0372 SS 9-19-11 final rule update

SUPPORTING STATEMENT
VESSEL MONITORING SYSTEM FOR ATLANTIC HIGHLY MIGRATORY SPECIES
OMB CONTROL NO. 0648-0372

A.

JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.
The purpose of this collection of information is to comply with the Magnuson-Stevens Fishery
Conservation and Management Act (Magnuson-Stevens Act), the United States' obligations
under the Atlantic Tunas Convention Act of 1975 (ATCA; 16 U.S.C. 971), other domestic
Federal regulations, and the implementing regulations at 50 CFR part 635.
In this revision request, resubmitted for the final rule, the National Marine Fisheries Service
(NMFS) is proposing that Mobile Transmitting Unit (MTU) Vessel Monitoring System (VMS)
units be replaced by Electronic Mobile Transmitting Unit (E-MTU) VMS units in Atlantic HMS
fisheries subject to VMS requirements. These updated VMS units are capable of sending and
receiving electronic messages. Using the updated E-MTU VMS units, NMFS also proposes
implementing a declaration system through which vessels declare target species and gear
deployed for fishing trips. These modifications would improve enforcement of HMS
regulations.
VMS aids the NMFS Office of Law Enforcement (OLE) in monitoring and enforcing closed
areas implemented to reduce bycatch of juvenile swordfish, sharks, sea turtles, and other species
necessary to comply with the Marine Mammal Protection Act, Endangered Species Act, and
National Standard 9 (bycatch and bycatch mortality reduction) of the Magnuson-Stevens Act.
There are numerous areas that are closed to fishermen fishing for Atlantic highly migratory
species (HMS) with pelagic and bottom longline gear onboard. Consistent with implementing
regulations in place for the Atlantic Large Whale Take Reduction Plan (ALWTRP), shark gillnet
vessels are required to use VMS at certain times of year to minimize the likelihood of
interactions between fishing gear and marine mammals. Traditional methods of surveillance by
ships and planes would be ineffective in patrolling such large areas. In HMS fisheries, VMS is
designed to automatically report positions on all vessels carrying pelagic longline gear (at all
times and all locations), bottom longline gear (vessels between 33°00' N. latitude and 36°30' N.
latitude between January 1 and July 31 every year), or shark gillnet (all locations, between
November 15 and April 15) gear on board.
By requiring that E-MTU VMS units be professionally installed and used to replace the dated
MTU VMS units, NMFS will ensure that newer, more reliable, technology is in use, improve
fisheries monitoring and enforcement of regulations, and provide NMFS enforcement agents
with the ability to communicate directly with vessels at sea via electronic messaging and other
means. With this newer technology, NMFS enforcement agents could: notify vessel operators of
emergency changes to closed areas; provide notice of fishery closures in real time; inform
operators of environmental disasters (oil rig fires/oil spills); send notice of dangerous weather;
and receive distress or emergency transmissions.
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NMFS is also proposing that, two hours prior to leaving port, fishermen provide NMFS
enforcement with notice of the beginning of a fishing trip and a declaration of the target fishery
and gear onboard. In addition, this proposed rule would require vessel operators to provide a
minimum of three hours’ advance notice of landing. Currently, vessel operators are required to
turn on the VMS unit two hours before leaving port. Under this proposed rule, vessel operators
would also need to declare the species being targeted and the gear being used. Creating a fishery
declaration system would facilitate enforcement and compliance monitoring. Vessels may be
permitted to participate in multiple fisheries that authorize numerous fishing gears. The
declaration system would provide NMFS enforcement with advance notice of the target fishery
and gear possessed onboard which provides enforcement with critical information concerning
which regulations apply to that particular vessel during that trip.
Any new declaration system would be compatible with the capabilities of newly required EMTU VMS units and consistent with declaration protocols currently employed in Councilmanaged fisheries. Additionally, the requirement to notify NMFS enforcement at least three
hours prior to returning to port provides notification that fishing activities are being completed,
gear is no longer being deployed, and the vessel is transiting back to port.
Vessels with E-MTU VMS units would be able to communicate through electronic messages
with shore-based fishery personnel, which could allow fishery participants to: communicate
directly with NMFS enforcement in the case of a power disruption; download updated E-MTU
software without removal of the device; communicate with manufacturers to remedy
malfunctions; receive required software upgrades with little interference; communicate with
vessel owners and fish houses; and send distress calls to monitoring companies in the event of an
emergency. Although some of these features are potentially useful functions, they are not the
primary purpose of VMS and, it is important that fishermen not see them as a substitute for
required safety equipment such as a properly installed and functioning Emergency Position
Indicating Radio Beacon (EPIRB).
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 applicable NOAA Information Quality Guidelines.
The installation and activation checklist would be submitted one time after the new E-MTU
VMS unit is installed by a qualified marine electrician. The checklist indicates the procedures to
be followed by the marine electricians whom install the updated E-MTU VMS units. These
forms would be completed by the electricians and then submitted to NMFS by the vessel owner.
This checklist provides the OLE with information about the hardware installed and the
communication service provider that will be used by the vessel operator. Specific information
that links a permitted vessel with a certain transmitting unit and communications service is
necessary to ensure that NMFS will receive automatic position reports properly. In the event that
there are problems, NMFS will have access to a database that links owner information with
installation information. NMFS can then contact the vessel operator and discern whether the
problem is associated with the transmitting hardware or the service provider.

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Existing MTU VMS units are programmed to report the vessel’s location to National Oceanic
and Atmospheric Administration (NOAA) OLE every hour, 24 hours a day, while the vessel is
away from port. This allows vessels to traverse closed areas or remain at sea after a fishery has
closed as long as they do not commence fishing operations. NOAA OLE uses VMS position
data to reduce costs and improve enforcement of time/area closures, to monitor the fleet during
the closed period, to deter illegal fishing, to increase efficiency of surveillance patrols, to provide
probable cause for obtaining a search warrant in enforcement investigations, and to support
enforcement of other regulations such as closed seasons once a quota has been reached. NMFS
is now requiring that an updated E-MTU VMS unit be installed and used to transmit information.
Because these units are capable of engaging in two-way communication and sending and
receiving electronic messages, NMFS would also implement a fisheries declaration system. Two
hours prior to leaving port to engage in fishing activities, vessels would provide NMFS OLE
with a declaration of target species and gear being deployed for a particular trip. Before
returning to port, vessels would again notify NOAA OLE three hours prior to landing after
fishing activities have been completed. This information would allow NOAA OLE to more
accurately track and monitor vessels for compliance in specific fisheries. Any new declaration
system would be compatible with the capabilities of newly required E-MTU VMS units.
NOAA Information Quality Guidelines do not apply to this information collection because the
information collected will not be disseminated to the public.
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.
VMS is the best technology available at this time for monitoring vessel locations to aid
enforcement efforts. The integrated Global Positioning System (GPS) provides a near real-time
mechanism for submitting accurate position reports. VMS is considered much more accurate
than logbooks for reporting geographical distribution of fishing effort for each trip. Logbooks
are submitted by fishermen seven days after offloading and only provide information regarding
the start of a fishing set. Thus, logbooks do not meet the real-time needs of enforcement and
could allow vessels to fish illegally in closed areas without prosecution. VMS, on the other
hand, provides 24 reports each day for the duration of the trip. Report data, in conjunction with a
declaration by the vessel, two-hours prior to leaving port, would provide pertinent data
concerning target species and gear being deployed. This information is important for discerning
which closed areas apply to a particular vessel and allows enforcement to react immediately if a
vessel is found fishing in a closed area.
MTU VMS units have been required in certain HMS fisheries since 2003. Recently, E-MTU
VMS units have become available and are currently being used in Council-managed fisheries.
These updated E-MTU units are capable of two-way communication which expands the potential
for transmission of electronic information to/from NMFS. A fishery declaration system would be
implemented where vessels send information to NOAA OLE concerning the target species and
gear being deployed prior to leaving port to engage in fishing activities and after fishing is
completed. Furthermore, vessels would be able to receive information from NOAA concerning
weather alerts, natural disasters, fishery closures, and other information. The updated VMS units
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may provide a platform for future electronic logbook reporting of both target and non-target
species.
4. Describe efforts to identify duplication.
Position reports at the start of each fishing set are required of participants using the HMS
logbook, and will therefore be duplicated by participants using VMS; however, VMS position
reports are automated and would need to be sent every hour while vessels are away from port
and would not require any action on the part of the vessel operator. Typically, most of the
participants in the pelagic longline (PLL) fishery for tunas and/or swordfish use the HMS
logbook. Vessels participating in the shark bottom longline (BLL) and gillnet fisheries use a
different logbook (Coastal Fisheries Logbook) that does not require position reports of individual
fishing set and would not be duplicated. If electronic catch reporting is developed in the future,
paper logbooks may become obsolete.
There are no alternate sources of such specific and near real-time vessel location and activity
information. Use of VMS is required in other fisheries and fishermen who have already
purchased a VMS unit can use the same unit for multiple fisheries. Information is only reported
one time to enforcement and not duplicated.
5. If the collection of information involves small businesses or other small entities, describe
the methods used to minimize burden.
All owners of vessels with commercial permits for HMS, (i.e., swordfish, sharks, and tuna) are
considered small entities. Proposed VMS regulations would require the approximately 329
pelagic longline, bottom longline, and shark gillnet vessels to maintain their new VMS units at a
daily cost of approximately $1.56/day (24 location reports + 2 declaration reports x
$0.06/transmission). Individual position or message reports cost $0.06/transmission for both
sending and receiving data. In an attempt to provide vessel owners with some flexibility, NOAA
OLE has published general type approval specifications in the Federal Register (January 31,
2008; 73 FR 5813) describing the types of units that would be appropriate. Existing units that
meet the criteria range in price from $3,100 - $3,600, depending on the features of the E-MTU
VMS device. This provides vessel owners with some flexibility of choice and helps to minimize
costs. Vessels are already required to use a MTU VMS in certain HMS fisheries, therefore,
active vessels will need to purchase new equipment and cover updated operation and data
transmission costs.
Currently, reimbursement funds ($3,100/E-MTU VMS unit) may be available for some HMS
fishery participants required to upgrade to E-MTU VMS units. The reimbursement could only
be applied to the costs of the updated unit and would not offset any costs incurred as a result of
installation by a qualified marine electrician or of data transmission. Participants that have
already received reimbursement funds from NOAA OLE for an E-MTU VMS may not be
eligible to receive additional reimbursement funds.

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6. Describe the consequences to the Federal program or policy activities if the collection is
not conducted or is conducted less frequently.
Using VMS to verify the location of a vessel is passive and automatic, requiring no reporting
time on the part of the vessel operator. ICCAT recognizes the developments in satellite-based
VMS and their possible utility, including better resource management and, thus, more effective
and sustainable use of resources. More specifically, benefits for management include increased
compliance with and enhanced enforcement effectiveness regarding area restrictions, more
timely data regarding fishing effort by areas, and more timely catch reporting. Other possible
benefits of the VMS include increased vessel safety and dependable and confidential
communications, which may improve fleet management.
Monitoring and enforcement are essential components of fisheries management. Monitoring
fishing vessels facilitates enforcement of NMFS’ conservation and management regulations by
enabling detection of violations. Monitoring also promotes compliance by having a general
deterrent effect. Lack of proper monitoring and enforcement makes it difficult to gauge the
effectiveness of conservation and management measures. In the case of overfished stocks,
enforcement is necessary to prevent further overfishing and subsequent decline to dangerously
low stock levels. As a practical matter, it is very difficult for enforcement personnel to
effectively monitor the full operational range of the U.S. pelagic longline fleet without having
some method of detecting a vessel’s location. With respect to pelagic longline time/area closures
in particular, the size of the closed areas makes the likelihood of detection through conventional
surveillance methods rather small.
The use and submission of a checklist, completed by a qualified marine electrician, is required
only for the initial installation or when the hardware or communications service provider
changes.
Less frequent reporting would prevent NMFS and the vessel operator from confirming that the
system is functioning properly and would make it more difficult to determine whether a vessel is
fishing in, or transiting through a closed area. Furthermore, not requiring vessels to make a
declaration before leaving port describing target species and gear deployed would make it
difficult for NOAA OLE to know which closed areas and other regulations apply to that
particular vessel.
7. Explain any special circumstances that require the collection to be conducted in a
manner inconsistent with OMB guidelines.
VMS will be reporting positions 24 times a day, which is more frequent than OMB guidelines
suggest. This frequency is required for the near real-time and accurate tracking of vessel
activities. The requirement for 24 position reports per day is designed to allow NMFS to
distinguish between a vessel that is setting gear, and a vessel that is traversing a closed area.
Fewer reports would indicate that a vessel was in the area but would not indicate whether the
vessel was setting gear or traversing the area. The time burden as a result of this frequency,
however, remains minimal because the position reports are automated and require no action on
the part of the vessel operator. As stated above, the two-time (per trip) declaration would
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facilitate improved enforcement of regulations because NOAA OLE would know which gear is
being deployed and the relevant target species for individual trips.
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 proposed rule 0648-BA64 seeking public comment was published coincident with the first
submission of this information collection request. Based on one comment received, the upper
limit of the new VMS installation cost was changed from $200 to $400.
A final rule will be published in early October, 2011. A draft is included in this submission.
9. Explain any decisions to provide payments or gifts to respondents, other than
remuneration of contractors or grantees.
No payments or gifts are to be offered as part of this information collection.
10. Describe any assurance of confidentiality provided to respondents and the basis for
assurance in statute, regulation, or agency policy.
As stated on the VMS installation and activation checklist, all automated position reports and
declaration reports received by NMFS will be treated as confidential data in accordance with the
Magnuson-Stevens Act and NOAA Administrative Order 216-100.
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.
A total of 329 vessels are subject to the updated VMS requirements (Table 1). Based on the
number of limited access (directed and incidental) permits for swordfish, an estimated 249
pelagic longline vessels are subject to the VMS requirement. Based on the number of limited
access directed shark permits, an estimated 50 bottom longline shark fishing vessels and 30 shark
gillnet vessels are also subject to the VMS requirement. Once the updated VMS is installed by a
qualified marine electrician, the vessel owner would be required to submit a activation checklist
via regular mail to NOAA OLE. The estimate for this burden is 5 minutes per participant.
Prior to engaging in fishing activities the vessel operator must turn the system on two hours
before leaving port and verify that the system is functioning properly. At that time, vessels
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would transmit an electronic message to NOAA OLE declaring target species and gear deployed
for the fishing trip. Vessels would also report to NOAA OLE when they are returning to port.
NMFS estimates that these declarations would require approximately 10 minutes per trip
(2 declarations, 5 minutes/declaration)). Once on, position reports are automatically sent from
the VMS on an hourly basis. The automatic position reports are not considered burden to the
respondents. Burden associated with maintenance is not anticipated with the updated E-MTU
VMS units.
Table 1. Number of HMS Vessels Required to Comply with VMS Requirements by Gear
Type Based on 2010 Permit Data.
Pelagic Longline
(Swordfish
Directed +
Swordfish
Incidental)

Bottom Longline
(Directed and
Incidental Shark
Permit Holders
in NC, SC, and
VA)

249

50

Gillnet
(Vessels with a
Directed Shark
Permit and
Landed Sharks
with Gillnet,
2004-2007)
30

Total

329

Pelagic Longline Vessels:
Trip duration within the PLL fleet varies based on time of year, location, target species, market
prices, quota availability, and other factors. Logbook data from 2006-2009 indicate that the
average trip duration for PLL vessels was 9 days. It is assumed that vessels need at least one day
in port to offload their catch and procure supplies before returning to sea, during which time they
would not be required to provide position reports. On average, PLL vessels may take 36 trips
per year, which equals 324 days per year at sea (36 trips/year * 9 days/trip = 324).
One-time burden:
Total responses: 249 (installation considered part of activation response) annualized to 83.
Installation time: average of 4 hours x 249 = 996 hours.
Submission of completed installation checklist: 5 minutes x 249 = 1,245 min/60 min. = 20.41
hours.
Total hours: 1,016.41, annualized to 338.8 (339) hours.
Recurring burden:
Per vessel responses: 36 trips/year * 2 declarations = 72 declarations. Total responses: 72 * 249
= 17,928.
36 trips/year * 2 declarations/ * 5 minutes/declaration / 60 minutes/hour = 6 hours/vessel).
Estimated burden for the entire PLL fleet would be 1,494 hours (249 vessels * 6 hours/vessel =
1,494 hours).
Total annualized/annual responses: 83 + 17,928 = 18,011.
Total annualized/annual hours: 339 + 1,494 = 1,833.

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Shark Bottom Longline Vessels:
All vessels with bottom longline gear onboard are required to use VMS from January 1 to July
31 when they are between 33 N and 36.3 N, on an annual basis.
During this time period (January-July) and in this vicinity, most participants with bottom
longline on board would be targeting large coastal sharks (LCS). It is assumed that most vessels
targeting LCS would be making day-trips (i.e., returning to port to offload once every 24 hours).
For the purpose of estimating the potential burden of this requirement participants could also be
fishing for small coastal sharks and pelagic sharks which are typically open for the duration of
the time period in this area. Therefore, it is assumed that vessels could be in this vicinity with
BLL gear onboard for 212 days/year (January 1 – July 31).
One-time burden:
Total responses: 50 (installation considered part of activation response) annualized to 17.
Installation time: average of 4 hours x 50 = 200 hours.
Submission of completed installation checklist: 5 minutes x 50 = min/60 min. = 4.2 hours.
Total hours: 204, annualized to (68) hours.
Recurring burden:
Per vessel responses: 212 trips/year * 2 declarations = 424 declarations. Total responses: 424 *
50 = 21,200.
212 trips/year * 2 declarations/ * 5 minutes/declaration / 60 minutes/hour = 35.3 hours/vessel.
Estimated burden for the entire BLL fleet would be hours (50 vessels * 35 hours/vessel = 1,767
hours).
Total annualized/annual responses: 17 + 21,200 = 21,217 responses.
Total annualized/annual hours: 68 + 1,767 = 1,835 hours.
Directed Shark Gillnet Vessels:
Vessels that possess a shark directed permit and have gillnet gear onboard between November 15
and April 15 would be required to use VMS when they are away from port in the Southeast U.S.
Restricted Area as defined in 50 CFR 229.32.
The gillnet fishery primarily targets small coastal sharks (SCS) and blacktip sharks (included in
the non-sandbar LCS complex). Season length for sharks varies from year to year based on
quota availability, catch rates, and other considerations. Many shark gillnet vessels possess
permits which allow them to participate in other fisheries using gillnet gear, therefore, to
estimate burden it is assumed that affected vessels could be engaged in fishing activities and
subject to VMS requirements for the duration of this time period every year (152 days).
One-time burden:
Total responses: 30 (installation considered part of activation response) annualized to 10.
Installation time: average of 4 hours x 30 = 120 hours.
Submission of completed installation checklist: 5 minutes x 30 = 150 min/60 min. = 2.5 hours.
Total hours: 123, annualized to (42) hours.
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Recurring burden:
Per vessel responses: 152 trips/year * 2 declarations = 304 declarations. Total responses: 304 *
30 = 9,120.
152 trips/year * 2 declarations/trip * 5 minutes/declaration / 60 minutes/hour = 25.3 hours/vessel.
Estimated burden for the entire gillnet fleet would be hours (30 vessels * 25.3 hours/vessel = 760
hours).
Total annualized/annual responses: 10 + 9,120 = 9,130 responses.
Total annualized/annual hours: 42 + 760 = 802 hours.

Table 2 Summary of the estimated burden for PLL, BLL, and gillnet vessels.
PLL vessels
BLL vessels
Gillnet vessels
Total
249
50
30
329
Respondents
18,011
21,217
9,130
48,358
Responses
1,833
1,835
802
4,470
Hours
13. Provide an estimate of the total annual cost burden to the respondents or recordkeepers resulting from the collection (excluding the value of the burden hours in Question
12 above).
In the table below, purchase and installation costs for the 329 vessels required to have VMS are
one- time costs and are not included in subsequent years’ annual cost burden estimates, but are
annualized in the text below the table. Note that there is no submission cost for the activation
checklist.
Table 3. Summary of the total costs associated with the revised E-MTU VMS requirements
in Atlantic HMS fisheries.
Pelagic Longline Vessels
E-MTU VMS Unit
Estimated Installation
Costs (one-time)
Daily Position Report
Costs (Hourly, 24/day)
($0.06/report *24
reports/day)
Estimated Days
Fishing/Year
Annual Position Report
Costs/ Vessel
($1.44/day * days
fishing/year)

$3,100
$50-400 ($400 used for
estimation purposes)
$1.44

Shark Bottom Longline
Vessels
$3,100
$50-400 ($400 used for
estimation purposes)
$1.44

324

212

152

$466.56/vessel

$305.28/vessel

$218.88/vessel

Annual Number of
Fishing Trips
Annual Gear/Spp.
Declaration Costs

36

212

152

$4.32

$25.44

$18.24

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Shark Gillnet Vessels
$3,100
$50-400 ($400 used for
estimation purposes)
$1.44

Pelagic Longline Vessels
($0.12/trip)/Vessel
($0.12/trip *
trips/year)**
Total Estimated
Costs/Vessel (Year 1)
(VMS unit
+installation+position
reports+declaration
reports)
Number of Affected
Vessels
Total Costs by Fishery
(Year 1)
(Total Estimated
Costs/Vessel*Number of
Affected Vessels)
Gross Cost of
Compliance, Year One
(all HMS vessels
combined)
Potential
Reimbursement Funds
($3,100/vessel * Number
of Affected Vessels)
Compliance Costs (Year
1) (avg. cost/vessel)
(installation + position
reports + declaration
reports)
Compliance Costs/Vessel
(Year 2 and Beyond)
(position reports +
declaration reports)

Shark Bottom Longline
Vessels

Shark Gillnet Vessels

$3,970.88

$3,830.72

$3,737.12

249

50

30

$988,749

$191,536

$112,113

$1,292,398

$1,019,900

$870/vessel

$730/vessel

$637/vessel

$470/vessel

$330/vessel

$237/vessel

Note: Although $1,019,900 may be available as reimbursement funds, we are currently
requesting approval for the full capital and start-up funds of $1,151,500.
Total capital and start-up costs would be $1,151,500 ($3,500 x 329 vessels), annualized to
$383,833.
Total annually recurring reporting costs will be ($470 x 249 = $117,030) + ($330 x 50 =
$16,500) + ($237 x 30 = $7,110): $140,640 (average of 427.48 per vessel).
Total annualized costs would be 524,473, or an average of $1,594 per vessel.

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14. Provide estimates of annualized cost to the Federal government.
There would be no significant cost to the Federal government outside of the initial
reimbursement. NMFS is developing an integrated hardware and tracking system to manage the
various VMS programs being developed for many other U.S. fisheries. Those costs are already
covered by current programs of the Office of Law Enforcement and are extraneous to this
collection. Given the current capacity of these systems, incremental costs specifically
attributable to the HMS VMS program are negligible.
15. Explain the reasons for any program changes or adjustments.
Adjustment(s): The number of affected vessels has changed from 292 to 329.
Program changes: The hours and costs are changed to reflect changes to VMS equipment,
maintenance, and installation costs and reporting requirements.
1. Purchase and installation of 329 new VMS units.
2. Removal of $500 annual repair/maintenance responses and expenses for 292 current
VMS units.
3. Addition of $0.12 data transmission costs per trip for 292 units and $1.12 for the
additional 37.
4. Addition of cost estimates ($400) for having a qualified marine electrician install E-MTU
VMS units.
16. For collections whose results will be published, outline the plans for tabulation and
publication.
No formal scientific publications based on this program are planned at this time. The data will
be used for enforcement, management reports, and drafting or evaluating fishery management
plan amendments by NMFS. However, subsequent use of the data collected over a series of
years may be included in scientific papers and publications. Position data will remain
confidential and will only be revealed to the public in aggregated form.
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.
Not Applicable.
18. Explain each exception to the certification statement.
There are no exceptions.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
This collection does not employ statistical methods.
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