Collection Instruments: Instruction
A. JUSTIFICATION
1. Circumstances which make the collection of information necessary.
Under the provisions of 33 U.S.C. 401, 491, and 525, it shall not be lawful to construct a bridge or causeway over navigable waters of the United States unless the plans and location of such structures have been approved by the Secretary of Homeland Security through the Commandant, U. S. Coast Guard. The plans and map of the location must be in such detail as may be required for a full understanding of the bridge project. The procedures of obtaining an individual bridge permit are set forth in 33 CFR 115.50 and 115.60. The procedure essentially calls for a letter of application with letter size drawings (plans) and map showing the proposed bridge project and its location.
Section 102(2)(C) of the National Environmental Policy Act of 1969 (NEPA), as amended, requires federal agencies to assess in detail the environmental impacts of proposed major federal actions on the quality of the human environment. 40 CFR 1500-1508 sets forth the procedures, and 40 CFR 1502.3 specifically mandates the requirement for impact statements.
2. Purpose of the Information Collection
It is against the law to build a bridge over the navigable waters of the United States without approval of the plans and location of such structures. The Coast Guard, before a bridge permit is issued or denied, uses the information provided by the applicant to evaluate the effect the bridge project will have on the reasonable needs of navigation and on the human environment. The applicants are private entities, Federal, state, or local government agencies, or organizations employing more than 100 persons.
3. Consideration of the use of improved information technology to reduce the burden.
Currently applicants can submit the required material electronically to the Coast Guard via email, CD-ROM or posting documents to applicant websites for Coast Guard download. Development of the Bridge Permit Application Guide (BPAG), COMDTPUB P16591.3 (series) and the Bridge Administration Manual (BAM), CONDTINST M16590.5 (series) have prevented waste within the Coast Guard. The BPAG provides a standard for assisting applicants in compiling the required information and documents. The BAM provides the same standard for Coast Guard field units and Headquarters to review and evaluate permit applications.
4. Efforts to identify duplication.
The granting of a bridge permit over the navigable waters of the United States is a unique function that falls solely under the jurisdiction of the Coast Guard. There is no duplication in the collection of necessary information to complete an application. The procedures for developing environmental assessments or environmental impact statements (40 CFR 1506) require that duplicative efforts be eliminated between federal, state and local governments. Thus, where practicable, joint public meetings or hearings are held, joint public notices can be issued, and environmental documents/statements, reports, and analyses can be referenced and/or adopted. Additionally, Executive Order 13604: Improving Performance of Federal Permitting and Review of Infrastructure Projects, directed federal agencies to improve the permitting and review process for infrastructure projects throughout the country. Agency implementation of the EO further reduced duplicative efforts for the collection of materials from bridge permit applicants between the Coast Guard and other federal agencies.
5. Methods used to minimize the burdens to small business.
Not applicable. The respondents are, with private entities, Federal, state, or local government agencies, or organizations employing more than 100 persons.
6. Consequences to the Federal program if collection were not done or conducted less frequently.
The result of either not collecting this information or conducting it less frequently would be noncompliance with statutory and regulatory requirements. The Coast Guard’s bridge permit program would become ineffective and their inability to make informed decisions on whether proposed bridges or bridge modifications would meet the reasonable needs of navigation with due consideration of the effects on the human environment could jeopardize maritime navigation. Every application for a Coast Guard bridge permit must go through this collection process. The Coast Guard has no influence on how many bridge applications it receives annually. Federal funding for transportation projects is the largest influence.
7. Special circumstances that require collection to be conducted in an inconsistent manner.
None.
8. Solicitation of Comments.
A 60-Day Notice (See [USCG-2015-0690], August 24, 2015, 80 FR 51291) and 30-Day Notice (November 19, 2015, 80 FR 72444) were published in the Federal Register to obtain public comment on this collection. The Coast Guard has not received any comments on this information collection.
9. Provide any payment or gift to respondents.
Not applicable. Neither applicants nor respondents to public notices on bridge projects are compensated for providing data or information.
10. Assurances of confidentiality provided to respondents.
Not applicable. Bridge permit case records are public records and subject to applicable provisions of Title 49 Code of Federal Regulations Part 7, Public Availability of Information Transportation (49 CFR 7). (From COMDTINST M16590.5C, Bridge Administration Manual, paragraph 1.M.2.).
11. Additional justification for any questions of a sensitive nature.
Not applicable. The Bridge Permit Application Guide contains no questions of a personal or private nature.
12. Estimate of annual hour and cost burden.
Frequency of Response: Usually once, when applying for Coast Guard approval of proposed bridge construction or bridge modification.
Applicant cost to provide the information contained in the Bridge Permit Application Guide can vary greatly depending upon the level of environmental documentation required under NEPA. There are three levels of NEPA documentation: categorical exclusions (CE), environmental assessments (EA) and environmental impact statements (EIS). For the purposes of this OMB evaluation categorical exclusions shall be considered low impact projects by the Bridge Program since they typically require minimal coordination and documentation. Also, all calculations are based on FY14 figures. FY14 is the larger data set over the past three fiscal years and is reflective of the 17% yearly increase in permit applications. Application preparation for low impact projects account for approximately 61% of Coast Guard Bridge Permit Applications. EAs and EISs require a much more rigorous analysis and take more time and capital to produce so they are considered to be high impact projects by the Program. Application preparation for high impact projects account for approximately 39% of Coast Guard Bridge Permit Applications.
Number of Bridge Permit Applicants (Respondents):
FY14 – Low Impact 81 + High Impact 52 = 133 total
FY13 – Low Impact 74 + High Impact 43 = 117 total
FY12 – Low Impact 66 + High Impact 33 = 99 total
The majority of the applications received by the Coast Guard are from federal applicants such as the Federal Highway Administration (FHWA), for which the Coast Guard is not the lead federal agency for NEPA. The Coast Guard is not the lead federal agency for approximately 77% of Coast Guard Bridge Permit Applications because all Federal actions must comply with the provisions of the National Environmental Policy Act (NEPA) of 1969. For these 77% the applicant is another federal agency (FHWA, Federal Railroad Administration (FRA)/Federal Transit Administration (FTA), etc). Any Federal applicant for a bridge permit becomes responsible as the lead federal agency under NEPA to conduct a NEPA evaluation. The NEPA documentation has already been prepared at the time of application since the lead federal agency is required to prepare NEPA documentation when federal funding is involved. The below numbers do not include the number of hours and associated costs a federal applicant spends on NEPA documentation since the documentation is not a sole requirement of the Coast Guard, but a requirement that is met before a Coast Guard Bridge permit application is considered.
Due to staffing limitations, the Coast Guard typically requires the applicant to prepare the NEPA documentation when the Coast Guard is the lead federal agency, approximately 23% of the time. NEPA documentation requirements vary based upon the impacts and complexity of the project. Implementation procedures are based on Council on Environmental Quality (CEQ) Regulations found in 40 CFR 1500-1508. When a private entity/owner applies for a Coast Guard bridge permit the Coast Guard must now assume lead federal agency responsibilities for NEPA. The Coast Guard Bridge Program often coordinates with the private applicant to have them produce the NEPA documentation for the Coast Guard to expedite the permit process, as allowed by the CEQ regulations. The cost to do this then falls to the applicant. Market research suggests that low impact (CE) projects typically take 120 hours to produce a NEPA document at an estimated cost of $12,000. High impact (EA and EIS) projects typically take between 500 (EA) and 5,000 (EIS) hours to produce a NEPA document at an estimated cost of between $50,000 (EA) and $500,000 (EIS). Sections a. and b. below represent low and high impact projects, respectively.
The calculations contained below are based upon the level of NEPA documentation required for the proposed project and reflect the low impact/high impact determination. The costs shown are also based upon the schedule of hourly rates for personnel contained in enclosure (2) to COMDTINST 7310.1P. Total estimated respondent financial cost for FY14 is shown in Section d. at $941,322.00. These calculations do not include the hours and cost for NEPA documentation preparation described above.
Application
preparation by the applicant for low
impact
projects (categorical exclusions).
These projects account for approximately 61% of Coast Guard Bridge
Permit Applications. Rates are based on COMDTINST 7310.1P Coast
Guard Reimbursable Standard Rate dated
11 February 2015.
Within government (I/G)
Outside government (O/G)
Pre-application consultations w/federal, state, local govt.
(GS-13/14, O/G $101) X 8 hrs = $808.00
Application preparation (GS-11, O/G $61) X 40 hrs = $2,440.00
Clerical (GS-5/8, O/G $50) X 4 hrs = $200.00
Drawings prepared (GS-9, O/G $51) X 10 hrs = $510.00
Respondent financial burden per application = $3,958.00
Respondent burden hours per application, low impact = 62 hrs
Total Respondent hours - 62 X 81 applications (61% of 133, FY14) = 5,022hrs
Total Respondent Cost - $3,958.00 X 81 applications = $320,598.00
Application preparation for high impact projects (environmental assessments and environmental impact statements). These projects account for approximately 39% of Coast Guard Bridge Permit Applications.
Note: the hourly differences between an environmental assessment and an environmental impact statement are evident in the NEPA document preparation, and not with the other Bridge Permit Application requirements, as described below.
Within government (I/G)
Outside government (O/G)
Pre-application consultations w/federal, state, local govt.
(GS-13/14, O/G $101) X 87 hrs = $8,787.00
Application preparation (GS-11, O/G $61) X 40 hrs = $2,440.00
Clerical (GS-5/8, O/G $50) X 4 hrs = $200.00
Drawings prepared (GS-9, O/G $51) X 10 hrs = $510.00
Respondent financial burden per application = $11,937.00
Respondent burden hours high impact (87+40+4+10 hrs) = 141 hrs
Total Respondent hours - 141 hrs X 52 applications (39% of 133, FY14) = 7,332 hrs
Total Respondent Cost - $11,937.00 X 52 applicants = $620,724.00
FY14 total respondent hours (5,022+7,332) = 12,354 hrs
FY14 total respondent cost ($320,598+$620,724) = $941,322.00
13. Provide an estimate of the annualized capital/start-up costs to respondents.
The estimated cost for the copying, postage and handling of a bridge permit application:
Low Impact Project = $50.00
Total Respondent Cost - $50.00 X 81 applications = $4,050.00
(61% of 133, FY14)
High Impact Project = $200.00
Total Respondent Cost - $200.00 X 52 applications = $10,400.00
(39% of 133, FY14)
FY 14 estimated total cost = $14,450.00
14. Estimates of annualized cost to the Federal Government.
The estimated annual federal cost for administration for FY14 is $1,580,160.50; this number will change slightly from year to year depending on the number of applications received in that year. This estimate is primarily federal personnel salary and overhead costs associated with field and headquarters time expended in processing a respondent's application for a bridge permit or permit amendment. The costs are directly related to working with and evaluating the information collected from respondents in order to make the federal decision required on bridge project impacts on navigation and on the human environment. Personnel costs are calculated from information in enclosure (2) to COMDTINST 7310.1P.
Prepare District jurisdictional and navigational determinations, review and provide feedback for application package, prepare and distribute Coast Guard public notice and agency notifications, review and address public concerns, and prepare District Findings of Fact (total 78.4 hours). These actions differ very little between low impact and high impact projects as well as between Coast Guard lead vs. non-lead federal agency.
CG application review and acknowledgment
(GM-12, I/G $67) X 12 hrs = $804.00
CG jurisdictional/navigation clearance determinations & coordination
(GM-12, I/G $67) X 25 hrs = $1,675.00
Prepare and distribute CG Public Notice/Agency Notifications
(GS-13/14, I/G $94) X .50 hrs = $47.00
(GS-12, I/G $67) X 11 hrs = $737.00
Review and prepare public notice responses
(GS-12, I/G $67) X 3.5 hrs = $234.50
Prepare District Findings of Fact. Same for low and high impact, same for Coast Guard lead vs. non-lead
(GS-12, I/G $67) X 26 hrs = $1,742.00
78 hrs $5,239.50
When the Coast Guard IS NOT the lead federal agency, review and comment on preliminary and final environmental documents, attend resource/regulatory agency meetings and draft Finding of No Significant Impact (FONSI) or Record of Decision (ROD) for high impact projects. These projects account for approximately 80% of Coast Guard Bridge Permit Applications.
Review and comment on preliminary and final environmental documents.
(GS-12, I/G $67) X 18 hrs = $1,206.00
Attend resource/regulatory agency meetings.
(GS-12, I/G $67) X 3 hrs = $201.00
Draft FONSI or ROD for high impact projects.
(GS-12, I/G $67) X 5 hrs = $335.00
26 hrs $1,742.00
When the Coast Guard IS the lead federal agency review environmental documents, to include reviewing applicant prepared environmental documents and coordination and consultation with natural resource agencies (average for low and high impact = 37 hours). These projects account for approximately 20% of Coast Guard Bridge Permit Applications.
Please note that the following dollar amounts; $1675.00, $804.00, $1541.00 and $446.50; are used in both the LOW and HIGH impact calculations.
Review applicant-prepared preliminary and final environmental documents
(GS-12, I/G $67) X 25 hrs = $1,675.00
Attend resource/regulatory agency meetings.
(GS-12, I/G $67) X 12 hrs = $804.00
Circulate and address comments and concerns.
Low Impact
(GS-12, I/G $67) X 17 hrs = $1,139.00
High Impact
(GS-12, I/G $67) X 60 hrs = $4,020.00
Draft CE determination, FONSI or ROD, review and comment on final environmental document.
Low Impact
(GS-12, I/G $67) X 8 hrs = $536.00
High Impact
(GS-12, I/G $67) X 58hrs = $3,886.00
Prepare final environmental document/cover for agency signature, prepare permit package for District/Commandant review, prepare transmittal letter/case file and completion report.
Same for low and high impact
(GS-12, I/G $67) X 23hrs = $1,541.00
(GS-13/14, I/G $94) X 4.75 hrs = $446.50
89.75 hrs Low impact = $6,141.50
182.75 hrs High impact = $12,372.50
Coast Guard HQ receives application package, evaluates impacts on navigation and the environment, prepares written evaluations, bridge permit or denial, and transmittal letter to District. This section applies to all applications.
Low Impact
(GS-15, I/G $109) X 3.50 hrs = $381.50
(GS-13, I/G $80) X 33.50 hrs = $2,680.00
37 hrs Low impact = $3,061.50
High Impact
(GS-15, I/G $109) X 5.50 hrs = $599.50
(GS-13, I/G $80) X 47.50 hrs = $3,800
53 hrs High impact = $4,399.50
FY14 Coast Guard hours per response:
Low impact projects, Coast Guard not the lead federal agency = 141.00 hrs (a+b+d(low))
Low impact projects, Coast Guard is the lead federal agency = 204.75 hrs (a+c(low)+d(low))
High impact projects, Coast Guard not the lead federal agency = 157.00 hrs (a+b+d(high))
High impact projects, Coast Guard is the lead federal agency = 313.75 hrs (a+c(high)+d(high))
FY14 Total Cost burden hours:
The calculations in this section are based upon 133 projects for FY14. 61% were considered low impact (81 applications). Of this 22% were Coast Guard lead (18 applications) and 78% were not Coast Guard lead (63 applications). 39% of the applications were considered high impact projects (52 applications). Of this 17% were Coast Guard lead (9 applications) and 83% were not Coast Guard lead (43 applications). These numbers are used to generate the Coast Guard burden hours.
Total Coast Guard burden hours (low impact projects, Coast Guard not the lead federal agency) = 8,883 hrs (63 applications X 141 hrs)
Total Coast Guard burden hours (low impact projects, Coast Guard is the lead federal agency) = 3,685.50 hrs (18 applications X 204.75 hrs)
Total Coast Guard burden hours (high impact projects, Coast Guard not the lead federal agency) = 6,751 hrs (43 applications X 157 hrs)
Total Coast Guard burden hours (high impact projects, Coast Guard is the lead federal agency) = 2,823.75 hrs (9 applications X 313.75 hrs)
Total Coast Guard burden hours, FY 11 = 22,143.25 hrs
FY14 Federal government financial burden
Coast Guard financial burden (low impact projects/Coast Guard not the lead federal agency) = $632,709.00 ($10,043.00(a+b+d(low) X 63 applications)
Coast Guard financial burden (low impact projects/Coast Guard is the lead federal agency) = $259,965.00 ($14,442.50 (a+c(low)+d(low) X 18 applications)
Coast Guard financial burden (high impact projects/Coast Guard not the lead federal agency) = $489,383.00 ($11,381.00 (a+b+d(high) X 43 applications)
Coast Guard financial burden (high impact projects/Coast Guard is the lead federal agency) = $198,103.50 ($22,011.50 (a+c(high)+d(high) X 9 applications)
Total Federal Cost (FY14, 133 applications) = $1,580,160.50
15. Reason for changes or adjustments in the burden.
Total public burden hours for FY 14 are calculated to be 12,354. Starting with the last OMB approval period, the Program utilizes quarterly reporting data (Bridge Program Quarterly Activities Report) from each district office to generate more accurate permit data then previously available. The data presented in this justification represents the best information currently available.
Growth identified between FY12 and FY14 (average of 17%) is indicative of normal permit request growth rates currently being experienced within the Program and this rate of growth is anticipated to continue in the future.
16. Plans for tabulation, statistical analysis and publication.
Not applicable. No publication of collected information or statistical analysis is planned.
17. Approval for not to explain the OMB expiration date.
USCG will display the OMB control number and expiration date of OMB approval of this information collection on the next revision to the BPAG (currently under development).
18. Exception to the certification statement.
There are no exceptions.
B. COLLECTION OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable. The collection does not employ statistical methods.
| File Type | application/msword |
| File Modified | 2015-11-19 |
| File Created | 2015-07-31 |