Final Rule SuptStmt (11-2011)

2011 SUPPORTING STATEMENT

MARKETING ORDER ADMINISTRATION BRANCH

ONIONS GROWN IN CERTAIN DESIGNATED COUNTIES IN IDAHO, AND MALHEUR COUNTY, OREGON

OMB NO. 0581-NEW

(Final Rule)

NOTE TO REVIEWER: This collection was inadvertently overlooked in submitting for the Proposed Rule and is now being submitted as the Final Rule. These forms are currently approved under the Generic Vegetable and Specialty Crops collection, 0581-0178. The Committee developed a recommendation that would necessitate changes to two forms and cause burden to increase on the other form due to the number of handlers who would be required to submit to the Committee. Upon approval, AMS will make a request to OMB to merge this package into the currently approved Generic Vegetable and Specialty Crops collection..

1. JUSTIFICATION

   1. EXPLAIN THE CIRCUMSTANCES THAT MAKE THE COLLECTION OF INFORMATION NECESSARY. IDENTIFY ANY LEGAL OR ADMINISTRATIVE REQUIREMENTS THAT NECESSITATE THE COLLECTION.

Federal marketing orders are authorized by the Agricultural Marketing Agreement Act of 1937 (7 U.S.C. 601-674; Act). This legislation permits regulation of certain agricultural commodities for the purpose of providing orderly marketing conditions in interstate and intrastate commerce and improving financial returns to producers. The Act provides in section 608d(1) that information necessary to determine the extent to which an order has effectuated the declared policy of the Act shall be furnished at the request of the Secretary of Agriculture (Secretary).

Marketing orders become effective only after public hearings are held in accordance with formal rulemaking procedures specified by the Act. Orders can authorize the issuance of grade, size, quality, maturity, inspection requirements, pack and container requirements, and pooling and volume regulations. Some also provide authority for research and development, including paid advertising. Pursuant to section 608e(1) of the Act, certain grade and condition requirements are imposed on commodities imported into the United States for which marketing orders regulate domestic production. These programs, which are created at the request of producers, impose regulations on handlers who place their product into commercial channels.

One of the 28 active Federal marketing orders regulates onions grown in designated counties in Idaho, and Malheur County, Oregon. This marketing order, which became effective in 1957, is administered by the 11-member, Parma, Idaho-based Idaho-Eastern Oregon Onion Committee (Committee) under the U.S. Department of Agriculture’s (USDA) supervision and requires inspection on all onion lots handled pursuant to the order to determine whether the lot meets grade, size, quality and maturity standards.

This information collection is necessary for the Secretary and the Committee to monitor and enforce adherence to the regulations of the marketing order.

2. INDICATE HOW, BY WHOM, HOW FREQUENTLY, 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.

Marketing orders, along with the rules and regulations issued thereunder, authorize the Committee to collect certain information from handlers and producers (7 CFR Part 900). As a convenience to onion handlers and producers who are required to submit this information, the Agriculture Marketing Service (AMS) and the Committee have created forms as a means for providing the requested information. These forms require the minimum information necessary to effectively carry out the requirements of the marketing order.

The Committee’s forms are contained in the Generic Vegetable and Specialty Crops package (OMB No. 0581-0178), which was approved for three-year renewal by OMB on March 17, 2011. While the package was in review channels, the Committee, on January 20, 2011, developed a recommendation that would necessitate changes to two of its forms and cause another’s burden to increase due to the number of handlers who could be required to submit it to the Committee. The proposed amendment would revise § 958.328(e) of the order’s handling regulation to permit the shipment of special purpose, “experimental” onions without regard for minimum grade, size, maturity, pack and inspection requirements currently prescribed under paragraphs (a), (b), and (c) of § 958.328. Handlers would use the following and currently existing forms to indicate whether their onion lot is for special purposes and, as a result, would be exempt from mandatory inspection:

Order No. 958 - Idaho/Oregon Onions:

1. Application to Make Special Purpose Shipments – Certificate of Privilege: FV-34 (§§ 958.56 and 958.328): Commodities that are shipped to the fresh market must meet certain requirements in grade, size, quality, maturity, pack, container, and inspection. The same commodities shipped to other outlets are exempt from these requirements, provided that they meet certain safeguards, one of which is a certification that a commodity shipped to an exempt outlet will not enter fresh market channels. To receive this exemption, a handler must apply to the Committee and acquire this certificate permitting each such shipment. The Committee uses this form to verify compliance with these requirements.

2. Onion Diversion Report: FV-35 (§§ 958.56 and 958.180): Handlers use this form to report to the Committee shipments of onions that were diverted from fresh market channels. The Committee uses this information to verify that only authorized outlets are used.

3. Special Purpose Shipment Receiver Certification: FV-36 (§§ 958.56 and 958.328): Handlers and receivers use this form to report to the Committee on shipments made under Certificates of Privilege to special purpose or exempt outlets. This information is used by the Committee for compliance 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, 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.

Upon approval, these forms will be used to submit information directly to the Committee that administers the marketing order for onions produced in designated counties in Idaho and Malheur County, Oregon. The Committee is not part of a Federal agency, but is an industry commodity board that operates under Federal authority and oversight.

The availability and submission of forms electronically is at the discretion of the Committee. Currently, all Committee forms are transmitted by fax or postage mail.

The Committee periodically reviews its forms and information collection processes to ensure that they are understood by industry members, are easy to complete, and place as small a burden as possible on the respondents.

4. DESCRIBE EFFORTS TO IDENTIFY DUPLICATION. SHOW SPECIFICALLY WHY ANY SIMILAR INFORMATION ALREADY AVAILABLE CANNOT BE USED OR MODIFIED FOR USE FOR THE PURPOSE(S) DESCRIBED IN ITEM 2 ABOVE.

Reports and forms are periodically reviewed to avoid unnecessary duplication of information collection by industry and public sector agencies. At the present time, there is no duplication between Federal agencies.

4. IF THE COLLECTION OF INFORMATION HAS SIGNIFICANT IMPACT ON A SUBSTANTIAL NUMBER OF SMALL BUSINESSES OR OTHER SMALL ENTITIES (ITEM 15 OF THE PAPERWORK REDUCTION ACT SUBMISSION FORM), DESCRIBE THE METHODS USED TO MINIMIZE BURDEN.

Information collection requirements have been reduced to the minimum requirements of the marketing order. Forms require only a minimal amount of information, which can be supplied without data processing equipment or a trained statistical staff. The primary sources of data used to complete the forms are routinely used in all business transactions. Thus, the information collection and reporting burden is relatively small, and requires the same reporting requirements for all handlers and receivers. Essentially all of the 35 handlers who would complete the forms are small businesses. The information collection does not significantly disadvantage any handler or receiver that is smaller than industry average.

4. 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.

If this information collection was not conducted, not only would the Secretary lose his ability to administer the order, but the Committee would be unable to monitor industry compliance with the inspection mandate and would miss an opportunity to build new markets for small, mixed-color onions packaged in one-pound bags. Under existing regulations, such onions would not conform to the requirements of the U.S. No. 1 grade standard.

4. 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 3 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 OF 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.

There are no such special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.6.

4. 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.

A 60-day notice was imbedded in a Proposed Rule that was published in the Federal Register on June 21, 2011 (Vol. 76, No. 119, page 35997-36000), which invited comments from interested persons through August 22, 2011. No comments were received, thus no changes were necessary to the rule.

• 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 3 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 Committee meets throughout the year to assess the marketing order’s regulatory and informational needs. The Committee assesses the type of information that is collected, keeps close contact with industry representatives and trade associations to ensure their utmost efficiency, and endeavors to consult with representatives from whom the information is to be obtained at least every three years. In addition, notices of Committee meetings are sent to all those associated with the respective industry, and any concerns regarding onion issues are welcomed. Use of these forms has been discussed with the following Committee managers and their staff:

Idaho-Eastern Oregon Onion Committee, Parma, Idaho; Manager, Candi Fitch; Phone (208) 722-5111.

U.S. Department of Agriculture, Agricultural Marketing Service, Fruit and Vegetable Programs, Marketing Order Administration Branch, Portland, OR; Marketing Specialists, Barry Broadbent and Gary Olson; Phone (559) 487-5901

4. EXPLAIN ANY DECISION TO PROVIDE PAYMENT OR GIFT TO RESPONDENTS, OTHER THAN REMUNERATION OF CONTRACTORS OR GRANTEES.

Respondents are not provided with gifts or payments for providing information.

4. DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO RESPONDENTS AND THE BASIS FOR THE ASSURANCE IN STATUTE, REGULATION, OR AGENCY POLICY.

Section 608(d) of the Act provides that information acquired will be kept confidential. Reports submitted to the Committee are accessible only by the Committee managers and staff, AMS field office employees, and certain USDA employees in Washington, D.C. Committee members have access to handler reports and assessment records for the purpose of administering compliance with the Orders, and determining assessments, but are under strict orders to maintain the confidentiality of this information by securing these records under lock and key. Committee staff is aware of the penalties for violating confidentiality requirements. Forms, such as ballots, which request confidential information, contain statements that the information will be held in strict confidence.

4. PROVIDE ADDITIONAL JUSTIFICATION FOR ANY QUESTIONS OF A SENSITIVE NATURE, SUCH AS SEXUAL BEHAVIOR AND ATTITUDE, 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).

Questions of a sensitive nature are not included on any form in this information collection.

4. 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 OTHERWISE 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 DIFFERENCE 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.

The number of respondents required to file forms is 60 and is estimated based on records kept by the Committee that track handlers regulated under the marketing order. See AMS-71 spreadsheet for breakout.

• 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.

See AMS-71 spreadsheet for breakout of burden.

• PROVIDE ESTIMATES OF ANNUALIZED COST TO RESPONDENTS FOR THE HOUR BURDENS FOR COLLECTIONS OF INFORMATION, IDENTIFYING AND USING APPROPRIATE WAGE RATE CATEGORIES.

The respondents’ estimated annual cost of providing information to the Committee using these three forms is $10,802.11. This total has been estimated by multiplying 347 total burden hours by $31.13, the national mean hourly wage of Farm, Ranch, and Other Agricultural Managers, according to the U.S. Department of Labor Statistics. (National Compensation Survey: Occupational Employment and Wages, May 2009; http://bls.gov/oes/current/oes119011.htm.)

4. 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, PREPARATION 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, MAKE: (1) PRIOR TO OCTOBER 1, 1995, (2) TO ACHIEVE REGULATORY COMPLIANCE WITH REQUIREMENTS NOT ASSOCIATED WITH THE INFORMATION COLLECTION OR KEEPING RECORDS FOR THE GOVERNMENT, OR (4) AS PART OF CUSTOMARY AND USUAL BUSINESS OR PRIVATE PRACTICES.

There are no start-up cost burdens to respondents or record keepers that are not included in items 2 and 14.

4. 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, OPERATIONS 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 Federal government’s annual costs for providing oversight and assistance for this information collection is estimated at $19,588.67 the first year and for subsequent years it is estimated to be about $20,176.33, assuming higher overhead costs. A breakdown of the oversight costs for the first year is the following:

Salaries/benefits/awards $2,188.67
Travel $5,000
Printing/Copying/Mailing/Postage $800
Federal Register Services $2,400
OGC (legal services) $8,000
Supplies/equipment $1,200
TOTAL $19,588.67

4. EXPLAIN THE REASON FOR ANY PROGRAM CHANGES OR ADJUSTMENTS REPORTED IN ITEM 13 OR 14 OF THE OMB FORM 83-I.

AMS is requesting approval for 347.23 burden hours, based on 2,650 annual responses. This information collection is for 3 of the Committee’s 11 forms currently approved by OMB. The previous burden for these three forms totaled 2,125 burden hours, based on 278.25 annual responses.

The higher burden calculation is due to the increased number of handlers who would complete the forms. The average number of minutes per response remains unchanged for each form. FV-34 and FV-36 would be edited to add “Experimentation” alongside the five other options for “Shipment Purpose.” No edits would be made to the text of FV-35.

4. 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.

There are no plans to publish any information or data collected.

4. IF SEEKING APPROVAL TO NOT DISPLAY THE EXPIRATION DATE FOR OMB APPROVAL OF THE INFORMATION COLLECTION, EXPLAIN THE REASONS THAT DISPLAY WOULD BE INAPPROPRIATE.

AMS requests approval not to display the expiration date on the forms associated with this information collection because having to do so would: (1) decrease the efficiency of the marketing order programs; (2) be financially prohibitive to the committee and board; and (3) delay the use of the forms and cause confusion to the respondents.

Displaying expiration dates on the forms would decrease the efficiency of the marketing order. At the time the forms expire, the Committee would need to destroy otherwise-usable forms, counteracting the Administration’s goal of increasing program efficiency. As the forms are widely distributed, there is the possibility that a respondent could inadvertently complete an expired form before a new form was distributed, having a severe adverse legal consequence if the validity of the form were ever challenged. For example, if expired ballots were inadvertently used to elect Committee members, the members’ seats could later be found to be invalid, causing a disruption of the committee, requiring re-election, and negatively affecting the entire industry. This would increase legal and administrative costs, and greatly decrease efficiency.

This committee is very small with a small operating budget, and relies heavily on financial discounts to function properly. As such, it orders large quantities of these forms at once to get lower printing prices, knowing that they will be in use for several years. Displaying expiration dates on the forms could financially hurt them as they simply could not afford to reprint forms or pay more for the forms they order from the printer.

Finally, putting expiration dates on the forms prevents them from being used once they reach expiration while the new forms are in the OMB-approval process. The Committee mails forms to respondents in a timely manner to ensure accurate completion. If the Committee needs to order additional forms during this process, it could not order the forms with a new expiration date, as there are no guarantees that a requested expiration date would be approved by OMB. This would delay the Committee’s use of these forms, and hinder the smooth operation of the marketing order requirements. Displaying expiration dates on forms also confuses respondents, who may think that the expiration date applies to the time their information is due, rather than the validity of the actual form.

4. EXPLAIN EACH EXCEPTION TO THE CERTIFICATION STATEMENT IDENTIFIED IN ITEM 19, "CERTIFICATION FOR PAPERWORK REDUCTION ACT SUBMISSIONS," OF OMB FORM 83-I.

The agency is able to certify compliance with all provisions under item 19 of OMB Form 83-I.

1. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS.

This collection of information does not employ statistical methods.

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