1625-0014
Supporting Statement
for
Request for Designation and Exemption of
Oceanographic Research Vessels
A. Justification
1. Explain the circumstances that make the collection of information necessary.
This data collection is necessary for the designation of Oceanographic Research Vessels (ORV). According to 46 USC 2113, 46 CFR 3.10, and 46 CFR 14.403, oceanographic vessels may be exempted from the statute and regulations governing the shipment, discharge, payment and personal outfitting of merchant seamen.
Section 2113 of U.S.C. 46 also provides the Secretary of Homeland Security with the authority to exempt certain vessels from the inspection and manning requirements of law when vessels are engaged in oceanographic research. It also contains flexible exemption authority for regulation of ORVs.
According to 46 CFR Section 3.10-1, an individual can submit a written request to the Officer in Charge, Marine Inspection (OCMI) seeking a vessel be designated as an ORV. At a minimum, the following information must be submitted during the initial request: 1) a detailed description of the vessel, including its identification number, owner and charterer; 2) a specific operating plan stating precisely the intended use of the vessel; and 3) any additional information as may be requested by the OCMI. According to 46 CFR Section 3.10-5, at least 60 days prior to the expiration date of the Letter of Designation or Certificate of Inspection, a request for renewal must be submitted in the same manner as above.
According to 46 CFR Section 14.403, certain requirements of 46 USC do not apply to the employment of merchant mariners on ORVs. Those requirements include concerns for the shipment and discharge of mariners, their pay and allotments, and the adequacy of their clothing. According to 46 CFR Section 14.405, an individual in charge of an ORV may submit a written request to the OCMI seeking an exemption. The request must state: 1) any requirement of any section listed in 46 CFR 14.403(b) from which the applicant wishes an exemption; and 2) what business practices regarding, among other things, the shipment and discharge of merchant mariners, their pay and allotments, and the adequacy of their clothing would justify the exemption.
This information collection supports the following strategic goals:
Prevention
Maritime Safety
Prevention Policy & Response Policy Directorates (CG-5P & CG-5R)
Safety: Reduce deaths, injuries, and property damage associated with commercial maritime operations.
Economic Growth and Trade/Mobility: Reduce interruptions and impediments that restrict the economical movement of goods and people, while maximizing safe, effective, and efficient waterways for all users.
2. By whom, how, and for what purpose the information is to be used.
This information is used by the OCMI to determine: 1) if a vessel can be designated as an ORV; and 2) can be exempted from specific inspection and/or manning requirements. [According to 46 CFR Section 3.05-3, an ORV is a vessel which the U.S. Coast Guard finds is employed exclusively in one or more of the following: a) oceanographic instruction, b) limnologic instruction, c) oceanographic research, or d) limnologic research.]
An ORV may be inspected or uninspected. If uninspected, it receives a Letter of Designation; if inspected, its designation appears on its Certificate of Inspection. A Letter of Designation is valid for two years and a Certificate of Inspection is valid for five years. According to the Coast Guard's MISLE database, there are 93 uninspected ORVs with a current Letter of Designation and 20 inspected ORVs with a current Certificate of Inspection. Since uninspected ORVs’ Letters of Designation expire after two years, on average half (47 vessels) will expire any given year. The ORV designation on inspected vessels must be renewed every five years, so on average, 20 percent (4 vessels) will need to seek re-designation in any given year.
3. Consideration of the use of improved information technology.
Requests for ORV designation can be mailed, faxed or electronically submitted via e-mail to the OCMI. There is no specific CG form that must be completed for the request and the content of a request can vary. If a respondent opts to submit a request electronically, e-mail provides the most versatile method of submission. No other e-submission method is envisioned for this ICR. A list of Coast Guard sectors, as part of a comprehensive list of Coast Guard units, can be found at: http://www.uscg.mil/top/units/.
We estimate that 100% of the reporting requirements can be done electronically. At this time, we estimate that approximately 50% of the responses are collected electronically.
4. Efforts to identify duplication. Why similar information cannot be used.
The Coast Guard may hold information regarding the physical description of the vessels concerned. Consequently, if a vessel renews its Letter of Designation or Certificate of Inspection, it does not have to duplicate its physical description unless changes have been made.
With the partial exception of certain inspected vessels, the information necessary to allow designation of ORVs and their exemption(s) from certain requirements is not generated elsewhere.
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 not done or conducted less frequently.
The initial written request for a vessel to receive the designation of ORV and corresponding exemptions is voluntary and relatively spontaneous. Once designated, an uninspected vessel, on average, must renew its designation every two years, an inspected vessel every five years.
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 a manner consistent with the guidelines in 5 CFR 1320.5(d)(2).
8. Consultation.
A 60-day Notice and a 30-day Notice were published in the Federal Register to obtain public comment on this collection (See [USCG-2012-0077], February 21, 2012, 77 FR 9951; and May 4, 2012, 77 FR 26561). The Coast Guard has not received any comments on this information collection.
9. Explain any decision to provide payment or gift to respondents.
The Coast Guard does not provide payments or gifts to respondents in exchange for a benefit sought.
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 estimated annual number of respondents is 51.
The estimated annual number of responses is 51.
The estimated annual hour burden is 51 hours.
The estimated annual cost burden is $4,233.
According to the Coast Guard's MSMS database, there are 20 ORVs that have a current Certificate of Inspection and 93 that have a current Letter of Designation. We estimate that 51 will request an ORV designation or Certificate of Inspection each year. We expect an average of 1 hour to complete the request for ORV designation or Certificate of Inspection. Consequently, we estimate an average of 51 hours to request ORV designation or Certificate of Inspection each year. We estimate the average hourly wage for an owner of this type of vessel is $83 per hour.1 Therefore, the total cost to owners to request ORV designation or certificate of inspection each year is estimated to be $4,233. See Table 1.
Table 1: Hour and Cost Burden to Owners of Vessels Seeking ORV Designation/Certification
Number of ORV Designated or Certificated Vessels |
Number of Designation or Certification Requests Per Year |
Hour Burden Per Request |
Total Hour Burden Per Year |
Cost Per Hour |
Total Cost Per Year |
113 |
51 |
1 |
51 |
$83 |
$4,233 |
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.
The cost to the Government is the cost to the OCMI to review the request of an ORV designation or certificate of inspection and determine its eligibility. Assuming it takes 0.5 hours to review and determine if the requesting vessel is eligible, and the average wage of Coast Guard personnel is $65 per hour,2 we estimate the annual cost to the Coast Guard is $1,690 ($1,690 = 51 requests/year x 0.5 hours/request x $65/hour). See Table 2.
Table 2: Hour and Cost Burden to Federal Government
Number of OVR Designated or Certificated Vessels |
Number of Designation or Certification Requests Per Year |
Hour Burden Per Request |
Total Hour Burden Per Year |
Cost Per Hour |
Total Cost Per Year |
113 |
51 |
0.5 |
26 |
$65 |
$1,690 |
15. Explain the reasons for the change in burden.
The change in burden is an ADJUSTMENT due to a change in the vessel population. There is no proposed change to the reporting or recordkeeping requirements of this collection. 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. Approval to not display expiration date.
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.
The collection of information does not employ statistical methods.
1 Equivalent to a GS-13 “out-of-government” rate per Commandant Instruction 7310.1M.
2 Equivalent to a GS-12 “in-government” rate per Commandant Instruction 7310.1M.
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT |
| Author | zzjward1 |
| Last Modified By | David A. Du Pont |
| File Modified | 2012-06-25 |
| File Created | 2012-06-25 |