPOL 73/78) and codified in 33 USC §§ 1901-1909 requires that the Secretary of the Department in which the Coast Guard is operating to prescribe regulations for refuse record books and waste management plans. These statutory provisions are addressed in 33 CFR Part 151.55 and 151.57 respectively.

(c) The letter of instruction’s contents should verify the PIC’s credentials, stating that the holder has received sufficient formal instruction from the owner, operator, or agent of the vessel, as required by 33 CFR 155.710(e) (2) and 155.715.

(d) DCR recordkeeping applies to Great Lakes vessels that discharge bulk dry cargo residue, per 33 CFR 151.55.

This information collection supports the following strategic goals:

Department of Homeland Security

• Prevention

• Protection

U.S. Coast Guard

• Safety

• Protection of the Natural Resources

Marine Safety, Security and Stewardship Directorate (CG-5)

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

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

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

(a) Vessel operators of U.S. oceangoing ships, 40 feet or more in length, engaged in commerce or equipped with galleys and berths are required to develop waste management plans. The purpose of a waste management plan is to prevent the discharge of waste, including plastics, into water. These plans are used to determine whether a ship is in compliance with MARPOL 73/78 Annex V.

(b) Vessel operators of U.S. oceangoing ships of 400 gross tons or more, and U.S. ships involved on international voyages carrying 15 passengers or more, are required to maintain refuse record books. Refuse record books (discharge logs) are used to document waste discharges from the ships. These are also used to determine whether a ship is in compliance with MARPOL 73/78 Annex V. If noncompliance is indicated, these records may serve as evidence that a ship has violated discharge restrictions.

(c) To ensure that fuel transfer competency standards are met, all persons in charge (PICs) on un-inspected vessels must carry a Letter of Instruction if they do not hold a Coast Guard issued license or properly endorsed Merchant Mariner’s Document.

(d) DCR recordkeeping requires foreign carriers conducting bulk dry cargo operations on the U.S. waters of the Great Lakes, and U.S. carriers conducting those operations anywhere on the Great Lakes, to record data about:

• Cargo handled;

• Shoreside facilities involved in loading and unloading;

• Control measures used by the facility or vessel to reduce the accumulation of DCR (and hence the volume of DCR needing discharge);

• Time needed to implement control measures;

• Estimated volume of DCR resulting from each loading or unloading; and

• Date, time, vessel location, and speed during each discharge.

Carriers enter this data on a form (CG-33). The form is kept aboard the vessel for two years, and copies of the form are submitted to the Coast Guard each quarter.

This data gives the Coast Guard a more comprehensive picture of what causes DCR accumulation, the conditions under which DCR is swept overboard, the volume of DCR being discharged into the Great Lakes, and the efficacy of control measures in reducing DCR accumulation and the volume of DCR discharges. This data is essential if the Coast Guard is to monitor and respond to future trends in Great Lakes DCR discharges. For example, as we announced in our May 2008 NPRM, we intend to begin a new rulemaking that would consider requiring the use of control measures. This information collection will provide important data on the efficacy of any control measures that carriers now voluntarily employ.

3) Consideration of the use of improved information technology.

(a) We believe that most waste management plans and related materials can be recorded electronically.

(b) and (c) Not applicable. To meet international treaty obligations and national compliance and enforcement requirements, the logs and Letter of Instruction must be maintain and available in written (i.e., non-electronic) format.

(d) We believe that most DCR recordkeeping can be recorded and sent electronically. Form CG-33 can be used to record, store, and report data electronically.

We estimate that 60% of the recordkeeping requirements can be done electronically. At this time, we estimate that 25% are done electronically.

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

There are no State or local regulations relating to this issue. No similar information collection is conducted by other Federal agencies. Similar information does not exist.

5) Methods to minimize the burden to small businesses if involved.

This information collection does not have an impact on small businesses or other small entities.

6) Consequences to the Federal program if collection were conducted less frequently.

(a) Written waste management plans ensure personnel responsible for the handling of ship generated refuse are aware of the garbage pollution regulations and that waste is handled aboard the ship in a consistent manner. If this information were not recorded, vessel personnel would be unfamiliar with waste handling procedures, which might result in the unintentional disposal of garbage in violation of the regulations. This information is a one-time requirement and revised whenever waste handling procedures are modified.

(b) This information is collected whenever applicable ships discharge garbage. If recordkeeping were required less frequently, the Coast Guard would not be able to use these records as an enforcement tool. Less frequent recordings of disposal/discharge operations would also hinder the Coast Guard’s ability to accurately evaluate the level of compliance among ships with MARPOL 73/78 Annex V discharge restrictions. Lastly, if the crew is not held accountable for documenting every disposal/discharge operation, the recordkeeping process will no longer be an effective tool to promote knowledge of discharge regulations and awareness of waste handling practices on the ship.

(c) If information was submitted or recorded less frequently, no assurance could be given that vessels are operating within the applicable requirements that ensure marine safety.

(d) If the DCR loading, unloading, or discharge operation data were recorded less frequently, the Coast Guard would expect the data to be less accurate, and this would reduce our ability to enforce compliance with the conditions under which DCR discharges are permitted in the Great Lakes, as well as our ability to monitor and respond to long term developments in DCR discharge practices.

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

This information collection is conducted in manner consistent with the guidelines in 5 CFR 1320.5(d)(2).

8) Consultation.

A 60-day Notice will be was published in the Federal Register to obtain public comment on this collection. (See [USCG-2010-xxxxx]; xxx, x, 2010; 75 FR xxxxx). The USCG has not received any comments on this information collection.

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

There is no offer of monetary or material value for this information collection.

10) Describe any assurance of confidentiality provided to respondents.

There are no assurances of confidentiality provided to the respondents for this information collection.

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

There are no questions of sensitive language.

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

The burden for each of the three aspects of this collection is contained in the following paragraphs and in Tables 12.1, 12.2, 12.3, 12.4. Table 12.5 provides a summation of the burden for all aspects of this collection. It should be noted that the applicability of each regulation is different, as described in paragraph 2. All hour burdens are for recordkeeping.

The burden associated with the Waste Management Plan portion of this collection is collection is reported in 12.1.

Table 12.1 - Waste Management Plans
	Universe of Potential Respondents	14,374
	# New Plans Developed Annually	217
	# Plans Modified Periodically	2,831
	Annual # of Respondents	3,048
	Annual # of Responses	3,048
	Clerical Effort/Response, New Plans (hrs)	1.25
	Clerical Hourly Rate	$33
	Management Effort/Response, New Plans (hrs)	1.25
	Management Hourly Rate	$84
	New Plan Hour Burden/Plan	2.5
	New Plan Cost Burden/Plan	$146
	Total New Plan Hour Burden	543
	Total New Plan Cost Burden	$31,736
	Clerical Effort/Response, Plan Modification (hrs)	0.5
	Clerical Hourly Rate	$33
	Management Effort/Response, Plan Modification (hrs)	0.5
	Management Hourly Rate	$84
	Plan Modification Hour Burden/Plan	1
	Plan Modification Cost Burden/Plan	$59
	Total Plan Modification Hour Burden	2,831
	Total Plan Modification Cost Burden	$165,614
	TOTAL BURDEN HOURS	3,374
	TOTAL BURDEN COST	$197,350

Notes on Table 12.1:

a. The Coast Guard estimates that these plans will be modified, on average, once every five years. The estimated number of responses is therefore 20 percent of the universe of potential respondents (number of vessels required to maintain a waste management plan.)

b. We estimate that, on average, five percent of the population consists of new vessels, requiring the creation of a new waste management plan.

c. The positions of management and clerical staff are analogous to a Lieutenant (O-3) and a GS-5, respectively. The rates shown are in accordance with the current edition of COMDTINST 7310.1 (series).

The burden associated with the Refuse Discharge Log portion of this collection is collection is reported in 12.2.

Table 12.2 - Refuse Discharge Logs
			Avg Annual # of	Avg Daily	Total #	Annual Hour Burden
	Vessel Type	# Vessels	Days in Operation	Entries	Entries	Per Vessel Type
	Commerical fishing vsls	139	330	1	45,870	3,823
	Freight Ship	170	330	2	112,200	9,350
	Industrial vsls	109	330	1	35,970	2,998
	MODUs	60	365	1	21,900	1,825
	OSVs	266	365	1	97,090	8,091
	Oil recovery vsls	44	330	1	14,520	1,210
	Passenger vsls	96	330	2	63,360	5,280
	Research vsls	5	200	1	1,000	83
	School Ship	8	200	1	1,600	133
	Tank Ship	68	330	2	44,880	3,740
	Towing Vessel	21	262	1	5,502	459
	Unclassified	21	200	1	4,200	350
	Manned Platforms	770	365	1	281,050	23,421
	TOTAL	1,777			729,142	60,763
				Cost/Hour		$84
	TOTAL NUMBER OF RESPONDENTS		1,777
	TOTAL NUMBER OF RESPONSES		729,142
	TOTAL ANNUAL HOUR BURDEN		60,763
	TOTAL ANNUAL COST BURDEN		$5,104,092

Notes on Table 12.2:

a. The Coast Guard estimates that each log entry will take no more than five minutes to complete.

b. The responsibilities of the individual making the log entry is commensurate with that of a Lieutenant (O-3). The wage rate shown is in accordance with the current edition of COMDTINST 7310.1 (series).

The burden associated with the PIC Letter of Designation portion of this collection is collection is reported in 12.3.

Table 12.3 - PIC Letter of Designation
	# Vessels Requiring PIC Designation		122
	# PICs On Board Each Vessel		2
	Total # PICs Holding Designation		244
	Estimated Annual Attrition Rate		30%
	Estimated # Replacement Letters Created		73
	Hour Burden per Designation Letter		0.167
	Total Hour Burden		12
	Wage Rate of Individual Creating Letter		$68
	Total Cost Burden		$830
	TOTAL NUMBER OF RESPONDENTS		73
	TOTAL NUMBER OF RESPONSES		73
	TOTAL ANNUAL HOUR BURDEN		12
	TOTAL ANNUAL COST BURDEN		$830

Notes on Table 12.3:

a. The Coast Guard estimates that each vessel will be required to maintain two designated PICs.

b. Because this collection is performed only once during an individual’s period of employment, the number of responses is assumed to match the rate of attrition (turnover), conservatively estimated at 30 percent.

b. The responsibilities of the individual creating the Letter of Designation is commensurate with that of a Lieutenant, Junior Grade (O-2). The wage rate shown is in accordance with the current edition of COMDTINST 7310.1 (series).

c. We estimate that each letter will take no more than 10 minutes to create.

The burden associated with the DCR recordkeeping portion of this collection is collection is reported in 12.4.

Table 12.4 Discharge Cargo Residue

U.S. Recordkeeping Burden:
	U.S. Respondents						55
	U.S. Clerical Responses						9,295
	U.S Master Response						1,320
	Clerical Effort/ Response (HR)						0.08
	Clerical Hourly Rate						$61
	Clerical Total Hours						775
	Master/Captain Hourly Rate						$115
	Master/Captain Total Hours						110
		Total Clerical Cost					$47,275
		Total Master/Captain Cost					$12,650
		Total Hour Burden					885
		Total Burden Cost					$59,925
Canadian Recordkeeping Burden:
	Canadian Respondents						33
	Canadian Clerical Responses						2,558
	Canadian Master Response						363
	Clerical Effort/ Response (HR)						0.08
	Clerical Hourly Rate						$61
	Clerical Total Hours						213
	Master/Captain Hourly Rate						$115
	Master/Captain Total Hours						30
		Total Clerical Cost					$12,993
		Total Master/Captain Cost					$3,450
		Total Hour Burden					243
		Total Burden Cost					$16,443
Non-Canadian Foreign Recordkeeping Burden:
	Non-Canadian Foreign Respondents						186
	Non-Canadian Foreign Clerical Responses						2,046
	Non - Canadian Master Response						186
	Clerical Effort/ Response (HR)						0.08
	Clerical Hourly Rate						$61
	Clerical Total Hours						171
	Master/Captain Hourly Rate						$115
	Master/Captain Total Hours						16
		Total Clerical Cost					$10,431
		Total Master/Captain Cost					$1,840
		Total Hour Burden					187
		Total Burden Cost					$12,271
Total DCR Recordkeeping Burden:
	Total Respondents						274
	Total Responses						15,768
	Total Recordkeeping Hours						1,159
	Total Master/Captain Hours						156
			TOTAL BURDEN HOURS				1,315
			TOTAL BURDEN COST				$88,639

Notes on Table 12.4:

a. The Coast Guard estimates that each Clerical Recordkeeping Entry will take .08 hours or 5 minutes to complete and each Master/Captain Certification will take .08 hours or 5 minutes to complete.

b. The responsibilities of the individuals making the recordkeeping entry and certification are commensurate with that of GS-11 and GS-15 respectively. The wage rate shown is in accordance with the current edition of COMDTINST 7310.1 (series).

The summation of the four aspects of this collection is provided in the following table:

Table 12.4 - Summation of Collection Burden
		Waste Management	Refuse Discharge	PIC Designation	Dry Cargo Residue	GRAND
		Plans	Logs	Letters	Recordkeeping	TOTALS
	Total # Respondents	3,048	1,777	73	274	5,172
	Total # Responses	3,048	729,142	73	15,768	748,031
	Total Burden Hours	3,374	60,763	12	1,315	65,464
	Total Burden Cost	$197,350	$5,104,092	$830	$88,639	5,390,910

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

There are no capital, start-up or maintenance costs associated with this information collection.

14) Estimates of annualized Federal Government costs.

(a), (b), (c): This collection is for recordkeeping purposes only, and the public need not submit the information for review to the Coast Guard. Instead, Coast Guard personnel review these documents during periodic inspections, random boardings, and post-casualty, in conjunction with other vessel documentation and equipment. The incremental burden to the Government is negligible, and therefore not herein calculated.

(d): For the DCR recordkeeping collection data, the Coast Guard would review records during periodic vessel inspections, random boarding’s, and post-casualty, in conjunction with other vessel documentation and equipment. In addition, we would analyze reported data as part of the data collection and analysis work to be performed in conjunction with the proposed new rulemaking to consider requiring the use of DCR control measures on the Great Lakes. The incremental burden to the Government is negligible, and therefore not herein calculated.

15) Explain the reasons for the change in burden.

The change (i.e., decrease) in hour burden is an ADJUSTMENT due to a change to the vessel population. The Coast Guard used the Marine Information for Safety and Law Enforcement (MISLE) database for estimating vessel populations, which allows us for a more accurate estimate the vessels impacted by this COI. The reporting and recordkeeping requirements and the methodology for calculating burden remain unchanged.

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

This information collection will not be published for statistical purposes.

17) Explain the reasons for seeking not to display the expiration date for OMB approval of the information of collection.

The Coast Guard will display the expiration date for OMB approval of this information collection.

18) Explain each exception to the certification statement.

The Coast Guard does not request an exception to the certification of this information collection.

B. Collection of Information Employing Statistical Methods.

This information collection does not employ statistical methods.

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