0508 Ss 080318

SUPPORTING STATEMENT

CERTIFICATION REQUIREMENTS FOR DISTRIBUTORS OF NOAA

ELECTRONIC NAVIGATIONAL CHARTS

OMB CONTROL NO. 0648-0508

A. JUSTIFICATION

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

This request is for extension of a current information collection.

NOAA produces electronic navigational charts (ENCs) as one of its products under its Nautical Charting Program. Official NOAA ENCs which conform to International Hydrographic Organization (IHO) standards may be used in a type approved* display system, such as an Electronic Chart Display and Information System (ECDIS), to comply with Federal nautical chart carriage requirements administered by the United States Coast Guard.

The information collected allows NOAA to administer the regulation, and to better understand the marketplace resulting in products that meet the needs of the customer in a timely and efficient manner.

NOAA established a certification program for the re-distribution of official NOAA ENCs in

15 CFR part 995 in order to ensure the quality and content of official NOAA ENCs remains intact throughout the redistribution process.

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 all applicable Information Quality Guidelines.

The information collected by NOAA's Office of Coast Survey (OCS) regarding the redistribution of official ENC's allows OCS to better allocate resources towards ENC production and product improvement. This information adheres to NOAA Information Quality Guidelines in that it provides utility to the end user, whereby, OCS is continuously improving the quality of the ENC product that is distributed to the end user, either by the Certified ENC distributor program or via the free downloads on the NOAA website.

Certified ENC distributors are required to report via email or via the OCS inquiry and discrepancy web site (http://ocsdata.ncd.noaa.gov/idrs/discrepancy.aspx) any error detected during the conversion process, that apparently originate in the NOAA ENC files. This allows OCS to quickly make the correction and re-post the data for distribution via the web.

Twice per year, the certified distributors are required to submit a distribution report (a spreadsheet that they maintain) to NOAA with the following information: Distribution Customer(s), Vessel Name(s), ENC(s) and Subscription Type(s). This allows NOAA to evaluate which particular product is in high demand and to adjust production schedules accordingly.

* “Type approved” is an internationally recognized process that certifies compliance of navigation systems to the International Maritime Organizations standards for electronic navigation.

NOAA OCS 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. Although the information collected is not expected to be disseminated directly to the public, results may be used in scientific, management, technical or general informational publications. Should NOAA OCS decide to disseminate the information, it will be subject to the quality control measures and 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.

Responses from the Certified ENC Distributors are all electronic and sent via email. The distributors send the information via spreadsheet (extracted from their databases). The ENC site is at http://www.nauticalcharts.noaa.gov/mcd/enc/certdist.htm.

4. Describe efforts to identify duplication.

The Office of Coast Survey is the only agency that produces official ENC's for the nation's coast. Therefore it is the only agency which manages a collection for the Certified ENC Distributors.

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

This collection does not involve small businesses or other small entities.

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

The reporting of errors found in our data during the conversion process is an invaluable aspect of quality control of the OCS ENC data. If this established feedback mechanism were not available, OCS would not be able to quickly react and repair data to ensure that the end user ultimately receives data that is consistent and correct.

The reports that are required by the distributors enable OCS to better focus production efforts to those products that are in high demand by the end-user.

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

There are no special circumstances that require the collection to be conducted in a manner inconsistent with OMB guidelines.

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 June 5, 2018 (83 FR 26008) solicited public comments. No comments were received.

In conjunction with the Federal Register notice an email survey was sent to program participants. The survey included the following questions:

1.  Are the instructions for reporting ENC distribution information clear?

2.  Are the time frames reasonable?

3. Does your company/organization understand why we need to collect the distribution information?

Eight distributors were contacted; two responded. Both agreed that the instructions are clear and the time frames are reasonable. One responded that he was less clear about why we collect the data. He also suggested that reporting be only annual.

Response: Industry standard is monthly. If anything we would collect reports more, rather than less, often. The information collected allows NOAA to administer the regulation, and to better understand the marketplace resulting in products that meet the needs of the customer in a timely and efficient manner.

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

No payments or gifts are given to information respondents.

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

Assurance of confidentiality is given in the codified federal regulations (there are no NOAA forms on which this information can be displayed): 15 CFR part 995.21 addresses a registry of data users for the distribution program. Within the CFR it states that "NOAA agrees to treat such information as proprietary.”

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.

Not applicable.

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

Number of respondents: 8

Frequency: 2 times per year for the distribution report and as often as weekly for error inquiries/reports

Total Number Expected: 16 responses for distribution report and 208 reports of, or inquiries for potential, errors in the data. (4 issues per month times 12 months)

Average Response Time: 1 hour for the report and 1-2 hours (average 1 hour, 30 minutes) for error reporting

Total Annual Response: 224 responses and 328 hours (16 for distribution reporting; 312 for error reporting).

Hourly Labor Cost: $25

Total Annual Labor cost: $8,200.

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).

There is no recordkeeping/reporting cost burden, as all distributors have computers and email accounts for their business needs.

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

Annualized costs to the federal government are approximately $2,200 in labor costs. However, the time spent on this program is part of regular staff hours.

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

N/A.

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

These results will not be published.

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.

N/A.

18. Explain each exception to the certification statement.

N/A.

B. COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS

This collection does not employ statistical methods.

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