0269 SS extension 110713_rev

SUPPORTING STATEMENT

WESTERN ALASKA COMMUNITY DEVELOPMENT QUOTA (CDQ) PROGRAM

OMB CONTROL NO. 0648-0269

This action requests extension of this information collection.

INTRODUCTION

National Marine Fisheries Service (NMFS) manages the groundfish fisheries in the exclusive economic zone (EEZ) off Alaska. NMFS manages the groundfish and crab fisheries of the Bering Sea and Aleutian Islands management area (BSAI) under the Fishery Management Plan for Groundfish of the Bering Sea and Aleutian Islands Management Area and the Fishery Management Plan for Bering Sea/Aleutian Islands King and Tanner Crabs (FMPs). The North Pacific Fishery Management Council (Council) prepared the FMPs under the authority of the Magnuson-Stevens Fishery Conservation & Management Act (16 U.S.C. 1801 et seq.) as amended in 2006. The International Pacific Halibut Commission and NMFS manage fishing for Pacific halibut through regulations established under the authority of the Northern Pacific Halibut Act of 1982. Regulations implementing the FMPs appear at 50 CFR parts 300, 679, and 680.

The Western Alaska Community Development Quota (CDQ) Program is an economic development program associated with Federally managed fisheries in the Bering Sea and Aleutian Islands Management Area (BSAI). The CDQ Program receives apportionments of the annual catch limits for a variety of commercially valuable species in the BSAI, which are in turn allocated among six different non-profit managing organizations representing different affiliations of communities (CDQ groups). The CDQ Program redistributes a portion of commercially important BSAI fisheries species to adjacent communities. There are 65 communities participating in the program. CDQ groups use the revenue derived from the harvest of their fisheries allocations as a basis both for funding economic development activities and for providing employment opportunities. Thus, the successful harvest of CDQ Program allocations is integral to achieving the goals of the program.

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information necessary.

The CDQ Program was established to provide eligible western Alaska villages with the opportunity to participate and invest in BSAI fisheries, to support economic development in western Alaska, to alleviate poverty and provide economic and social benefits for residents of western Alaska, and to achieve sustainable and diversified local economies in western Alaska.

The fisheries primarily affected include the halibut CDQ, fixed gear sablefish CDQ, and pollock CDQ fisheries. All six CDQ groups annually are allocated groundfish CDQ, halibut CDQ, and crab CDQ. These groups participate, either directly or indirectly, in the commercial harvest of these allocations.

CDQ groups receive royalties from the successful harvest of CDQ by commercial fishing companies, as well as access to employment and training opportunities for their communities’

residents. Royalties and income from CDQ harvesting activities are used to fund economic development projects in CDQ communities. Based on the most recently available information, the CDQ groups received approximately $60 million in royalties from the harvest of their CDQ allocations in 2009.

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.

a. Groundfish/Halibut CDQ and Prohibited Species Quota (PSQ) Transfer Request

[NO CHANGES]

CDQ groups may request that NMFS transfer groundfish CDQ, halibut CDQ, or Prohibited Species Quota (PSQ) from one group to another group by each group submitting a completed transfer request as described in § 679.5(n)(1). NMFS will approve the transfer request if the CDQ group transferring quota to another CDQ group has sufficient quota available for transfer. If NMFS approves the request, NMFS will make the requested transfer(s) by decreasing the account balance of the CDQ group from which the CDQ or PSQ species is transferred and by increasing the account balance of the CDQ group receiving the transferred CDQ or PSQ species. The PSQ will be transferred as of the date NMFS approves the transfer request and is effective only for the remainder of the calendar year in which the transfer occurs. NMFS will not approve transfers to cover overages of CDQ or PSQ. The transfer of either CDQ or PSQ may occur during any month of the year, and either may be transferred without the other.

A CDQ group may transfer all or part of its annual CDQ or PSQ to another group for several reasons, including but not limited to:

♦ Changes in, or the non-availability of, a group’s harvesting partner;

♦ Length of a particular non-CDQ fishery season;

♦ Availability of a given target species; and

♦ Weather or seasonal conditions impacting smaller vessels

In order for an inter-CDQ group transfer to be approved, both parties must be already established and recognized by NMFS as a CDQ group prior to the transfer. The CDQ or PSQ would be transferred as of the date NMFS approves the transfer request. Transfers will continue to be effective only for the remainder of the calendar year in which a transfer occurs.

Six CDQ groups are in the CDQ Program, and all six have the hardware and software to accomplish online transfers. Industry requested the option to submit transfer requests electronically in order to react quickly to changing conditions and to realize harvesting efficiencies. When using the online submittal method, the respondent must enter the NMFS Person ID, password, and Transfer Key, previously provided by NMFS, instead of name, address, telephone number, fax number, and email address. These three pieces of information are provided by NMFS after an applicant is approved for participation in the CDQ Program. A paper or electronic request form must be completed with all information fields accurately filled in by transferors and transferees, and all required additional documentation must be attached.

CDQ groups may transfer groundfish CDQ, halibut CDQ, and PSQ online from one CDQ group to another, instead of each group submitting a transfer request directly to NMFS. Rather than NMFS reviewing each request prior to transfer to ensure that the group providing CDQ has adequate quota available to transfer, this check would be done automatically by NMFS’ catch accounting system. This form should be completed and signed by a representative from each CDQ group proposing to transfer annual amounts.

Submit the completed application via one of the following means:

Electronically [email protected], using a NMFS-approved format

[attachment to e-mail]

By fax 907-586-7465

By mail Sustainable Fisheries Division

NMFS Alaska Region

PO Box 21668

Juneau, AK 99802-1668

Online [expected mid-year 2014]

For questions or additional information, call NMFS Sustainable Fisheries at 907-586-7228.

Groundfish/Halibut CDQ and PSQ transfer request

Transferring CDQ group information.

Group Name or initials

CDQ group number.

CDQ representative

Business Telephone Number, Business Fax Number, and Business e-mail address

Name and signature

Receiving CDQ group information

Group name or initials

CDQ group number

CDQ representative

Business Telephone Number, Business Fax Number, and Business e-mail Address

Name and signature

CDQ amount transferred.

Species name or species category

Area

Amount

Groundfish (to the nearest 0.001 mt)

Halibut (lb net weight)

PSQ amount transferred.

Species name or species category

Crab Zone

Amount (number of animals)

Transfer year

Certification of transferor

Non-electronic submittal

Transferor's designated representative must sign and date the application

certifying that all information is true, correct, and complete

Electronic submittal

Transferor's designated representative must log into the system and create a transfer request as indicated on the computer screen.

By using the transferor's NMFS ID, password, and Transfer Key and submitting the transfer request, the designated representative certifies that all information is true, correct, and complete

Certification of transferee

Non-electronic submittal

Transferee's designated representative must sign and date the application

certifying that all information is true, correct, and complete

Electronic submittal

Transferee's designated representative must log into the system and create a transfer request as indicated on the computer screen.

By using the transferee's NMFS ID, password, and Transfer Key and submitting the transfer request, the designated representative certifies that all information is true, correct, and complete.

CDQ or PSQ transfer request, Respondent
Number of respondents Total annual responses Frequency of response = 2 Total burden hours 30 minutes x 12 Total personnel cost ($25/hr x 6 hr) Total miscellaneous costs (11.10) Copy (0.05 x 12 = 0.60) Fax (2 x 5 = 10) Email and planned online (0.05 x 10 = 0.50)	6 12 6 hr $150 $11

CDQ or PSQ transfer request, Federal Government
Total annual responses Total burden hours Time per response = 20 minutes Total personnel cost ($25/hr x 4) Total miscellaneous cost	12 4 hr $100 0

b. Application for Approval of Use of Non-CDQ Harvest Regulations [NO CHANGES]

The fisheries management regulations governing the CDQ fisheries were integrated into the regulations governing the concurrent fisheries for groundfish, halibut, and crab -- often

termed the ‘‘non-CDQ’’ fisheries -- to comply with certain changes made to the Magnuson-Stevens Act. Section 305(i)(1) of the Magnuson-Stevens Act was amended on July 11, 2006, by the Coast Guard and Maritime Transportation Act (Coast Guard Act) (Pub. L. 109–241). The Coast Guard Act replaced all of the existing language in section 305(i)(1) to ensure that they are no more restrictive than the regulations in effect for comparable non-CDQ fisheries managed under individual fishing quotas or cooperative allocations.

NMFS interprets the statement ‘‘in a manner no more restrictive than for other participants in the applicable sector’’ from the Magnuson-Stevens Act to mean that the fishery management regulations associated with regulating the harvest of CDQ allocations should be no more costly, complex, or burdensome than those that apply to comparable non-CDQ sectors managed under IFQs or cooperative allocations. Vessels that are participating in a voluntary fishery cooperative in a non-CDQ sector are authorized to conduct groundfish CDQ fishing under the same regulations that apply while such vessels are used to directed fish in the non-CDQ fisheries and are not required to comply with the CDQ operational regulations at § 679.32(c)(3)(i).

A CDQ group representative, a representative of an association representing CDQ groups, or the authorized representative of a voluntary fishing cooperative may submit an application to use alternative CDQ harvest regulations. A completed application consists of an application form and a copy of the cooperative contract or an affidavit, as described below:

♦ Application form. The application to use alternative CDQ harvest regulations is available on the NMFS Alaska Region Web site at www.alaskafisheries.noaa.gov. All information fields must be accurately completed, including information about the applicant, the voluntary fishing cooperative, and the vessels participating in the voluntary cooperative.

♦ Cooperative contract or affidavit. A copy of the current voluntary fishing cooperative contract demonstrating participation in the cooperative by the owners of each of the vessels named on the application form or an affidavit that includes the information required in § 679.32(e)(3)(i)(B).

NMFS will approve an application to use non-CDQ harvest regulations when it determines that:

♦ all of the information submitted with the application complies with the requirements of §679.32(e)(2) and (3),

♦ the vessels listed on the application represent a majority of vessels participating in an applicable sector, and

♦ the CDQ harvest regulations are more restrictive than the non-CDQ regulations for the applicable sector.

NMFS will issue an initial administrative determination (IAD) disapproving the application and the reasons for its disapproval if the application is incomplete, the voluntary cooperative does not represent a majority of the vessels participating in the sector, or the CDQ harvest regulations are not more restrictive than the non-CDQ regulations for the applicable sector. An applicant who receives an IAD disapproving an application may appeal under the procedures set forth at

§ 679.43.

An application requesting approval for the use of non-CDQ harvest regulations may be submitted to NMFS at any time. Once approved, an application to use alternative CDQ harvest regulations is effective as of the date on which NMFS approves the application. The approval is effective until the requesting entity withdraws its application, or until there is a change in the membership of the voluntary cooperative, whichever occurs first.

The entity that received approval for use of non-CDQ harvest regulations must promptly notify NMFS of any changes in the voluntary fishing cooperative’s membership. Amendments to an approved application to use alternative CDQ harvest regulations may be submitted to NMFS at any time.

The completed application may be submitted by one of the following methods:

Electronically [email protected], using a NMFS-approved format

[attachment to e-mail]

By fax 907-586-7465

By mail Sustainable Fisheries Division

NMFS Alaska Region

PO Box 21668

Juneau, AK 99802-1668

For questions or additional information, call NMFS Sustainable Fisheries at 907-586-7228.

Application for Approval of Use of Non-CDQ Harvest Regulations

Indicate type of application: new or amendment

Block A – Voluntary Fishery Cooperative Information

Name of Voluntary Cooperative

Name of Cooperative’s Representative

Permanent Business Mailing Address

Business Telephone Number, Business Fax Number, and Business E-mail Address

Block B – Applicant Information

Check here if applicant is the same as the entity/person identified in Block A

If YES, proceed to Block C

Name of Organization

Name of Organization’s Representative

Permanent Business Mailing Address:

Business Telephone Number, Business Fax Number, and Business E-mail Address

Block C– Certification

Printed Name and Signature of Representative and Date Signed

Block D. Cooperative Vessel Information

Vessel Name

Federal Fisheries Permit No.

License Limitation Program No.

Attachment

Voluntary fishing cooperative contract or affidavit

Name of the authorized representative of the cooperative

Printed names and signatures of each vessel owner that is a party to the voluntary cooperative

Vessel name, FFP number, and LLP license number for each vessel managed under the cooperative

Target species, processing mode, gear types, and management area(s) associated with cooperative’s Federal fishing operations

If voluntary fishing cooperative contract does not contain this information, the applicant also must submit a written affidavit that provides all of the information that is not included in the cooperative contract.

Approval of Non-CDQ Harvest Regulations, Respondent
Number of respondents Total annual responses Frequency of response = 1 Total burden hours 5 hours x 1 Total personnel cost ($25/hr x 5 hr) Total miscellaneous costs (5.05) Fax ($5 x 1 = 5) Copy (0.05 x 1 = 0.05)	1 1 5 hr $125 $5

Approval of Non-CDQ Harvest Regulations, Federal Government
Total annual responses Total burden hours Time per response (1 hr x 1) Total personnel cost ($25/hr x 1) Total miscellaneous cost	1 1 hr $25 0

c. Alternative Fishing Plan [REMOVED]

The “alternative fishing plan” under the CDQ Program was removed by a final rule published in September 26, 2012 (77 FR 59053). The action standardized the monitoring options for longline catcher/processors in both the CDQ and non-CDQ fisheries, so the alternative fishing plan regulations are no longer necessary.

It is anticipated that the information collected will be disseminated to the public or used to support publicly disseminated information. NOAA Fisheries will retain control over the information and safeguard it from improper access, modification, and destruction, consistent with NOAA standards for confidentiality, privacy, and electronic information. See response to Question 10 of this Supporting Statement for more information on confidentiality and privacy.

The information collection is designed to yield data that meet all applicable information quality guidelines. Prior to dissemination, the information will be subjected to quality control measures and a pre-dissemination review pursuant to Section 515 of Public Law 106-554.

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.

The Groundfish/halibut CDQ or PSQ transfer request and Application for Approval of Use of Non-CDQ Harvest Regulations are available in a fillable format on the NMFS Alaska Region website at http://www.alaskafisheries.noaa.gov. NMFS expects that the online access to the quota transfer form will be available mid-year 2014.

4. Describe efforts to identify duplication.

No duplication exists with other information collections.

5. If the collection of information involves small businesses or other small entities, describe the methods used to minimize burden.

The entities directly regulated are the six CDQ groups that participate in the halibut, sablefish, groundfish, and pollock CDQ fisheries in the BSAI. CDQ groups are considered to be small entities under the RFA’s categorization of small, non-profit organizations; they are not significantly impacted.

In addition, a voluntary fishing cooperative consisting of vessels that participate in a non-CDQ sector as well as conduct groundfish CDQ fishing is not considered a small business.

6. Describe the consequences to the Federal program or policy activities if the collection is not conducted or is conducted less frequently.

The purpose of the CDQ Program is to provide Western Alaska communities a method to support regionally based, commercial seafood or other fisheries-related businesses. Under the CDQ Program, 65 eligible Western Alaska communities have organized into six separate CDQ groups. Without this program, these small communities would be economically devastated.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

Not Applicable.

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 Federal Register notice published on May 20, 2013 (78 FR 29331) solicited public comments on the information collection. One comment was received; however, the comment did not relate to the collection of information.

A questionnaire was prepared and submitted to representatives of each of the six CDQ groups as well as the fishing cooperative whose vessels conduct CDQ and non-CDQ fishing.

NMFS received one response on behalf of six CDQ groups. The comments are summarized below. Question No. 3 asked about miscellaneous costs for each of the two forms. NMFS received comments for both questions that differed from NMFS’ estimate of miscellaneous costs. Although the comments did not include reasons why their cost estimate was higher, one response implied that their response included personnel time and cost. In the future, NMFS will clarify the miscellaneous cost question to state that the estimated miscellaneous costs are only recordkeeping costs and do not include personnel time and cost.

Groundfish/Halibut CDQ and Prohibited Species Quota (PSQ) Transfer Request at http://alaskafisheries.noaa.gov/sustainablefisheries/bycatch/salmon/chinook/forms/cdqpsq_transfer_nonchinook.pdf
[X] YES, I use this form [__] Not applicable
	YES (X)	NO (X)	COMMENTS	No Comment (X)
1. Is the information requested on the form easily available? If NO, explain.	6
2. Is our estimate of 30 minutes per transfer for completion and submittal of a paper transfer accurate? If NO, explain.	6
3. Is our estimate of $5.05 per transfer for completion and submittal of a paper transfer accurate and reasonable? If NO, explain		6	We estimate that thirty minutes to complete the application would cost approximately $24.00.
4. NMFS is scheduled to have online transfer available in mid-2014. Would it be less expensive or take less time to complete an online application? Explain.	6		An online application would eliminate the extra steps required to print and scan or mail the form.
5. Are the instructions for the transfer request clear and understandable? If NO, explain.	6
6. Provide any additional comments on any aspect of the CDQ requirements.			For purposes of efficiency, the CDQ entities would prefer an online medium for all NMFS required forms/applications.	6

Application for Approval of Use of Non-CDQ Harvest Regulations at http://alaskafisheries.noaa.gov/ram/cdq/noncdqharvestregsapp.pdf
[X] YES, I use this form [__] Not applicable
	YES (X)	NO (X)	COMMENTS	No Comment (X)
1. Is the information requested on the form easily available? If NO, explain.	6
2. Is our estimate of 5 hours for completion and submittal of application accurate? If NO, explain.	6		The last time the CDQ groups used this form was March 2012. On that occasion, 5 hours was an appropriate estimate of time spent coordinating with the FLCC to obtain vessel information, complete an affidavit, and draft the submission letter.
3. Is our estimate of $5.05 per application for completion and submittal accurate and reasonable? If NO, explain		6	We estimate that five hours to complete the application would cost approximately $240.00.
4. Are the instructions for the application clear and understandable? If NO, explain.	6
5. Provide any additional comments on any aspect of the CDQ requirements.				6

9. Explain any decisions to provide payments or gifts to respondents, other than remuneration of contractors or grantees.

No payment or gift will be provided under this program.

10. Describe any assurance of confidentiality provided to respondents and the basis for assurance in statute, regulation, or agency policy.

As stated on the transfer form and in the regulations, the information collected is confidential under section 402(b) of the Magnuson-Stevens Act. It is also confidential under NOAA Administrative Order 216-100, which sets forth procedures to protect confidentiality of fishery statistics.

All information collected is part of a system of records: NOAA #19, published April 17, 2008.

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.

Information collected for the CDQ Program does not include information of a private or sensitive nature.

12. Provide an estimate in hours of the burden of the collection of information.

Estimated total unique respondents: 7, increased from 6. Estimated total responses: 13. Estimated total burden: 11 hr. Estimated total personnel cost: $275, decreased from $ 425.

13. Provide an estimate of the total annual cost burden to the respondents or record-keepers resulting from the collection (excluding the value of the burden hours in Question 12 above).

Estimated total miscellaneous costs: $16, increased from $2.

14. Provide estimates of annualized cost to the Federal government.

Estimated total responses: 13. Estimated total burden: 5 hr, decreased from 18 hr. Estimated total personnel cost: $125, decreased from $450, based on $25/hr the average wage equivalent to a GS-9 employee in Alaska, including COLA. Estimated total miscellaneous costs: $0, decreased from $2.

15. Explain the reasons for any program changes or adjustments.

No program changes are made in this action. Adjustments are made to correct the number of participants using each form and to add costs for submitting a fax.

Groundfish/halibut CDQ or PSQ transfer request

A form, CDQ or PSQ Transfer Request, was removed and replaced by two separate forms when

a new program was created for the management of Chinook salmon prohibited species catch in the Bering Sea pollock fishery managed under the American Fisheries Act implemented by a final rule RIN No. 0648-AX89 (75 FR 53026, August 30, 2010). One new transfer form, called the “Application for Transfer of Bering Sea Chinook Salmon PSC Allocations,” was created for the transfer of Chinook salmon and eventually approved under OMB Control No. 0648-0393. The second new form, called “Groundfish/Halibut CDQ and Prohibited Species Quota (PSQ)

Transfer Request,” was approved under OMB Control No. 0648-0269. The original form was analyzed to have 6 respondents, 48 responses, 12 hr burden, $300 personnel costs, and $2 miscellaneous cost. This revised form was analyzed to have 6 respondents, 12 responses, 6 burden hours, $150 personnel cost, and $61 miscellaneous cost.

a decrease of $150 personnel costs, $150 instead of $300

an increase of $10 miscellaneous costs, $11 instead of $1 (fax costs are added)

Application for approval of use of non-CDQ harvest regulations

an increase of $4 miscellaneous costs, $5 instead of $1 (fax costs are added).

16. For collections whose results will be published, outline the plans for tabulation and publication.

The information obtained from this collection is not expected to be published for statistical use.

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.

Not Applicable.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.

APPENDIX

QUESTIONS FOR OMB CONTROL NUMBER 0648-0269 COLLECTION

WESTERN ALASKA COMMUNITY DEVELOPMENT QUOTA (CDQ) PROGRAM

(July 24, 2013)

The Office of Management and Burden (OMB) requires each Federal agency to ask for comments from non-agency persons who are required to comply with recordkeeping and reporting regulations for that agency. To satisfy the OMB paperwork requirements for renewal of OMB Control Number 0648-0269 (Expiration Date 12/31/2013). NMFS Alaska Region is requesting your opinion on the CDQ Program collection. NMFS currently requires the use of two forms in the CDQ Program collection:

♦ Groundfish/Halibut CDQ and Prohibited Species Quota (PSQ) Transfer Request – used for CDQ and PSQ transfer between CDQ groups (§ 679.5(n))

♦ Application for Approval of Use of Non-CDQ Harvest Regulations – [one-time use only] used by a voluntary fishing cooperative in a non-CDQ sector that requests authority to conduct groundfish CDQ fishing under the same regulations that apply while such vessels are used to directed fish in the non-CDQ fisheries so they are not fishing under two different sets of regulations (§ 679.32(e))

Please take a few minutes to let us know what you think about details of these two forms. Also, we would appreciate any comments you may have on any aspect of this collection.

Respond to YES or NO answers and NO COMMENT answers with an “X”. Enter comments in the COMMENT section. Then, email your responses to me at [email protected] no later than Friday, August 2, 2013.

If you have questions about the questionnaire or need additional information, please call me at 907-586-7008. Thanks in advance.

Respectfully,

Patsy A. Bearden

Sustainable Fisheries Division

NMFS Alaska Region

Telephone (907)586-7008

Fax (907) 586-7465

e-mail [email protected]

Groundfish/Halibut CDQ and Prohibited Species Quota (PSQ) Transfer Request at http://alaskafisheries.noaa.gov/sustainablefisheries/bycatch/salmon/chinook/forms/cdqpsq_transfer_nonchinook.pdf
[__] YES, I use this form [__] Not applicable
	YES (X)	NO (X)	COMMENTS	No Comment (X)
1. Is the information requested on the form easily available? If NO, explain.
2. Is our estimate of 30 minutes per transfer for completion and submittal of a paper transfer accurate? If NO, explain.
3. Is our estimate of $5.05 per transfer for completion and submittal of a paper transfer accurate and reasonable? If NO, explain
4. NMFS is scheduled to have online transfer available in mid-2014. Would it be less expensive or take less time to complete an online application? Explain.
5. Are the instructions for the transfer request clear and understandable? If NO, explain.
6. Provide any additional comments on any aspect of the CDQ requirements.

Application for Approval of Use of Non-CDQ Harvest Regulations at http://alaskafisheries.noaa.gov/ram/cdq/noncdqharvestregsapp.pdf
[__] YES, I use this form [__] Not applicable
	YES (X)	NO (X)	COMMENTS	No Comment (X)
1. Is the information requested on the form easily available? If NO, explain.
2. Is our estimate of 5 hours for completion and submittal of application accurate? If NO, explain.
3. Is our estimate of $5.05 per application for completion and submittal accurate and reasonable? If NO, explain
4. Are the instructions for the application clear and understandable? If NO, explain.
5. Provide any additional comments on any aspect of the CDQ requirements.

19