SUPPORTING STATEMENT FOR
Regattas and Marine Parades
OMB Control No.: 1625-0008
COLLECTION INSTRUMENT(S): CG-4423 and Instruction
A. 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.
Marine events may potentially block navigation channels or cause interference with adjacent vessel traffic or with the ability of larger commercial vessels to safely navigate designated shipping lanes. Also, adjacent vessel traffic may interfere with the safety or conduct of the marine event. The Coast Guard is authorized, under 33 U.S.C. 1233, to issue regulations to promote the safety of life on navigable waters during regattas and marine parades. In 33 CFR Part 100 the Coast Guard established regulations to provide notification of and effective control over marine events conducted on the navigable waters of the United States to promote the safety of life and property in the event area. This rulemaking authority has been delegated to the District Commanders under 33 CFR 1.05-1.
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.
The current Application for Approval of Marine Event form, CG-4423, is required to be submitted. The permit application provides the Coast Guard with information needed to: identify the marine event and the event contact, to consider whether or not an event is likely to result in the loss of human life unless special precautions are taken, and to issue a notice to mariners to inform the public about the event. The Coast Guard uses this information to identify each marine event, the event sponsor and responsible representatives for accountability, clarifying information and event control, to determine whether the event requires and merits Coast Guard approval, Coast Guard supervision or assistance, and what impacts the event may have on navigation and on the environment.
The purpose of the application information elements under 33 CFR 100.15(d) is as follows:
Items 1 & 2: The name and address of the sponsoring organization or authorized representative, person to be contacted if further details are needed to identify the event sponsor, and the people accountable for the overall event and details. The telephone number provides an alternate time saving means of contacting the sponsor's representative for additional or clarifying information. The submitter’s electronic mail address allows for automated receipts to be sent for applications submitted online via http://homeport.uscg.mil. The name of the person in charge of the event, his or her location, and how to be reached during the event in case questions arise or the conduct of the event must be adjusted. In some cases, the same person performs all these duties and the information need not be repeated.
Items 3, 4, 5 & 6: The description of the nature and purpose of the event, information on general public interest, the number of participating boats and the number of spectator craft are needed to consider the size and complexity of the event, what impacts on navigation may result, and for determining whether or not a permit is needed and may be issued.
Items 7, 8 & 9: The event location, date and time schedule are needed to identify each marine event and are used with other available information to consider potential impacts on navigation and whether a permit is needed and may be issued. This information is also used in advising the boating public about the event. Attaching a section of a chart or a scale drawing showing the event boundaries and/or courses and markers contemplated is needed to clearly indicate where the event occurs, the event's relationship to navigation channels or potential environmental impacts, and placement of course markers/navigational aids for the event. The number of sponsor provided safety patrol vessels is needed to consider the adequacy of protection provided by the sponsor and what additional resources may be needed to ensure the safety of life during the event. The Coast Guard cannot have any question or doubt over the location, sailing courses or event boundaries separating participants from non-participants or adjacent navigation.
The Coast Guard must develop environmental documentation appropriate for the event either from additional environmental information provided by the sponsor in the application or on its own based on experience with other similar events in similar locations. This environmentally related information is needed to enable the Coast Guard to properly assess potential environmental impacts, the applicant's efforts to mitigate or avoid those impacts, including other contacts with other agencies and their responses, and to develop appropriate environmental documentation and permit conditions.
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 responses, and the basis for the decision for adopting this means of collection. Also describe any consideration of using information technology to reduce burden.
Neither the statutory authority nor the existing regulations prohibit the use of transmitting permit application information through electronic means. Applications mailed to the Coast Guard are always accepted as are applications submitted through the following means:
ONLINE SUBMISSION: Applications may be submitted through an online “fillable-fileable” form available at http://homeport.uscg.mil. Applicants fill the form out online and select the appropriate Coast Guard office to submit it to through an online pick list. A copy of the form will be automatically sent to the selected Coast Guard unit along with a receipt acknowledging submittal to the applicant. The information collected via the online form replicates the automated Adobe version of the CG-4423; however, in block 25 of the CG-4423, rather than requesting the applicant’s signature, the online application requests the person filling out the form to check a box that states “By submitting this form I certify that I have full authority to represent the sponsoring organization.” There is no statutory or regulatory requirement that the form be signed; however, the Coast Guard wishes affirmation that the person submitting the form has the authority to do so.
FACSIMILE: Applications facsimiled to the appropriate Coast Guard office. Fax numbers for Coast Guard Offices can be found by accessing the Coast Guard’s Homeport Web Portal at http://homeport.uscg.mil and clicking the “Sector Directory” link.
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.
The information supplied in the application for a marine event permit is not available from other sources in a timely manner. Each event is considered on a case-by-case basis. Although information may exist for a similar event, the required information would still be needed to correctly apply the available information to the specific marine event being considered by the Coast Guard.
5. If the collection of information impacts small businesses or other small entities (Item 5 of OMB Form 83-I), describe any methods used to minimize burden.
This information collection does not have an impact on small businesses or other small entities.
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.
If the information in the permit application were not provided when a permit is required, the Coast Guard would not be able to determine whether or not an event is likely to result in the loss of human life unless special precautions are taken, nor be able to issue a notice to mariners to alert the navigation community of the event, its location and its schedule, nor prepare the proper environmental documentation and appropriate mitigation and precautionary measures in a timely manner. The Coast Guard needs to know of the intention to hold the event in advance and then determine whether simple notification to navigation, appropriate regulations, or permit conditions, or a combination, would best ensure the safety of life and property on the water. Marine event permits that are issued for repetitive events are valid for one year.
7. Explain any special circumstances that would cause an information collection to be conducted in a manner:
This information collection is conducted in manner consistent with the guidelines in 5CFR 1320.5(d)(2).
8. If applicable, provide a copy and identify the data 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.
A 60-Day Notice (See [USCG-2016-0926], December 27, 2016, 81 FR 95158) and 30-Day Notice (July 24, 2017, 82 FR 34317) 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. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.
USCG does not provide payments of gifts to respondents in exchange for a benefit sought.
Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.
There are no assurances of confidentiality provided to the respondents for this information collection. This information collection request is covered by the Marine Information for Safety and Law Enforcement (MISLE) Privacy Impact Assessment (PIA) and System of Records Notice (SORN). Links to the MISLE PIA and SORN are provided below:
https://www.dhs.gov/sites/default/files/publications/privacy_pia_uscg_misle.pdf
https://www.gpo.gov/fdsys/pkg/FR-2009-06-25/html/E9-14906.htm
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.
There are no questions of sensitive language.
12. Provide estimates of the hour burden of the collection of information.
The total annual hour burden on respondents is estimated to be 5270.83 hours. The total annual cost to respondents for submitting permit applications is estimated to be $302,756.48.
The Coast Guard estimates there will be approximately 5,500 respondents submitting a permit application for one or more events to the Coast Guard annually. We estimate that 50% (2750 applications) will be submitted online through the Homeport Web Portal.
The time to gather the marine event information to prepare the permit application and complete the form is estimated to take approximately 60 minutes. The permit application may be typed in online format or using an automated form suitable for facsimile or mailing. Respondents may also print out a blank CG-4423 and complete it in ink. Even though the information must be developed over the course of planning the event, someone must collect the details to enter them into the permit application. This includes time to obtain a chart section or prepare a scale drawing, enter event boundaries, courses and markers that the Coast Guard needs to consider any impacts the event may have on navigation, whether or not to issue the permit, and to use as needed for a notice to mariners. The explanations for items 3, 5, 6, 8 and 9 consume most of the estimated time to complete the permit application.
Total annual burden on the public:
1 hour x 2750 (automated form) = 2750 hours
55 min x 2750 (online form) = 2520.83 hours
Total burden hours = 5270.83 hours
Estimated cost burden.
Permit applications come from sponsors of marine events which include a variety of groups with an interest in marine activities. The Coast Guard estimates that most permit application forms are completed by personnel who meet the Bureau of Labor and Statistics (BLS) definition of General and Operations Managers. BLS estimates the mean hourly salary of General and Operations Managers as $57.44.
The cost per marine event to complete an automated Adobe permit application is therefore $57.44 (1 hour x $57.44/hr). The cost per marine event to complete an online application is therefore $52.65 (55 minutes x $57.44/hr). The total cost burden to the public to complete permits for regattas and marine parades is $302,756.48 (5270.83 hours x $57.44/hr).
Summary
Number expected to be submitted online |
2750 (50% of total) |
Number of Forms Submitted |
Number expected to be submitted on automated Adobe form |
2750 (50% of total) |
|
Total Number of CG-4423 forms submitted annually |
5500 (2750 online + 2750 Adobe) |
|
Estimated time to complete automated Adobe CG-4423 |
1 hour |
Time to Complete |
Estimated time to complete online CG-4423 |
55 minutes |
|
Estimated time burden for automated Adobe CG-4423 |
2750
hours |
Public Time Burden |
Estimated time burden for online CG-4423 |
2520.83
hours |
|
Total Estimated time burden |
5270.83
|
|
BLS Hourly salary for General & Operations Managers |
$57.44/hour |
Public Cost Burden |
Estimated cost per marine event to submit automated Adobe application |
$57.44
|
|
Estimated cost per marine event to submit online application |
$52.65
|
|
Total Estimated cost burden to public |
$302,756.48
|
13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.
There are no record keeping, capital, start-up or maintenance costs associated with this information collection.
14. 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. Agencies also may aggregate cost estimates from Items 12, 13, and 14 in a single table.
It is estimated that the Coast Guard issued approximately 5,500 marine event permits in 2012. The proposed estimate of 5,500 permit applications will allow for minor yearly fluctuations in the number of permit applications processed and for a number of permits denied.
Operational Expenses: Estimated number of respondents annually is 5,500 permit applications processed. Total annual cost to the government is $4,880,125. The source for the personnel cost figures is Enclosure (2) to Commandant Instruction 7310.1 Q, Standard Rates.
The Coast Guard estimates that the total cost to the Government for reviewing an estimated 5,500 permit applications (Form CG-4423) annually for a marine event is $682,000. This is based upon 2 hours work for an E-6 through E-7 ($62.00 per hour) for reviewing 5,500 permit applications, determining whether or not a permit should be required, and preparing a local and/or broadcast notice to mariners for the event. The tasks necessary to review a permit application include logging it in, determining jurisdiction, considering the impact on navigation, contacting other agencies and/or the applicant, determining whether a permit should be required, some data base work, and preparation of a local and/or broadcast Notice to Mariners.
The Coast Guard estimates that the total cost to the Government for processing an estimated 5,500 supporting environmental documents for marine event is $4,239,125. This is based upon 3 hours work for a Coast Guard Junior Officer (O-2/O-3) or GS-12/13 ($74.75 per hour) to prepare a categorical exclusion determination (CED) and checklist for 4,500 marine event permits ($968,625) and 80 hours work for a Coast Guard Officer O-3/O-4 or GS-12/13 ($80.75 per hour) to prepare an environmental assessment for 500 marine event permits ($3,230,000). Approximately 500 permits will not require environmental documents because of the nature of the event. The tasks necessary to process the additional environmental documentation include logging it in, reviewing authorities, considering the impact on the environment, contacting other agencies and/or the applicant, determining the safety patrols needed by the sponsor and the Coast Guard, as applicable, some data base work, developing appropriate environmental documentation, developing permit conditions, as needed, and making, routing and mailing copies.
15. Explain the reasons for any program changes or adjustments reporting in Items 13 or 14 of the OMB Form 83-I.
There are no program changes or adjustments reporting.
16. For collections 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 for OMB approval of the information collection, explain the reasons that display would be inappropriate.
USCG will display the expiration date for OMB approval of this information collection.
Explain each exception to the certification statement identified in Item 19, "Certification for Paperwork Reduction Act Submission," of OMB 83-I.
USCG does not request an exception to the certification of this information collection.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | SUPPORTING STATEMENT FOR |
| Author | TSA Standard PC User |
| File Modified | 0000-00-00 |
| File Created | 2021-01-22 |