SuptStmt - ORDER 6-18-13

SuptStmt - ORDER 6-18-13.doc

Softwood Lumber Research, Promotion, Consumer Education & Industry Information Order

OMB: 0581-0264

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2013 SUPPORTING STATEMENT

Softwood Lumber Research, Promotion, Consumer Education and Industry Information Program

7 CFR Part 1217

OMB Number 0581-0264

(Order)


  1. Justification


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


The Softwood Lumber Research, Promotion, Consumer Education and Industry Information Order (Order) under the Commodity Promotion, Research, and Information Act of 1996, (PL 104-127, 110 Stat. 1032, April 4, 1996, 7 U.S. C. 7411-7425) requires collection of information to carry out the program. This legislation is hereinafter referred to as the 1996 Act. Under the enabling legislation, Congress has delegated the Department of Agriculture (USDA) the responsibility of establishing and overseeing agricultural commodity research and promotion orders, which may include a combination of promotion, research, industry information, and consumer information activities funded by mandatory assessments. These programs are designed to maintain, develop, and expand markets and uses for agricultural commodities. The Order was submitted by the Blue Ribbon Commission (BRC).

The Order provides for the development and financing of a coordinated program of research, promotion, and information for softwood lumber. The program includes projects relating to research, consumer information, advertising, sales promotion, information, market development and product research to assist, improve, or promote the marketing, distribution, and utilization of softwood lumber.

The program is administered by a Board appointed by the Secretary of Agriculture and financed by a mandatory assessment on domestic manufacturers and importers of softwood lumber. The Agricultural Marketing Service provides oversight to ensure: (1) funds are collected and properly accounted for; (2) expenditures of all funds are for the purposes authorized by the enabling legislation; and (3) the Board’s administration of the program conforms to USDA policy.

Section 515(i) of the 1996 Act provides authority to request from persons covered under the Order any information required to carry out the responsibilities of the program. Each appointed Board is responsible for collecting assessments from the affected persons covered under the program in order to carry out the Board’s responsibility. These programs require the use of the forms described in item 2 below.


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.


The Softwood Lumber Research, Promotion, Consumer Education and Industry Information Order (Order) is authorized under the 1996 Act. The Order was established by USDA through the issuance of the Order, rules and regulations. A referendum passed with 76 percent of those voting in the referendum representing 80 percent of the volume of softwood lumber represented in the referendum favored implementing the Order.

Under the Order, domestic manufacturers and importers of softwood lumber are subject to a mandatory assessment of $0.35 per thousand board feet of softwood lumber to fund a coordinated program to maintain, develop, and expand the demand of softwood lumber. The Order is administered by a 19 member Softwood Lumber Board (Board) comprised of 12 domestic manufacturer members from 3 regions (6 members from U.S. South Region, 5 members from U.S. West Region, and 1 member from the Northeast and lake States), and 7 importer members, 6 from 2 regions (4 members from Canadian West Region, and 2 members from Canadian East Region), and 1 importer member from a region not otherwise specified.

The members are appointed by the Secretary of Agriculture to administer the program with AMS oversight. Nominations are conducted by the Board through a nomination and balloting process for both domestic manufacturers and importers.

Board members serve terms of three years and could serve a maximum of two consecutive terms. For the initial Board, the terms were staggered for two, three, and four years. The Board uses assessments collected under the Order to carry out research, promotion, consumer education, and industry information activities. In order to carry out these responsibilities, domestic manufacturers and importers are required to submit certain information, as provided in Sections 515, 516, and 517 of the 1996 Act, and Sections 1217.41,1217.52, 1217.53, and 1217.71 of the Order.

Upon renewal of this information collection package, and during renewal of information collection package 0581-0093, this package will ultimately be merged into 0581-0093.

It is estimated that there are 1478 respondents comprised of 595 domestic manufacturers and 883 importers. These 1478 respondents are required to keep books and records to carry out the provisions of the Order. The 1478 respondents differ from the number of respondents completing the forms identified on the AMS Form 71, due to the fact that not all of the domestic manufacturers and importers have to fill out the forms listed, but all domestic manufacturers and importers have to keep the books and records to show they have either paid the assessment or are exempt from paying the assessment.

The information required under this program is gathered through the following forms, and is used by USDA’s AMS, and the Board as described below:


a) Background Information Form AD-755 (OMB 0505-0001) (Section 1217.41): This form contains questions to ascertain the nominee’s qualifications for consideration of appointment to the Board by the Secretary of Agriculture. The form questions include: personal identification information, including name, social security number, date of birth, and address; length of time engaged in manufacturing softwood lumber; quantity of million board feet manufactured; length of time engaged in importation of softwood lumber and the number of million board feet imported; employment information; professional affiliation(s); education; income sources for amounts over $10,000; and criminal history. The form would be completed by all Board nominees including domestic manufacturers and importers. This information would be provided to the Board and forwarded to USDA for use in the nomination process.


b) Application for Exemption from Assessments (SWL-AAE) (Section 1217.53): Domestic manufacturers or importers who ship or import less than a predetermined quantity per year could claim an exemption from assessments. This form requires handling and importation data, supporting documentation, and certification. The form requests the minimum information necessary for proof that domestic manufacturers and importers should be exempt from assessments under the Order.


c) Shipment/Import Quarterly Report (SWL-SIQ) (Section 1217.52): Domestic manufacturers and importers would be required to report to the Board on a reporting period determined by the Board information necessary for the Board to perform its duties. For domestic manufacturers, the information may include: the total quantity of softwood lumber shipped during the reporting period; deduction of total quantity of softwood lumber exempted during the period; and the domestic manufacturer’s tax identification number. For importers, the information may include: the total quantity of softwood lumber imported during such reporting period; softwood lumber imported during the reporting period including quantity, date, country of origin, and port of entry; and the importer of record tax identification number.


Importer Report (No form) is a report submitted to the Board by the U.S. Customs Service (Customs), from information obtained at the port of entry. The report requires information regarding the total quantity of product imported during the reporting period and a record of each importation of such product during such period, giving quantity, date, and port of entry. Assessments are reported on the Importer Report on a calendar month basis and accompany the payment to the applicable Board. Under the Order, U.S. Customs would collect assessments on imported softwood lumber and remit the funds to the Board.


Recordkeeping Requirements (Section 1217.71) are required to maintain and make available information for inspection by the Board and USDA. Each domestic manufacturer and importer subject to the 1996 Act and Order shall maintain appropriate records to carryout the requirements of theses regulations. Recordkeeping requirements will help provide for the effective operation of the Order, and its conformance with the 1996 Act.


d) Nomination Appointment Form (SWL-NOM) (Section 1217.41). This form would be used to nominate domestic manufacturers and importers to serve on the Board. For regional domestic manufacturer and importer representatives, the nomination form may be used to nominate persons to Board positions. Once all of the nominations for each position of the Board have been received, the Board will put the names on the ballot and send to eligible domestic manufacturers and importers to vote. Once the votes are tallied from the ballots those receiving the most votes would be nominated to the Board and forwarded to USDA for consideration by the Secretary of Agriculture.


e) Nomination Appointment Ballot (SWL-BAL) (Section 1217.41). This form would be used by domestic manufacturers and importers to vote on nominees to the Board. Once the votes are tallied from the ballots, those receiving the most votes would be nominated to the Board, and those nominees will be forwarded to USDA for consideration by the Secretary of Agriculture.


Background Statement (No Form) is information provided by domestic manufacturers and importers outlining their qualifications and desire to serve on the Board.


f) Organic Exemption Request Form AMS-15 (OMB No. 0581-0093) (Section 1217.53). Under the Order, the form would be completed by domestic manufacturers and importers requesting exemption from paying assessments. Domestic manufacturers and importers requesting exemption must produce or import products that meet the requirements for a “100 percent organic” label under the National Organic Program (7 CFR Part 205), and are not part of a split operation. The form also includes a certification statement.


g) Application for Refund of Assessments Paid (SWL-AFR) (Section 1217.53). Under the Order, the form would be completed by organic importers, domestic manufacturers and other importers requesting reimbursement for the assessments collected by the U.S. Customs Service on Softwood lumber that should have been exempt from assessments or by the Board. Importers requesting reimbursement must show the port of entry, entry date, number of trees and the amount of assessments collected to be reimbursed. In addition, the applicant must give name address, telephone number, tax identification number for proof payment of assessments for which they are requesting reimbursement. Domestic manufacturers must give the same type of information.


h) Referendum Ballot Form (SWL-ORB) (Section 1217.105). This form is used for the implementation, suspension, termination, amendment or continuation of the Order. The other information requested on this form is used for the purpose of verification. The form includes eligibility, vote, and the certification and signature sections. Referendum agents or the Secretary of Agriculture will tabulate the results of the referendum. The agents are officials of USDA, who are charged with promulgating and administering research and promotion programs.


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 Board, which administers the Order. The Board is not part of a Federal agency, but is a commodity industry Board that operates under Federal authority and USDA-AMS oversight. Though AMS is committed to complying with the e-Government Act, which requires Government agencies in general to provide the public the option of submitting information or transacting business electronically to the maximum extent possible, the availability and submission of forms electronically is at the Board’s discretion. Currently, forms are transmitted by fax machine and postal delivery.


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.


The information to be included on these forms is not available from other sources because such information relates specifically to individual domestic manufacturers and importers who are subject to the Order. The primary sources of information would be books and records pertaining to domestic manufacture of softwood lumber and imports of softwood lumber.

Information generated by State, Federal, and private sources would not generate information of a proprietary nature relative to domestic manufacturers and importers who are subject to the provision of the Order. Such information would not be detailed enough to be used for the specific purposes of determining the amount of softwood lumber domestically manufactured or imported. Therefore, there is no practical method for collecting the required information without the use of these forms.


  1. IF THE COLLECTION OF INFORMATION IMPACTS SMALL BUSINESSES OR OTHER SMALL ENTITIES (ITEM 5 OF THE OMB FORM 83-1), DESCRIBE THE METHODS USED TO MINIMIZE BURDEN.


The Small Business Administration defines, in 13 CFR part 121, small agricultural producers as those having annual receipts of no more than $750,000 and small agricultural service firms (domestic manufacturers and importers) as those having annual receipts of no more than $7.0 million. Under these definitions, we have estimated the number of respondents for this collection is 1478, and we estimate that 466 are considered small businesses.

Information collection requirements have been reduced to the minimum requirements of the Order. The primary sources of information used to complete the required forms are readily available from normal business records maintained by domestic manufacturers and importers. Such information can be supplied without data processing equipment or outside technical expertise.

Thus, the information collection and reporting burden is relatively small, and requiring the same reporting requirements for all domestic manufacturers and importers does not significantly disadvantage any domestic manufacturer or importer that is smaller than the industry average.


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 information is collected through a mandatory research and promotion program designed to maintain, develop, and expand markets for softwood lumber. If the information collection herein were not collected, the Board could not carry out the coordinated research, promotion, consumer education, and industry information program on softwood lumber, ensure compliance with the mandatory program or ensure proper assessment collection. Collecting data less frequently also would limit the Secretary’s ability to oversee the Order.


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;


- 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 STATUE 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 special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.6.


  1. 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 and request for comments was published in the Federal Register on April 24, 2013 (78 FR 24152). One comment was received was generally opposed to the softwood lumber program and not within the scope of this action.


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.


Mr. Steve Lovett, Chief Executive Officer to the Softwood Lumber Board; and Mr. Jack Jordan, Chairman of the Softwood Lumber Board, telephone number (312) 321-5131 were contacted on their views of the information collection.


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.


There are no obstacles to consulting with industry members who must submit information to the Board. Industry members are consulted on an ongoing basis on the information collection requirements.


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


AMS does not provide payments or gifts to respondents.

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


Section 1205(m)(2) of the 1996 Act provides that information collected from books and records will be kept confidential by those individuals having access to such information. The 1996 Act also provides for a fine and/or imprisonment for employees of the Board or USDA convicted of violating this confidentiality provision.

All information collected is treated as confidential, as indicated on the forms and in conformance with the Privacy Act and Freedom of Information Act. Other confidential information will be withheld from public review under the Freedom of Information Act and the Privacy Act, 5 USC 552.


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.


Questions of a sensitive nature are not included on any form. The only private information required is on the Background Information Form that a nominee to the Board must fill out. These questions are asked to ascertain his/her qualifications to serve on the Board and include: personal identification information, including name, social security number, date of birth, and address; length of time engaged in the manufacturing of softwood lumber; quantity of million board feet shipped; length of time engaged in importation of softwood lumber and the million board feet of softwood lumber imported; employment information; professional affiliation(s); education; income sources for amounts over $10,000; and criminal history. The form would be completed by all Board nominees including domestic manufacturers and importers. This information would be provided to the Board and forwarded to USDA for use in the nomination process. This information is provided to the Secretary for use in the selection process.


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 DIFFERENCE 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 IN ITEM 13 OF OMB FORM 83-I.


See AMS Form 71.

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 IN ITEM 14.


The respondents’ estimated annual cost of providing information to the Board is $61,743. An estimated number of 1478 respondents would provide information to the Board annually. This total has been estimated by multiplying 1871 hours by $33, the average mean hourly earnings of professional, specialty and technical white collar occupations, and executive, administrative, and managerial white collar occupations by worker and establishment characteristics and geographic areas (metropolitan). Data for computation of this hourly wage were obtained from the U.S. Department of Labor Statistics’ publication, “May 2011 National Occupation Employment and Wage Estimates in the United States,” updated March 29, 2012. This publication can also be found at the following website: http://www.bls.gov/oes/2011/may/oes_nat.htm#b11-0000.


  1. PROVIDE AN ESTIMATE OF THE TOTAL ANNUAL COST BURDEN TO RESPONDENTS OR RECORDKEEPERS RESULTING FROM THE COLLECTION OF INFORMATION. (DO NOT INCLUDE THE COST OF ANY HOUR BURDEN SHOWN IN ITEMS 12 AND 14).


  • 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 REASONS OTHER THAN TO PROVIDE INFORMATION OR KEEPING RECORDS FOR THE GOVERNMENT, OR (4) AS PART OF CUSTOMARY AND USUAL BUSINESS OR PRIVATE PRACTICES.


There are no capital, startup, operation, or maintenance costs associated with this program. The primary sources of information will be books and records pertaining to domestic manufacture or importation of softwood lumber that are normally maintained as part of usual and customary business practices.


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, OPERATION 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.


There are no additional costs associated with this information collection. The Federal government’s estimated annual cost for providing oversight and assistance for this information collection is estimated at $137,363 the first year and for subsequent years it is estimated to be about $90,000. AMS is reimbursed by the Board for all of its oversight costs. A breakdown of the oversight costs for the first year is the following:


Salaries/Benefits/FERS Contributions/Awards $105,326

Travel $10,000

Contracts/Services/Training $3,836

Printing/Copying/Mailing/Postage $3,638

Rent/Communication/Utilities/FTS $3,268

OGC (Legal Services) $10,000

Supplies/Equipment $1,295

TOTAL $137,363


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


This is a renewal with no changes in the burden hours 1871, 1478 respondents and 4,495 responses. The totals for the renewal package already include the merging of 0581-0265 into this package (0581-0264) approved on 12/13/11. Minor changes were made to the forms to assist those completing the forms with providing the requested information with no reflection to additional burden.



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.


There are no plans to publish any information or data collected at this time. The information collected on these forms is not for publication or statistical use. However, if a referendum is held to determine whether to suspend, terminate, amend or continue the order, a press release will be published to announce the results to the industry.


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


The Agency requests approval not to display the expiration date for OMB approval of the information collection. There is some confusion among respondents thinking their annual applications are good for the length of time noted in the expiration date, rather than expiring at the end of the marketing season. Additionally, the impact of the expiration date requirement on administrative and regulatory forms for the programs can adversely affect the operation and enforcement of statutes. Inadvertent use of a form with an expired date poses an opportunity for those looking for a means of disruption to challenge paying for services rendered, the validity of the collection of information, or legal requirement imposed by regulations or statutes.


18. 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 information collection does not employ statistical methods.


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