Supporting Statement 2015 without ACE

Supporting Statement 2015 without ACE.doc

Cargo Container and Road Vehicle Certification for Transport Under Customs Seal

OMB: 1651-0124

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Supporting Statement

Cargo Container and Road

Vehicle Certification for Transport under Customs Seal

1651-0124



Justification

  1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.


The United States is a signatory to several international Customs conventions and is responsible for specifying the technical requirements that containers and road vehicles must meet to be acceptable for transport under Customs seal. Customs and Border Protection (CBP) has the responsibility of collecting information for the purpose of certifying containers and vehicles for international transport under Customs seal. A certification of compliance facilitates the movement of containers and road vehicles across international territories. The procedures for obtaining a certification of a container or vehicle are set forth in 19 CFR Part 115.


The respondents to this information collection are members of the trade community who are familiar with CBP regulations.

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.

Owners and operators will submit the actual conveyance (containers or vehicles), or a proposed design, to various appointed certifying authorities for approval. The certification of the conveyance information expedites the movement of merchandise that it contains. If the owner or operator chooses not to use the program, additional time is required for each inspection, therefore causing an additional burden on both the public and CBP officers.


  1. 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.


These requirements involve the submission/presentation of a container or vehicle for inspection which would not be appropriate for an automated submission.


4. Describe efforts to identify duplication. Show specifically why any similar information already available cannot be used or modified for use for the purposes described in Item 2 above.


This information for each submission is unique and is therefore, not duplicated.


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


This information collection does not have an impact on small businesses or other small entities.

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


Since each certification is submitted only once, this information cannot be conducted less frequently. If the information is not collected, CBP could not carry out its regulatory responsibility.


7. Are there special circumstances?


This information is collected in a manner consistent with the guidelines of 5 CFR 1320.5(d)(2).


  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.

Public comments were solicited through two Federal Register notices published on August 11, 2015 (Volume 80, Pages 48117) on which no comments were received, and on November 13, 2015 (Volume 80, Page 70245) on which no comments have been received.


9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.


There is no offer of a monetary or material value for this information collection.


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

There is no PII associated with this collection of information. No assurances of confidentiality are provided to respondents.

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.

There are no questions of a sensitive nature.


  1. Provide estimates of the hour burden of the collection of information.



INFORMATION COLLECTION

TOTAL ANNUAL BURDEN HOURS

NO. OF

RESPONDENTS

NO. OF RESPONSES PER RESPONDENT


TOTAL

RESPONSES


TIME PER

RESPONSE


Cargo Container/Vehicle Certification



10,500

25

120

3,000


3.5 hours

Public Cost

The estimated cost to the respondents is $309,330. This is based on the estimated burden hours (10,500) multiplied by (x) the average loaded hourly wage rate for importers ($29.46). CBP calculated this loaded wage rate by multiplying the Bureau of Labor Statistics’ (BLS) 2014 median hourly wage rate for Cargo and Freight Agents ($19.89), which CBP assumes best represents the wage for importers, by the ratio of BLS’ average 2014 total compensation to wages and salaries for Office and Administrative Support occupations (1.4813), the assumed occupational group for importers, to account for non-salary employee benefits.1,2



13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.


There are no capital, start-up or maintenance costs associated with this information collection.

  1. 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, operational 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 associated with the review of these documents is $83,865. This is based on the number of responses that must be reviewed (3,000) multiplied by (x) the time burden to review and process each response (.5 hours) = 1,500 hours multiplied by (x) the average hourly loaded rate for a general CBP employee ($55.91)1 = $83,865.



15. Explain the reasons for any program changes or adjustments reported in Items 12 or 13 of this Statement.

There are no increases or decreases to the burden hours. There are no changes to the information collected.


16. For collection of information whose results will be published, outline plans for tabulation, and publication.


This information collection will not be published for statistical purposes.


17. If seeking approval to not display the expiration date, explain the reasons that displaying the expiration date would be inappropriate.

There is no form associated with this collection of information so it would not be appropriate to display the date.

18. “Certification for Paperwork Reduction Act Submissions.”

CBP does not request and exception to the certification of this information collection.


  1. Collection of Information Employing Statistical Methods


No statistical methods were employed.





1 CBP bases this wage on the salary and benefits of the national average of general, non-CBP Officer/frontline CBP positions, which is equal to a GS-12, Step 5. Source: Email correspondence with CBP’s Office of Administration on June 25, 2015.

1 Source of median wage rate: U.S. Bureau of Labor Statistics.  Occupational Employment Statistics, “May 2014 National Occupational Employment and Wage Estimates, United States- Median Hourly Wage by Occupation Code: 43-5011.”  Updated March 25, 2015.  Available at http://www.bls.gov/oes/2014/may/oes435011.htm. Accessed June 15, 2015. 

2 The total compensation to wages and salaries ratio is equal to the calculated average of the 2014 quarterly estimates (shown under Mar., June, Sep., Dec.) of the total compensation cost per hour worked for Office and Administrative Support occupations (24.66) divided by the calculated average of the 2014 quarterly estimates (shown under Mar., June, Sep., Dec.) of wages and salaries cost per hour worked for the same occupation category (16.6475). Source of total compensation to wages and salaries ratio data: U.S. Bureau of Labor Statistics. Employer Costs for Employee Compensation. Employer Costs for Employee Compensation Historical Listing March 2004 – December 2015, “Table 3. Civilian workers, by occupational group: employer costs per hours worked for employee compensation and costs as a percentage of total compensation, 2004-2015 by Respondent Type: Office and administrative support occupations.” June 10, 2015. Available at http://www.bls.gov/ncs/ect/sp/ececqrtn.pdf. Accessed June 15, 2015.

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