ICR0009 Supporting Statement

Supporting Statement A
30 CFR Part 1220, OCS Net Profit Share Payment Reporting
OMB Control Number 1012-0009
Current Expiration Date: November 30, 2011

Terms of Clearance: None
General Instructions

A completed Supporting Statement A must accompany each request for approval of a collection
of information. The Supporting Statement must be prepared in the format described below, and
must contain the information specified below. If an item is not applicable, provide a brief
explanation. When the question “Does this ICR contain surveys, censuses, or employ statistical
methods?” is checked "Yes," then a Supporting Statement B must be completed. The Office of
Management and Budget (OMB) reserves the right to require the submission of additional
information with respect to any request for approval.
Specific Instructions

A. Justification
1. Explain the circumstances that make the collection of information necessary. Identify
any legal or administrative requirements that necessitate the collection.
OMB Control Number and Title Change
After the Secretary of the Interior established the Office of Natural Resources Revenue (ONRR,
the former Minerals Revenue Management (MRM), a program under the Minerals Management
Service (MMS)) on October 1, 2010, OMB approved a new series number for ONRR and
renumbered our ICRs. The formerly approved OMB Control Number for this information
collection request (ICR) was “1010-0073,” and the new OMB Control Number is “1012-0009.”
Also, the previous title of this ICR was “30 CFR Part 220, OCS Net Profit Share Payment
Reporting,” and now the revised title of this ICR is “30 CFR Part 1220, OCS Net Profit Share
Payment Reporting.” This ICR affects only oil and gas leases on submerged Federal lands on
the OCS.
General Information
The Secretary of the U. S. Department of the Interior (Secretary) is responsible for collecting
royalties from lessees who produce minerals from leased Federal and Indian lands and the Outer
Continental Shelf (OCS). The Secretary is required by various laws to manage mineral resources
production on Federal and Indian lands and the OCS, collect the royalties and other mineral
revenues due, and distribute the funds collected in accordance with those laws. The ONRR
(formerly MRM of MMS) performs the royalty management functions and assists the Secretary
in carrying out the Department’s responsibility.

When a company or an individual enters into a lease to explore, develop, produce, and dispose of
minerals from Federal and Indian lands and the OCS, that company or individual agrees to pay
the lessor a share in an amount or value of production from the leased lands. The lessee is
required to report various kinds of information to the lessor relative to the disposition of the
leased minerals. Such information is generally available within the records of the lessee or
others involved in developing, transporting, processing, purchasing, or selling of such minerals.
Specific ICR Information
Public laws pertaining to mineral leases include Mineral Leasing Act of 1920 (30 U.S.C. 1923);
Outer Continental Shelf Lands Act of 1953 (43 U.S.C. 1353); Public Law 97-451—Jan. 12, 1983
(Federal Oil and Gas Royalty Management Act of 1982 [FOGRMA]); and Public Law 104185—Aug. 13, 1996 (Federal Oil and Gas Royalty Simplification and Fairness Act of 1996
[RSFA]), as corrected by Public Law 104-200—Sept. 22, 1996. These laws are posted at
http://www.onrr.gov/Laws_R_D/PublicLawsAMR.htm.
Title 30 CFR part 1220 covers the net profit share lease (NPSL) program and establishes
reporting requirements for determining the net profit share base under §1220.021 and calculating
net profit share payments due the Federal Government for the production of oil and gas from
leases under §1220.22. The ONRR collects and uses this information to determine all allowable
direct and allocable joint costs and credits under §1220.011 incurred during the lease term,
appropriate overhead allowance permitted on these costs under §1220.012, and allowances for
capital recovery calculated under §1220.020. The ONRR also collects this information to ensure
royalties or net profit share payments are accurately valued and appropriately paid.
NPSL Bidding System
To encourage exploration and development of oil and gas leases on submerged Federal lands on
the Outer Continental Shelf (OCS), the Bureau of Ocean Energy Management, Regulations, and
Enforcement (BOEMRE, the former Offshore Energy and Minerals Management [OEMM] of
Minerals Management Service [MMS]) promulgated regulations at 30 CFR part 260—Outer
Continental Shelf Oil and Gas Leasing. Also, BOEMRE promulgated specific implementing
regulations for the NPSL bidding system at §260.110(d). The BOEMRE, formerly
OEMM/MMS, established the NPSL bidding system to balance a fair market return to the
Federal Government for the lease of its public lands with a fair profit to companies risking their
investment capital. The system provides an incentive for early and expeditious exploration and
development and provides for sharing the risks by the lessee and the Federal Government. The
NPSL bidding system incorporates a fixed capital recovery system as a means through which the
lessee recovers costs of exploration and development from production revenues, along with a
reasonable return on investment.
NPSL Capital Account
The Federal Government does not receive a profit share payment from an NPSL until the lessee
shows a credit balance in its capital account; that is, cumulative revenues and other credits
exceed cumulative costs. Lessees multiply the credit balance by the net profit share rate (30 to

2

50 percent), resulting in the amount of net profit share payment due the Federal Government.
The ONRR requires lessees to maintain an NPSL capital account for each lease under
§1220.010, which transfers to a new owner when sold. Following the cessation of production,
lessees are also required to provide either an annual or a monthly report to the Federal
Government, using data from the capital account until the lease is terminated, expired, or
relinquished.
NPSL Inventories
The NPSL lessees must notify ONRR of their intent to perform an inventory and file a report
after each inventory of controllable materiel under §1220.032.
NPSL Audits
When non-operators of an NPSL call for an audit, they must notify ONRR. When ONRR calls
for an audit, the lessee must notify all non-operators on the lease. These requirements are
located at §1220.033.
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. Be specific. If this collection is a form or a
questionnaire, every question needs to be justified.
Under the NPSL bidding system, a notice of an OCS lease sale is published in the Federal
Register with a net profit share rate and a capital recovery factor (CRF) established for each tract
within the sale. The regulations allow the lessee to inflate certain costs by multiplying those
costs by the CRF. However, the calculation of this allowance differs by time period, within and
outside the capital recovery period. The capital recovery period begins with the issue date of the
lease and ends when one of the following occurs:
(1) The lessee completes the last well on the first platform specified in the
development and production plan;
(2) The balance in the capital account changes from a debit to a credit; or
(3) The lessee chooses to terminate the capital recovery period.
During the capital recovery period, the lessee calculates a cost base consisting of
allowable direct and allocable joint costs plus a 4-percent overhead allowance, less
production revenues and other credits received during the month. This cost base is
multiplied by the CRF established for the lease, resulting in the allowance for capital
recovery. This allowance can be deducted from current revenue and other credits within
the capital account. For example, if the CRF is 0.5, the lessee effectively adds another
50 percent of all allowable costs to the capital account. Once the capital recovery period
is closed, it cannot be re-opened, and the lessee no longer is eligible for the allowance for

3

capital recovery. However, the lessee then changes the overhead allowance to 10
percent.
The lessee is required to maintain an NPSL capital account. The capital account balance
represents the cumulative total of all costs and credits received over the life of the lease.
When companies enter into NPSL agreements, they agree to submit reports required by
§1220.031. There are no specific formats required for these reports. The ONRR uses the
data submitted in these reports to verify costs, revenues or credits, and net profit share
payments due. Not collecting this information would limit the Secretary’s ability to
discharge fiduciary duties and may also result in the inability to confirm the accurate
royalty value.
All information submitted is taken directly from the lessee's own records. No unique
information is required. Six leases, all in the Gulf of Mexico, are producing leases for
which monthly reports are submitted. Currently, five of these six producing leases are
profitable.
The last OCS lease sale involving NPSLs was in August 1983. Leases issued from 1980 through
1983 totaled 209, including 14 offshore Alaska leases and 51 offshore Atlantic leases. Of the
209 leases, 203 have terminated, expired, or been relinquished; and 6 are still active.
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, e.g., permitting electronic submission of responses,
and the basis for the decision for adopting this means of collection. Also describe any
consideration of using information technology to reduce burden and specifically how
this collection meets GPEA requirements.
The ONRR (formerly MMS’s MRM) program is moving to fully implement the Government
Paperwork Elimination Act (GPEA). However, our GPEA Plan indicates that the use of
information technology is not practicable for this information collection because of the small
number of lessees and the variety and complexity of computer programs used by the reporting
companies.
Currently, only six lessees report monthly. Because of the limited number of leases involved and
lessee respondents (less than 10) and their differing and complex system designs, ONRR has not
attempted to interface the companies' systems with ONRR systems. Therefore, at this time,
submission of information electronically is not practicable; nor is e-mail an option because an
original signature is required.
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.
Reports and other information are unique for each individual lease. Each lease is numbered for
identification, and a separate report must be filed for each lease. No other Federal Government

4

agency collects this information.
5. If the collection of information impacts small businesses or other small entities, describe
any methods used to minimize burden.
This collection of information does not have a significant economic effect on a substantial
number of small entities.
Due to the extremely difficult and expensive processes associated with deepwater exploration
and drilling, few small businesses were involved in the initial lease acquisitions. However, a few
small businesses now own leases through purchases from larger companies or operate leases
through farm-outs. Some of these purchased or farm-out properties may include NPSL lease
terms. There are no special provisions for mitigating reporting requirements for small businesses
in these circumstances; however, ONRR assists small entities by maintaining regular and routine
contact with these lessees as they file their reports. In addition, ONRR provides toll-free
telephone assistance to lessees, answering their questions regarding NPSL regulations and
responding to other concerns related to NPSLs. Since NPSLs are ongoing and require constant
monitoring, numerous contacts have been developed and maintained over many years, providing
timely opportunities to discuss any concerns regarding the information collected.
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.
The ONRR is required by law to gather this information. Title I of the Federal Oil and Gas
Royalty Management Act of 1982 (30 U.S.C. 1711) requires that the Secretary “. . . establish a
. . . system to provide the capability to accurately determine oil and gas royalties, interest, fines,
penalties, fees, deposits, and other payments owed and to collect and account for such amounts
in a timely manner.” By regulation, the lessee must submit either annual or monthly reports
related to NPSLs. Less frequent collection of information places the lessee in noncompliance
with the regulations and may also result in loss of net profit share payments to the Federal
Government.
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;

Title 30 CFR part 1220 requires that respondents submit annual, monthly, and on occasion
inventory reports for NPSL. Respondents submit annual reports until the account has paid out.
When accounts are paid out, respondents are required to report monthly capital account plus
Form MMS-2014, Report of Sales and Royalty Remittance (ICR 1012-0004, formerly 10100139). Respondents also submit an inventory report on occasion or every 3 years.

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*

requiring respondents to prepare a written response to a collection of information in
fewer than 30 days after receipt of it;

Not applicable in this collection.
*

requiring respondents to submit more than an original and two copies of any
document;

Not applicable in this collection.
*

requiring respondents to retain records, other than health, medical, government
contract, grant-in-aid, or tax records, for more than three years;

Not applicable in this collection.
*

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;

Not applicable in this collection.
*

requiring the use of a statistical data classification that has not been reviewed and
approved by OMB;

There are no special circumstances with respect to 5 CFR 1320.5(d)(2)(v) through (viii) as the
collection is not a statistical survey and does not use statistical data classification.
*

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 of data with other agencies for compatible confidential use; or

This collection does not include a pledge of confidentiality not supported by statute or
regulation.
*

requiring respondents to submit proprietary trade secrets 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.

This collection does not require proprietary, trade secret, or other confidential information not
protected by agency procedures. Information is protected in accordance with standards
identified in Item 10 below.

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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 in response to the PRA
statement associated with the collection over the past three years, 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.
As required in 5 CFR 1320.8(d), ONRR published a 60-day notice in the Federal Register on
March 25, 2011 (76 FR 16816). We received no comments in response to the Federal Register
notice.
Our outreach to three producers showed that none of the contacts had read and/or remembered
the published Federal Register notice on the extension of this ICR. We sent copies of the notice
via electronic mail soliciting comments from the following three producers and received no
comments:
Mr. Bill Arthur, Production Accountant, MC Offshore Petroleum, LLC; 1800 West Loop South,
Suite 1900; Houston, TX 77027; (832) 767-4700, ext. 102
Ms. Joanne Vacek, Production Analyst, Energy Resources Technology GOM, Inc.;
400 North Sam Houston Parkway East, Suite 600; Houston, TX 77060; (281) 848-6698
Ms. Mary Holman, ExxonMobil Corporation; P.O. Box 2024; Houston, TX 77252-2024; (713)
680-6134
The ONRR and lessees find it helpful to maintain regular and routine contact on these leases as
the lessees file their reports. In addition, ONRR provides toll-free telephone assistance to
lessees, answers their questions regarding NPSL regulations, and responds to lessees’ other
concerns related to NPSLs. Since NPSL leases are ongoing and require constant monitoring,
numerous contacts have been developed and maintained over many years, providing timely
opportunities to discuss any concerns regarding the information collected.

7

9. Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
The ONRR will not provide any payment or gift to respondents in this collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.
Commercial or financial information provided to ONRR, relative to minerals removed from
Federal and Indian leases, may be proprietary. Trade secrets and proprietary and other
information are protected in accordance with standards established by the Federal Oil and Gas
Royalty Management Act of 1982, as amended (30 U.S.C. 1733), and the Freedom of
Information Act (5 U.S.C. 552(b)(4)) and Department regulations (43 CFR 2).
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.
The collection does not include sensitive or private questions.
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 hour 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.

*

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 under
“Annual Cost to Federal Government.”

There are six respondents (Federal net profit share oil and gas OCS lessees). Based on current

8

data, we estimate the average number of annual responses is 110, and the total annual burden is
1,046 hours, for 1,040 reporting hours and 6 recordkeeping hours. We have not included in our
estimates certain requirements performed in the normal course of business and considered usual
and customary.
Summary of Information Collections
Information Collections
(and 30 CFR Reference*)
1. Maintain NPSL capital
account
(1220.010)
2. Reporting and Payment
requirements
(1220.031(a, c, d, e))

(1220.031(b))
3. Inventorying controllable
materiels
(1220.032(b))
4. Auditing NPSL lease
(1220.033(b)(1) & (2)
Subtotals
5. Recordkeeping
(1220.030)

Requirement to
Respond
Mandatory

Frequency
of
Response
Monthly

Mandatory

Mandatory

Mandatory

Mandatory

Number
of Annual
Responses
1

Annual
Burden
Hours
1

Annually &
on
occasion
Monthly
On
occasion

13

73

72
6

936
6

On
occasion

12

24

104

1,040

6

6

110

1,046

As
requested
TOTAL
*See Burden Breakdown table for complete citation.

We based our cost estimates for industry on the expectation that an accountant will perform all
requirements. We estimate the total annual reporting burden is 1,046 hours. Based on a cost
factor of $46 per hour for industry accountants, we estimate the total annual cost to industry is
$48,116 [$46 x 1,046 hours = $48,116]. The respondents submit their responses annually,
monthly, and on occasion.
We used tables from the Bureau of Labor Statistics (BLS) to estimate the hourly cost for industry
accountants. These statistics are located at http://www.bls.gov/bls/wages.htm. Based on BLS
May 2010 National Occupational Employment and Wage Estimates for industry accountants, we
estimate that the hourly cost factor would be $46 = [$33.15 [mean hourly wage] x 1.4 benefit
cost factor = $46.41, rounded to $46]. We added a multiplier of 1.4 (based on BLS News
Release USDL 11-0849 dated June 8, 2011, at http://www.bls.gov/news.release/pdf/ecec.pdf) for
benefits.

9

The following table shows the estimated burden hours by CFR section and paragraph.
SECTION A.12 BURDEN HOUR DETAIL
Citation
30 CFR 1220

Reporting & Recordkeeping
Requirement

Hour
Burden

Number of Annual
Responses

Annual
Burden Hours

PART 1220—ACCOUNTING PROCEDURES FOR DETERMINING NET PROFIT SHARE PAYMENT
FOR OUTER CONTINENTAL SHELF OIL AND GAS LEASES

§1220.010 NPSL capital account.
1220.010(a)

(a) For each NPSL tract, an NPSL
capital account shall be established
and maintained by the lessee for
NPSL operations . . .

1

1

1

6

6

1

1

1

13

721

936

§1220.030 Maintenance of records.
1220.030(a)
and (b)

(a) Each lessee . . .shall establish
and maintain such records as are
necessary . . .

1

§1220.031 Reporting and payment requirements.
1220.031(a)

1220.031(b)

1220.031(c)

1220.031(d)

1220.031(e)

(a) Each lessee subject to this part
shall file an annual report during the
period from issuance of the NPSL
until the first month in which
production revenues are credited to
the NPSL capital account . . .
(b) Beginning with the first month in
which production revenues are
credited to the NPSL capital
account, each lessee . . .shall file a
report for each NPSL, not later than
60 days following the end of each
month . . .
(c) Each lessee subject to this Part
1220 shall submit, together with the
report required . . .any net profit
share payment due . . .
(d) Each lessee . . .shall file a report
not later than 90 days after each
inventory is taken . . .
(e) Each lessee . . .shall file a final
report, not later than 60 days
following the cessation of production
...

Burden hours covered under 1220.031(b).

8

6

48

4

6

24

1

6

6

§1220.032 Inventories.
1220.032(b)

(b) At reasonable intervals, but at
least once every three years,
inventories of controllable materiel
shall be taken by the lessee. Written
notice of intention to take inventory
shall be given by the lessee at least
30 days before any inventory is to be
taken so that the Director may be
represented at the taking of inventory
...

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Citation
30 CFR 1220

Reporting & Recordkeeping
Requirement

Hour
Burden

Number of Annual
Responses

Annual
Burden Hours

2

6

12

2

6

12

§1220.033 Audits.
1220.033(b)(1)

1220.033(b)(2)

1220.033(e)

(b)(1) When nonoperators of an
NPSL lease call an audit in
accordance with the terms of their
operating agreement, the Director
shall be notified of the audit call . . .
(b)(2) If DOI determines to call for an
audit, DOI shall notify the lessee of
its audit call and set a time and
place for the audit . . .The lessee
shall send copies of the notice to the
nonoperators on the lease . . .
(e) Records required to be kept
under § 1220.030(a) shall be made
available for inspection by any
authorized agent of DOI . . .

TOTAL BURDEN
1

The Office of Regulatory Affairs determined
that the audit process is exempt from the
Paperwork Reduction Act of 1995 because
MMS staff asks non-standard questions to
resolve exceptions.
110

1,046

(6 NPSL reports x 12 months = 72 reports)

13. Provide an estimate of the total annual non-hour cost burden to respondents or
recordkeepers resulting from the collection of information. (Do not include the cost of
any hour burden already reflected in item 12.)
*

The cost estimate should be split into two components: (a) a total capital and startup 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 (including filing fees paid for form processing). 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 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

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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 ONRR has identified no non-hour cost burdens for this collection of information.
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.
To analyze and review the information, the Federal Government spends an average of ½ hour for
each reporting burden hour spent by respondents. The total estimated Federal Government time
burden is 523 hours [1,046 respondent burden hours x ½ hour = 523 hours], based on time or
effort needed to verify costs, revenues or credits, and net profit share payments due. Most of the
requirements are performed by a Federal Government auditor paid at the Grade 12 level. Based
on the United States 2011 General Schedule, Grade 12, Step 5, pay scale for a Government
auditor in the Denver, Colorado metropolitan area, the estimated hourly labor cost is $60 per
hour [$40.10 x 1.5 benefit cost factor = $60.15, rounded to $60]. We added a multiplier of 1.5
[based on BLS News Release USDL 11-0849 dated June 8, 2011, at
http://www.bls.gov/news.release/pdf/ecec.pdf] for benefits.
The annual cost to the Federal Government for verification and reporting of NPSL leases is
calculated as follows:
1,046 hrs x ½ hour = 523 hrs x $60 per hour = $31,380).
15. Explain the reasons for any program changes or adjustments in hour or cost burden.
(a) Annual Hour Burden.
Currently Approved
OMB Burden Hour
Inventory

Program Change
Estimated
Burden Hours

Program Adjustment
Estimated
Burden Hours

Total
Estimated
Burden Hour

1,046

0

0

1,046

There is no program change or adjustment for this information collection.
(b) Annual Cost Burden: There is no annual cost burden to report.

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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 ONRR will not publish the data.
17. If seeking approval not to display the expiration date for OMB approval of the
information collection, explain the reasons that display would be inappropriate.
This collection concerns regulatory requirements. There is no form associated with this ICR.
The ONRR will display the OMB approval expiration date on all appropriate material.
18. Explain each exception to the topics of the certification statement identified in
“Certification for Paperwork Reduction Act Submissions.”
To the extent that the topics apply to this collection of information, we are not making any
exceptions to the “Certification for Paperwork Reduction Act Submissions.”

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