Justification -- Expanded PGA Message Set Pilot Test

Request for Approval under the "Generic Clearance for the Collection of Routine Customer Feedback" (OMB Control Number: 1513-0132)

TITLE OF INFORMATION COLLECTION:

Expanded Pilot Test - Automated Commercial Environment and Partner Government Agency Message Set for Imports of Articles Regulated by the Alcohol and Tobacco Tax and Trade Bureau.

PURPOSE:

The Alcohol and Tobacco Tax and Trade Bureau (TTB) of the Department of the Treasury administers several provisions of the U.S. Code that relate to the importation of alcohol beverages, industrial spirits, and tobacco products. TTB is a participant in the effort to implement the International Trade Data System (ITDS), which is led by Customs and Border Protection (CBP) and involves 47 other Federal agencies with jurisdiction over imports and exports.

ITDS is an interagency program to establish a single electronic access point through which importers and exporters may submit the data required by government agencies for international trade transactions. The Security and Accountability for Every Port Act (SAFE Port Act; Pub. L. 109-347) of 2006 mandated participation in ITDS for all agencies that require documentation for clearing or licensing the importation and exportation of cargo.

Currently, importers and exporters must submit data to multiple agencies through various channels, often in paper form. The Automated Commercial Environment (ACE) in ITDS provides a "single window" that allows importers and exporters to enter one set of data for each consignment of imported or exported articles. Thus, the system has the potential to reduce overall paperwork burden for importers and exporters.

The Partner Government Agency (PGA) Message Set defines the additional information TTB requires from importers to complete TTB's import processes. After the data are entered, ITDS automatically distributes relevant data to each government agency, including TTB.

An earlier PGA message set pilot test for up to 100 respondents was approved by OMB under control number 1513-0132 in July 2015. This expanded test pilot information collection, for up to 300 respondents, will allow TTB and importers of articles that TTB regulates to thoroughly test use of the Automated Commercial Environment (ACE) and the Partner Government Agency (PGA) Message Set before going live in the system later this year. Importers will volunteer to participate in the expanded pilot test. Most of the information that importers will be required to submit through ACE is already required by TTB's regulations. However, importers will be required to submit their TTB permit number as part of the pilot. All importers of TTB­ regulated products are required to obtain a permit from TTB, and thus have a permit number, but they have not previously had to provide that number in order to complete an importation.

DESCRIPTION OF RESPONDENTS:

Respondents are current TTB permit holders and import articles that are regulated by TTB.

TYPE OF COLLECTION: (Check one)

[ ] Customer Comment Card/Complaint Form

[X] Usability Testing (e.g., Website or Software)

[ ] Focus Group

[ ] Customer Satisfaction Survey

[ ] Small Discussion Group

[ ] Other:

CERTIFICATION:

I certify the following to be true:

1. The collection is voluntary.

2. The collection is low-burden for respondents and low-cost for the Federal Government.

3. The collection is non-controversial and does not raise issues of concern to other Federal agencies.

4. The results are not intended to be disseminated to the public.

5. Information gathered will not be used for the purpose of substantially informing influential policy decisions.

6. The collection is targeted to the solicitation of opinions from respondents who have experience with the program or may have experience with the program in the future.

Name:

Andrew Malone, Program Manager (202-453-2188).

To assist review, please provide answers to the following questions:

Personally Identifiable Information:

1. Is personally identifiable information (PII) collected? [ ] Yes [ X ] No

2. If "Yes," will any information that is collected be included in records that are subject to the Privacy Act of 1974? [ ] Yes [ ] No [ X ] N/A

3. If "Yes," has an up-to-date System of Records Notice (SORN) been published?

[ ] Yes [ ] No [ X ] N/A

Gifts or Payments:

Is an incentive (e.g., money or reimbursement of expenses, token of appreciation) provided to participants? [ ] Yes [X] No

BURDEN HOURS

Category of Respondent	No. of Respondents	Participation Time	Burden
Private Sector	300	4.5 hours/respondent	1,350 hours
TOTALS	300	4.5 hours/respondent	1,350 hours

The pilot test will be conducted by no more than 300 respondents, who will make approximately 30 entries into ACE using TTB's PGA message set. Based on experience from the initial pilot test, each entry could take up to 7 minutes for the respondent to complete, for a total of 3.5 hours of testing per respondent. In addition, each respondent will take part in one telephone conference call of approximately one hour. Thus, each respondent will devote approximately 4.5 hours to the pilot test.

(This is a reduction in the 12 hours per respondent burden described in the initial pilot test, which estimated that each of the 100 respondents would require 20 minutes to complete each ACE entry and would participate in two telephone calls. This reduction in per entry burden is based on respondent feedback obtained during the initial pilot test.)

FEDERAL COST: The estimated annual cost to the Federal government is $0.00. The ITDS, including ACE and the PGA Message Set, are being developed independently of this information collection. This information collection imposes negligible marginal costs on Federal agencies.

If you are conducting a focus group, survey, or plan to employ statistical methods, please provide answers to the following questions:

The selection of you r targeted respondents.

1. Do you have a customer list or something similar that defines the universe of potential respondents and do you have a sampling plan for selecting from this universe? [ X ] Yes [ ] No

If the answer is yes, please provide a description of both below (or attach the sampling plan). If the answer is no, please provide a description of how you plan to identify your potential group of respondents and how you will select them.

All importers of TTB-regulated products are required by law to obtain a permit from TTB, and TTB maintains a list of these permit holders. In the Federal Register of August 15, 2015 (80 FR 47558), TTB published a notice announcing the ITDS pilot test and requesting volunteers from among its import permit holders to participate in the test. Participants in the pilot test will have available to them a set of Trade Filing Instructions, which provide detailed information on how to input this data into ACE. TTB made the Trade Filing Instructions available for public review and comment through the same Federal Register notice. As a result of that notice TTB continues to receive requests from TTB-regulated importers to participate in the PGA Message Set pilot test. TTB will draw from these volunteers for participants in this expanded pilot test.

Administration of the Instrument.

1. How will you collect the information? (Check all that apply)

[ X ] Web-based or other forms of Social Media [ X ] Telephone

[ ] In-person [ ] Mail

[ ] Other, Explain: _{_________________________________.}

2. Will interviewers or facilitators be used? [ ] Yes [X] No

Please make sure that all instruments, instructions, and scripts are submitted with the request.

Instructions/or completing Request/or Approval under the "Generic Clearance/or the Collection of Routine Customer Feedback"

TITLE OF INFORMATION COLLECTION: Provide the name of the collection that is the subject of the request. (e.g. Comment card for soliciting feedback on xxxx.)

PURPOSE: Provide a brief description of the purpose of this collection and how it will be used.

If this is part of a larger study or effort, please include this in your explanation.

DESCRIPTION OF RESPONDENTS: Provide a brief description of the targeted group or groups for this collection of information. These groups must have experience with the program.

TYPE OF COLLECTION: Check one box. If you are requesting approval of other instruments under the generic, you must complete a form for each instrument.

CERTIFICATION: Please read the certification carefully. If you incorrectly certify, the collection will be returned as improperly submitted or it will be disapproved.

Personally Identifiable Information: Provide answers to the questions. Note: Agencies should only collect PII to the extent necessary, and they should only retain PII for the period of time that is necessary to achieve a specific objective.

Gifts or Payments: If you answer yes to the question, please describe the incentive and provide a justification for the amount.

BURDEN HOURS:

Category of Respondents: Identify who you expect the respondents to be in terms of the following categories: (1) Individuals or households; (2) Private Sector; (3) State, local, or tribal governments; or (4) Federal Government. Only one type of respondent can be selected per row.

No. of Respondents: Provide an estimate of the Number of respondents.

Participation Time: Provide an estimate of the amount of time required for a respondent to participate (e.g. fill out a survey or participate in a focus group).

Burden: Provide the Annual burden hours: Multiply the Number of responses and the participation time and divide by 60.

FEDERAL COST: Provide an estimate of the annual cost to the Federal government.

If you are conducting a focus group, survey, or plan to employ statistical methods, please provide answers to the following questions:

The selection of your targeted respondents. Please provide a description of how you plan to identify your potential group of respondents and how you will select them. If the answer is yes, to the first question, you may provide the sampling plan in an attachment.

Administration of the Instrument: Identify how the information will be collected. More than one box may be checked. Indicate whether there will be interviewers (e.g. for surveys) or facilitators (e.g., for focus groups) used.

Submit all instruments, instructions, and scripts are submitted with the request.

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