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Livestock, Poultry and Grain Market News

OMB: 0581-0033

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2013 SUPPORTING STATEMENT

for

LIVESTOCK, MEAT, GRAIN AND POULTRY MARKET NEWS REPORT

OMB NO. 0581-0033


NOTE TO REVIEWER:


Per the 60-day notice, in accordance with the Paperwork Reduction Act of 1995 (44 U.S.C. Chapter 35), this notice announces the merger of Agricultural Marketing Services’ Livestock and Seed Program with Poultry Programs the newly combined program will be called Livestock, Poultry and Seed Program (LPS). As a result of this merger the market news divisions will become Livestock, Poultry and Grain Market News (LPGMN). Intention to revise and rename the following information collections of 0581-0033 Poultry Market News Reports, 0581-0005 Grain Market News, 0581-0154 Livestock and Meat Market News into one and request extension approval of the information collection retitled Livestock, Poultry, Meat and Grain Market News Reports from the Office of Management and Budget.


We are merging the burden and responses of 0581-0033, “Poultry Market News Reports”, 0581-0005 “Grain Market News”, and 0581-0154 “Livestock and Meat Market News” into one collection which will be retitled 0581-0033 “Livestock, Poultry, Meat and Grain Market News”.


A. Justification.


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


Livestock, Poultry and Grain Market News provides a timely exchange of accurate and unbiased information on current marketing conditions affecting trade in livestock, poultry, eggs, meats, grain, and wool.


The Agricultural Marketing Act of 1946 (60 Stat. 1087-1091, as amended; 7 U.S.C. 1621-1627) (AMA) mandates data collection, reporting and recordkeeping requirements of market information for the purpose of anticipating and meeting consumer demand and bringing balance between production and utilization of agricultural products. The AMA was established to provide for the orderly marketing and efficient distribution of various agricultural products capable of being produced in abundance. This is accomplished through the collection and dissemination of marketing information on a market-area basis and thereby maintaining farm income by bringing balance between supply and demand for agricultural products. This action is viewed by Congress as being in the public interest.


The collection of information in this request is based on the AMA, section 203, principally, paragraphs (b) (g) and (k) that direct the Secretary of Agriculture to develop marketing methods for reducing the price spread between producer and consumer, bring a balance between production and utilization of agricultural products, and to collect, tabulate and disseminate agricultural marketing statistics.


Livestock, Poultry and Grain Market News [LPGMN] carries out these market stabilization responsibilities within the agricultural industries by gathering, summarizing and distributing current, unbiased, factual information regarding prices, supply, demand, trends, movement and other pertinent information affecting the trading of livestock, poultry, meat, eggs, grain, wool and their respective products. This is accomplished through cooperation between Federal and State agencies, producers, industry organizations and others in the development and effectuation of marketing programs to improve distribution processes. LPGMN also obtains information through direct observations, and contact with industry representatives. Usefulness of the information collected is evidenced by the number of times users access the market report web site and by the high level of cooperation received from respondents, although participation is strictly voluntary. LPGMN does not interfere with the operation of markets; however, its reports may influence market-related decisions.


The information collection requirements in this request are essential to carry out the intent of the AMS by providing the array of marketing information necessary to effectuate adequate product distribution and supply and to administer the program.


  1. 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.


LPGMN reports provide interested segments of the market chain and the general public with unbiased comprehensive livestock; poultry, meat, eggs, wool and grain market data which helps equalize the competitive position of all market participants. Timely information regarding market trends ensures efficient marketing and distribution of the nation’s food supplies to the benefit of producers and consumers alike. All LPGMN reports are available to the public on the Internet at; http://www.ams.usda.gov/AMSv1.0/lpsmarketnewspage . These market reports receive an estimate of approximately 53,289,800 page views. Also, additionally many of these reports are sent via e-mail to subscribers who have specifically requested this information


AMS, LPGMN, reporters communicate with buyers and sellers of livestock, poultry, meat, wool, grain and egg commodities on a daily basis through the use of telephone conversations, face to face meetings, facsimile transmissions, and electronic mail messages in order to collect the data.


LPGMN reports are used primarily by the livestock, poultry, wool, grain and egg industries to determine future production and marketing projections. Federal agencies involved in food purchase programs and institutional buying rely on LPGMN reports as a source of supply and price data, to make policy decisions, settle trade discrepancies and perform a variety of other functions. Other agencies including the Foreign Agricultural Service, Economic Research Service, and the National Agricultural Statistics Service, use market news data to track prices, wages, agricultural productivity, and serve as indicators of economic growth. LPGMN data is often used in value determination settlements, contracting, or to resolve international trade disputes. Economists, investors and agricultural analysts may use market news reports to make financial decisions based on available supplies and current pricing. LPGMN data is also widely used by the private sector including producers or farmers, processors and distributors, retailers, restaurants and institutions, consultants, brokers, forecasters, transportation and financial or educational institutions. Finally, in times of catastrophic events, LPGMN reports are a critical resource of information for Government policymakers as a source of shared information with producers, shippers, transportation companies and others.


The following form PY-90 is used for the Monthly Dried Egg Solids Stocks Report in collection of the inventory information from commercial dried egg product plants throughout the U.S.  The information provided on form PY-90 is input into a database creating a universal vehicle to keep market trend information proprietary, but yet publically available.


PY-90: Monthly Dried Egg Solids Stocks Report - Data is collected by LPGMN from commercial dried egg products plants throughout the U.S. Market news reporters collect the information primarily via facsimile transmissions and email. The information is then assembled, summarized, and disseminated monthly to interested parties by subscription, automatic telephone answering devices, newspaper, radio, and computer. The monthly release includes total pounds of egg products, by class, in cooperating firms’ possession at the close of the inventory month, and a percentage change from the previous month and previous year. The release of the summarized information is used by industry as an aid to make knowledgeable marketing decisions. Data collection for the Monthly Dried Egg Solids Stocks report provides information on stocks on hand of dried egg solids. Stock levels on hand may have a substantial bearing on prices and output of both processed and shell eggs, since dried egg solids may be stored for relatively long periods of time. The information collected using form PY-90 assures that marketing channels are filled, but not overflowing, preventing unnecessary overages and/or shortfalls.


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 REPONSES, AND THE BASIS FOR THE DECISION FOR ADOPTING THIS MEANS OF COLLECTION. ALSO DESCRIBE ANY CONSIDERATION OF USING INFORMATION TECHNOLOGY TO REDUCE BURDEN.


Information for many statistical reports is received via e-mail, telephone, face to face meetings, and facsimile transmission. These delivery methods have been in use for several years and are adequate. Statistical reports usually contain data which customers have on-hand for their internal recordkeeping as part of their ongoing business practice.


LPGMN currently offers the ability to submit data and transact with LPGMN via e-mail, telephone or fax. Electronic submission is not available. Data is collected through unstructured telephone interviews or free-form industry data sheets. No standard form is used; therefore, no electronic forms can be created. At this time, only 1 of 8 respondents for form PY-90 supply information via e-mail.


LPGMN provides free public access to market reports on the Internet at http://www.ams.usda.gov/AMSv1.0/lpsmarketnewspage LPGMN also offers a subscription service to LPGMN reports through Cornell University whereby registered users receive specific reports via e-mail, at no charge. Finally, LPGMN provides e-mail subscription service on a limited basis for reports in Adobe PDF format.


  1. 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.


LPGMN representatives are in constant contact with members of the livestock, poultry, meat, wool, egg and grain industries that provide the market information used in reports. These individuals and industry trade association officials are contacted regularly in an attempt to avoid a duplication of requests for information. These individuals would be readily aware if this type of information was available since it directly affects their business and marketing decisions. Similar information is not available that can be used or modified.


  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.


We require only a minimal amount of information, which can be supplied without data processing equipment or outside technical expertise. The primary sources of data are routinely used in all business transactions. Collection of the information requested by LPGMN does not present any additional effort on the part of small businesses or other small entities as this information is assembled and maintained by these entities as part of their standard, ongoing business practice for internal recordkeeping.


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.


Less frequent collection of data would not meet the demand by industry and public users of this information. Industry participants are provided with up-to-date information on the movement of product and the amount of product in storage on a current basis, so that necessary adjustments in product flow can be made accordingly. Decreased collection would not yield the timely data resource necessary to carry out the responsibilities of this program. There are no technical or legal obstacles to reducing burden.


  1. 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;


Current release times for market reports are consistent with the demand for the reports, that is, when the information is most useful to the user. Also, reports are disseminated when information is available. Information released on a quarterly basis would not be effective in providing information to the public when needed. Market changes occur daily; therefore, quarterly reports would not provide timely information. While that information might be useful for historical significance, the public’s demand for information on current conditions of trade would not be met.


There are no special circumstances that would require respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of the information.


  • 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 PREMITTED 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), and 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.


The Agency published the notice of information collection and request for comments in the Federal Register on May, 29, 2013, Volume 78, Number 103, pages 32226-32227. No comments have been received.


DESCRIBE EFFORTS TO CONSULT WITH PERSONS OUTSIDE THE AGENCY TO OBTAIN THEIR VIEWS ON THE AVAILABILITY OF DATA, FREQUENCY OF COLLECTION, THE CLARITY OF INSTRUCTION AND RECORDKEEPING, DISCLOSURE, OR REPORTING FORMAT (IF ANY), AND ON THE DATA ELEMENTS TO BE RECORDED, DISCLOSED OR REPORTED.


Market News works closely with industry trade organizations including American Meat Institute, American Sheep Council, National Cattlemen and Beef Association, National Pork Association, United Egg Producers, National Turkey Federation, National Chicken Council, and the U.S. Poultry and Egg Export Council. By attending the regular meetings of these organizations, Market News is able to receive industry feedback regarding market reports and respond accordingly by modifying the reports as needed.


Illinois Grain and Feed Association

3521 Hollis Dr. 1152 15th Street, NW National Chicken Council

Springfield, IL 62711 Suite 430

Jeffrey Adkisson Washington, D.C. 20005

217/787-2417 202/296-2622


National Cattlemen’s Beef Association National Hay Association

1301 Pennsylvania Ave., NW Suite 300 151 Treasure Island Cswy. #2

Washington DC 20004 St. Petersburg, FL 33706

202/347-0228 800/707-0014

LPGMN is in frequent contact with representatives of other government agencies and officials of the livestock, meat, wool, poultry, egg and grain industries, who rely on LPGMN data. Various Federal and State agencies are consulted with regards to the various aspects of data collection, availability, frequency, recordkeeping, disclosure, and reporting format. These agencies include the Economic Research Service, National Agricultural Statistics Service, Foreign Agriculture Service, and various State Departments of Agriculture.


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 present circumstances that preclude consultation at least every 3 years with representatives from whom information is obtained.

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


LPGMN does not provide any payment or gift to respondents.

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


Agency policy has established confidentiality as paramount in importance in LPGMN reporting with respect to individuals’ and firms’ proprietary trade information. Information provided by individual firms is combined with that from other firms before being issued in a report. Firms contacted by LPGMN respond voluntarily with complete confidence that their information will not be used in any way that would disclose their individual operations. This ensures individuals that their confidential trade information will not be identified. Jeopardizing confidentiality would taint the reputation of LPGMN. Information collected by LPGMN is handled responsibly in accordance with LPGMN policy.


  1. PROVIDE ADDITIONAL JUSTIFICATION FOR ANY QUESTIONS FOR A SENSITIVE NATURE, SUCH AS SEXUAL BEHAVIOR AND ATTITUDES, RELIGIOUS BELIEFS, AND OTHER MATTERS THAT ARE COMMONLY CONSIDERED PRIVATE.



Questions of a sensitive nature are not asked.

  1. PROVIDE ESTIMATES OF THE HOUR BURDEN OF THE COLLECTION OF INFORMATION.


Estimated cost to respondent: Since industry must keep an accurate record of each transaction for their own use, the cost to the respondent is only minimal. At the same time, the respondents receive information from the market news reports, therefore, deriving a benefit from an overview type of information. See separate spreadsheet for breakdown of burden.


The respondents estimated annual cost in providing information to the industry is $422,091.99 There were no costs for postage or printing for respondents.


It is estimated that approximately 75 percent of respondents are in sales and 25 percent are in administrative support. Based upon the Bureau of Labor Statistics data, the average hourly wages are $32.64 for sales staff under Business and financial operations, purchasing agents and buyers, farm products. The average hourly wages for office and administrative support staff of $16.57.


SUMMARY:

Total Burden Hours: 14,747

Sales: 11,060 hours @ $32.64 = $360,998.40

Administrative: 3,687 hours @ $16.57 = $ 61,093.59


TOTAL: $422,091.99


Wages were obtained from the National Compensation Survey: Occupational Wages in the United States, May 2011. The survey can be found at:

http://www.bls.gov/ncs/ocs/sp/nctb1512.pdf



  1. PROVIDE AN ESTIMATE OF THE TOTAL ANNUAL COST BURDEN TO RESPONDENTS OR RECORDKEEPERS RESULTING FROM THE COLLECTION OF INFORMATION.


There are no start-up cost burdens to respondents not included in items 12 and 14.


  1. PROVIDE ESTIMATES OF ANNUALIZED COST TO THE FEDERAL GOVERNMENT. ALSO, PROVIDE A DESCRIPTION OF THE METHOD USED TO ESTIMATE COST, WHICH WOULD 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.


The estimated annual cost to the Federal Government to collect market information during regular contact with industry sources is $2,751,075.60.

This number is calculated on the basis that the average LPGMN reporter is a GS-11 for, which the average hourly salary rate including benefits is $28.91. With 61 LPGMN reporters spending 75 percent of their time doing data collection, the approximate cost for salaries and benefits is $2,751,075.60


1,560 hours x $28.91 = $45,099.60 x 61 reporters = $2,751,075.60


Other costs associated directly with data collection include travel, printing, mailing and operational expenses, these costs for FY-2013 are estimated at $978,000. Therefore, the costs for regular data collection are estimated at $3,729,075.60.


Previous cost estimates for this collection package were erroneously based on costs associated with form PY-90 and costs for the preparation of this information collection package but failed to capture all costs for services provided by LPGMN. The full function of LPGMN cannot be accurately reflected on AMS-71 due to the lack of forms associated with LPGMN. Further, previous cost estimates encompassed rulemaking activity which should not have been included here. The cost estimate indicated above has been computed to reflect costs to the Federal Government for information collection activities required by the LPGMN.


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


Overall the 0581-0033 package has had an increase due to the merger of the following collections; 0581-0005: Grain Market News Report and 0581-0154: Livestock and Meat Market News Reports. By combining these three collections overhead expenditures will be reduced to not only the public but the agency. Advancement of technology within the industry has enabled more participation amongst the LPGMN reporters and the industry to collect an even broader base of information which provides a more precise image of current market conditions without undue burden. There is an overall minimal difference due to rounding from the previous submission.


0581-0033: Poultry Market News Report – Has shown a decrease since the last submission as a result of the consolidation of several individual poultry reports into regional reports. In addition there has been some consolidation of industry contacts along with the closing of plants which has also decreased the amount of burden to the industry. Respondents completing form PY-90 submit this information on a monthly basis, the number of responses per respondent 108 (annually) has been incorporated.


0581-0005: Grain Market News Report – An increase from the previous submission has occurred due to several factors. First, unseasonable weather throughout much the United States has prompted additional reports as well as industry contacts. A prime example is the expansion of hay reports due to widespread drought conditions throughout most of the nation. These reports have aided producers and buyers with up to date prices, as well as an overview of supply and demand. The volatility within the grain markets from not only weather related issues, but economic factors have also spurred interest to participate and inquire about LPGMN reports. LPGMN has also expanded market coverage through the addition of bio-energy and organic reports. These additional reports were created upon request by not only the agriculture industry but the public for unbiased price discovery.


0581-0154: Livestock and Meat Market News Reports – More information has been reported due to not only advanced technical communication but growing interest in providing and receiving up to date and accurate information for marketing decisions. However, despite the decrease in burden hours and respondents there has been a change in type of respondents. Due to mandatory livestock reporting which involves slaughter cattle, hogs and lambs with those respondents now required to report in a different collection there has been an increase of interest from those involved in the feeding aspect of the industry.


The current overall burden has decreased by 13,698.58 hours. Overall number of annual responses also decreased for a total of 269,159 responses for the combined collections.


REASON




TYPE OF CHANGE


PREVIOUS

NEW


REGS

BURDEN

BURDEN

DIFFERENCE

PY-90

Monthly Dried Egg Solids Stocks Report, Dec. in response

8.96

7.97

-0.99

ADJ

7 U.S.C. 1621-1622

Regular Contact w/Industry for Price and Supply Data (includes phone calls), Dec in response

17,990.25

4,181.13

-13,809.12

ADJ

7 U.S.C. 1621-1627

Livestock & Meat Market News Reports, Dec in response

10,390.84

5,457.82

-4,933.02

ADJ

7 U.S.C., 1621-1627

Grain Reports, Inc. in response

39.96

4,454.74

4,414.78

ADJ

7 U.S.C., 1621-1627

Phone calls for Hay Reports [previous Alfalfa Reports], Inc. in response

15.98

645.75

629.77

ADJ

TOTAL

28,445.99

14,747.41

-13,698.58



  1. 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.

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


Market News is seeking continued approval not to display the expiration date on the form associated with this information collection. The Market News office in Atlanta, Georgia reproduces the form locally and distributes the form to respondents on a monthly basis. The display of the expiration date on the form leads to confusion on the part of the respondents.


  1. EXPLAIN EACH EXCEPTION TO THE CERTIFICATION STATEMENT IDENTIFIED IN ITEM 19, “CERTIFICATION FOR PAPERWORK REDUCTION ACT SUBMISSIONS,” OF OMB FORM 83-1.


There are no exceptions to the certification statement identified in item 19.

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