1625--NEW State Registration Data Supporting Statement 2021____

SUPPORTING STATEMENT FOR

State Registration Data

OMB Control No.: 1625--NEW

COLLECTION INSTRUMENT(S): Instruction, CGHQ-3923

A. Justification

1. Circumstances which make the collection of information necessary.

46 USC 12302 describes the requirement to create a standard numbering system. 46 USC 6102 describes the requirement to provide statistics and recommendations based on a marine casualty reporting system. The collection of vessel registration data accomplishes this goal by creating a means to measure casualty rates. Registration data frequently serves as the denominator of fatality rates (usually expressed in x deaths per 100,000 registered vessels). The existence of registration data allows the Coast Guard to normalize data and provide meaningful statistics and recommendations for the National Recreational Boating Safety (RBS) Program.

2. Purpose of the information collection.

Registration information is most frequently requested by federal sources and by the marine industry. Federally, it is used within the Coast Guard for the primary purpose of measuring fatality rates. It is also used by the Department of the Treasury for the purpose of calculating financial allocations of trust fund money. With respect to marine industry, a manufacturing association and boating safety product marketers usually request the information presumably to gauge market dynamics.

In the very least, registration data is published in an annual Recreational Boating Statistics report, a Coast Guard-produced publication that provides tables of information about boating accidents and boat registration data. The report is posted to the Coast Guard’s Boating Safety website, is downloadable, and is free to share. The Coast Guard also provides numerical information to a distribution list of interested individuals. This is currently an existing collection in use without an OMB control number.

3. Considerations of the use of improved technology.

The data collection does not involve an automated collection. Further, the Coast Guard does not dictate that the States use a particular system to collect their registration data.

4) Efforts to identify duplication.

In this information collection, the Coast Guard does not receive records reflecting individual boat owners so the Coast Guard cannot identify duplication. The Coast Guard can and has questioned the State whenever there has been a significant change in registration numbers.

5) Methods used to minimize the burdens to small business if involved.

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

entities.

6) Consequences to the Federal program or policy if collection were conducted less

frequently.

The Coast Guard will be severely limited in its ability to measure risk, as registration
data is normally used to calculate fatality rates. Further, the data provided from this
collection effort provides necessary input to the Department of the Treasury for use in
the formulas to determine tax revenues that fund the Sport Fish Restoration and Boating
Trust Fund.

7) Special collection circumstances.

This information collection is conducted in manner consistent with the guidelines in
5 CFR 1320.5(d)(2).

8) Consultation.

The Coast Guard previously published two, 60-day notices (79 FR 60483, October 7,
2014, and 81 FR 85987, November 29, 2016) and one, 30-day notice (83 FR 54128,
October 26, 2018) required by 44 U.S.C. 3506(c)(2). Those three notices elicited ten
public comment submissions. Following this paragraph, we list the specific concerns
or questions raised in those ten submissions. We also list the comments and questions
we received from Coast Guard staff that may be helpful to clarify for the public.
Following the comment description, we provide our updated responses, including
descriptions of any changes we made to the ICR and forms.

Comment (1): A requestor asks the Coast Guard to consider mandating to states that

personal watercraft (PWC) data collection is separately maintained. This will ensure

accuracy in the entirety of boat classification data collection and significantly aid PWC

manufacturers in market assessment.

Answer: The Coast Guard is maintaining the personal watercraft category in our

proposed data collection (see 33 CFR174.19(a)(11)); we proposed to collect statistics
on personal watercraft by length category.

Comment (2): A commenter stated that the Coast Guard's tabulation of State numbered

vessels as a result of this Information Collection Request (ICR) cannot be used to

measure risk as stated in the supplemental Paperwork Reduction Act submission that

accompanies this ICR, especially since there are numerous recreational boating

accidents and fatalities that occur in vessels not required to be numbered and not reflected

in this collection of information.

Answer: Information in the proposed collection will be used to measure risk; Registration
data frequently serves as the denominator of fatality rates (usually expressed in number of
deaths per 100,000 registered vessels). The existence of registration data allows the Coast
Guard to normalize data and provide meaningful statistics and recommendations for the
National Recreational Boating Safety (RBS) Program. The revised collection proposed to
break down registration by motorization so that an additional measure, motorized vessel
fatality rate, could be used (number of deaths on motorized vessels per 100,000 motorized
registered vessels). This measure would provide a much sounder denominator since all
States do not collect registration data on non-motorized vessels.

Comment (3): A commenter noted that in accordance with 33 CFR 174.123, each

State that has an approved numbering system must prepare and submit Coast Guard form

CGHQ-3923, Report of Certificates of Number Issued to Boats, to the Coast Guard.

Although OMB No. 1625--NEW reflects the revised vessel type terminology resulting

from the Coast Guard's 2012 issuance of the Final Rule on Changes to Standard

Numbering System, Vessel Identification System, and Boating Accident Report Database

(Docket No. USCG-2003-14963), it does not accurately reflect the CFR's terminology in

its title or instructions (i.e., all references to the approved numbering system, state

numbered boats and certificates of number have been replaced with registrations and

registered).

Answer: This is true. The proposed form focuses on registered vessels, which allows the

Coast Guard to examine a larger scope of vessels that fall under the National Recreational

Boating Safety Program. The Coast Guard will consider changes to the form title in 33

CFR 174.123 to more accurately reflect the data collection under this Information

Collection Request.

Comment (4): A commenter noted that OMB No. 1625--NEW is dated June 2014,

inferring that is already in use (or may be required for use). Because States are currently

in various stages of implementation of the Final Rule (with final implementation required

by January 1, 2017), States cannot be compelled to begin using OMB No. 1625--NEW

prior to January 1, 2017. Any required deviation from the use of CGHQ-

3923 prior to January 1, 2017 will result in additional (and in some cases, significant)

burden and cost to the States.

Answer: The June 2014 date was filled in as a placeholder. The form was drafted and sent for comment early so that the public could comment on the proposed content, and the States could prepare for changes after the data collection is finalized. The Coast Guard has accepted but not required a State’s use of this form.

Comment (5): At this time, the state of Ohio is still in the process of transitioning to the

new requirements cited in 33 CFR 174.19 (which we are required to implement by

January 1, 2017). That being the case, what are the Coast Guard's intentions

with regard to the version of the reporting form we will need to use to make our annual

reporting in 2015 and beyond? Will we have the option to use the ``older'' version of the

reporting form until such time that we have transitioned to the new requirements? And, if

required to use the new form prior to that transition, how will the Coast Guard view

any incomplete data that might not be able to be generated in the new format prior to

completion of the transition?

Answer: The Coast Guard has accepted but not required a State’s use of this form.

Comment (6): Knowing that hull type, and more importantly engine drive information

can be important details in better identifying and understanding the boating demographics

within a state, what is the rationale for omitting this information in this revised collection form?

Answer: The Coast Guard has not used the hull material or engine information collected

in prior registration collections. Because we have not used the data, we removed it from

the form so as to reduce the burden of data reporting on the States.

Comment (7): Do the estimates of the form completion burden account for any initial

burden in transitioning to this revised reporting scheme? What is the basis for estimates

of burden in items 12 and 13 of the Supporting Statement for the collection?

Answer: No. The burden estimate took into account the collection of information, which

is based on the number of respondents, frequency of form submission and an estimate of

the time taken to fill out the form.

Comment (8) is: Is there any relationship between this revision and anticipated efforts to

bring CFR into agreement with the Uniform Certificate of Titling Act for Vessels

(UCOTA-V)?

Answer: There is not a relationship between this revision and the UCOTA-V efforts.

Comment (9): Under Puerto Rico law, a Ship or vessel means any system of

transportation on water that has a motor installed, including, but without been

limited to jet skis, motorized rafts, power sailboats, motor boats, or powered driven boats

of any sort, including homemade vessels powered by motor, but excluding hydroplanes.

A watercraft means a mode of transportation which does not have a motor

installed, such as rowboats, canoes, kayaks, sailboats with or without oars, water skis,

surfboards with or without sail, rafts, inflatable systems, and any device that moves on

the surface of the water without being propelled by a motor, although it could be fit for

installation or adaptation of some type of motor. Therefore, the proposed change

creates an overburden of conflicting definitions or wording to deal with in this case. Also,

the removal of the proposed definitions leaves the accident investigation protocol without

proper wording to aid in the determination of felonies, infractions, or misdemeanors

committed.

Answer: This comment is outside the scope of the Notice requesting comments on this

information collection. Please use the definitions in 33 CFR 173.3 for this

information collection.

Comment (10): SS173.57: Same comment as in the previous paragraph. Mainly, when

evaluating marine events involving either vessels, watercrafts, or both. It may also affect

the terms and conditions of the memorandum of Agreement between the Government of

the Commonwealth of Puerto Rico and the USCG under 14 U.S.C. SS2,89,141; 46

CFR SS13109 and 33 CFR SS100.01 as to comply with 46 U.S.C. 13103(c)(2)

on the matter of marine events and boat accident reports procedures.

Answer: This collection of information does not relate to marine events or boat accident

report procedures. Therefore, this comment is outside the scope of the Notice requesting

comments on the collection.

Comment (11): The definitions in 33 CFR 181.3 do not include the manufacturing of

handmade vessels and is inconsistent with SS181.23(b). It should include person engaged

in the manufacture of a boat for his or her own use (operation) and not for sale.

Answer: This collection of information is for all registered vessels. If a homemade vessel

is registered, it should be included in the statistics.

Comment (12): If a state has already transitioned--or will soon transition--its

numbering system and the content of the certificates of number over to the requirements

cited in 33 CFR 174.19 (i.e., before the Jan. 1, 2017 implementation deadline), what

version of the form is it suppose to use? If, as a result of the ICR, the OMB formally

approves the collection and issues an OMB Control Number to this revised form 3923

before the Jan. 1, 2017 deadline for states to implement the new requirements, will a state

that does not make the transition until the deadline be able to submit its data on the ``old''

version of the form?

Answer: States would be asked to submit information on the historic form. If a State has already transitioned to the new terms ahead of the January 1, 2017 deadline, the Coast Guard will accept registration data on either form.

Comment (13): If there are variations in the version of the forms employed by the

states and submitted to the Coast Guard, how will the Coast Guard reconcile those

differences in the computation and report-out of registration data?

Answer: The Coast Guard will merge datasets if both the historic and proposed forms are

used. In addition to the above comments submitted to the docket, the following comments and questions were received by Coast Guard program staff members:

Comment (14): Is this just the periodic request to approve the continuation of the

collection of registration data?

Answer: Yes.

Comment (15): Has the Notice been issued primarily (at this time) as part of the

process to get OMB to issue a control number?

Answer: Yes.

Comment (16): Is this in preparation for collection of registration data under the

``new'' vessel terms authorized by the Final Rule on State Numbering System (SNS),

Vessel Identification System (VIS), and Boating Accident Report Database (BARD) (eff.

Jan 2017)?

Answer: Yes. This form makes use of the ``primary operation'' and ``vessel type'' in 33

Code of Federal Regulation 174.19.

Comment (17): Is there a revised collection form that will accompany it?

Answer: Yes. There is a revised collection form that is greatly simplified. The proposed

revision provides instructions, a breakdown of recreational vessel types by motorization

and length category, a breakdown of commercial vessel types, and an administration section.

Comment (18): Will there be any other supporting documentation posted to

regulations.gov for this Notice?

Answer: Yes. The Coast Guard posted additional files to docket USCG-2014-0173, including the proposed registration form and supporting statement.

Comment (19): A commenter questioned the Coast Guard’s response to previously

submitted comment (6) in which the Coast Guard noted a reduced reporting burden with the revised form. The commenter noted that the burden is not reduced since collecting aspects of vessels such as hull material and engine type are already required under 33 CFR 174 even if statistics regarding these aspects are not required on form CGHQ-3923.

Answer: The burden of filling out the revised form is reduced. On the previous version of CGHQ-3923, the Coast Guard required statistics on over 150 data points whereas the proposed version of the form requires only 69. The previous version requested information on five variables (vessel type, hull material, length, engine type, and use) whereas the proposed version requires only three variables (vessel type, length, primary operation). The Coast Guard expects a reduced burden as the proposed form will require fewer queries and fewer data point checks to complete it.

Comment (20): A commenter questioned why aspects of vessels such as hull material and engine type are necessary in 33 CFR 174 since they are not required elements to be reported on form CGHQ-3923.

Answer: Various aspects of vessels are required to be collected for law enforcement purposes. Even though various vessel aspects such as hull material and engine type are not on the proposed form CGHQ-3923, they are used in accident, theft, and fraud investigations. Using common terminology facilitates common understanding.

Comment (21): A commenter noted that hull material and engine type are of interest to sectors and should be on form CGHQ-3923 since information on them cannot be obtained outside of CGHQ-3923.

Answer: The Coast Guard works with various sectors including government, industry, non-profits, and researchers. If a party requested information other than what is available on CGHQ-3923, the Coast Guard would direct the user to a more appropriate contact.

Comment (22): A commenter provided a recommended version of CGHQ-3923 that is a modification of the previous CGHQ-3923. It includes additional hull material entries, an additional engine type, and changes the names of some categories.

Answer: The Coast Guard thanks the commenter for the suggested form but maintains a desire to have a simplified form for use by the States. The Coast Guard has not used the hull material or engine information collected previously. Because we have not used the data, we removed it from the form so as to reduce the burden of data reporting on the States.

Subsequently, the Coast Guard published an additional 60-day notice for public comment due to the significant time that has elapsed since the previous notices were published. A 60-day Notice (See [USCG-2014-0713], July 28, 2021, 86 FR 40604) and 30-day Notice (November 22, 2021, 86 FR 66326) were published in the Federal Register to obtain public comment on this collection. The U.S. Coast Guard Office of Auxiliary and Boating Safety received one comment in response to our 60-day notice.

The commenter expressed their support for the collection of information stating that the USCG should be allowed to collect the necessary information. The commenter also stated this rule is likely to result in a reduced reporting burden for the states; this, however, is in comparison to the form(s) the states have been using for the annual summary and submission of recreational vessel registration data to the Coast Guard, and not with regard to the substantial data collection and capture requirements that were imposed by the final rule. The commenter continued by stating they strongly encourage the expeditious, formal approval of this information collection request and authorization of the accompanying Form CGHQ-3923 to alleviate uncertainties among the states as to how and to what level of detail these data should be reported to the Coast Guard; and, they strongly encourage the Coast Guard's development and adoption of instructions for the states' use in completing both the Application for Certificate of Number (33 CFR 174.17) and the Form CGHQ-3923, for the sake of data consistency. Accordingly, no changes have been made to the Collection.

9) Provide any payment or gift to respondents.

There will be no offer of monetary or material value to respondents for this information

collection.

10) Assurances of confidentiality provided to respondents.

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) Additional justification for any questions of a sensitive nature.

There are no questions of sensitive language.

12) Burden Hour and Annualized Cost Estimates.

The 56 administrative individuals will spend three quarters of one hour to fill out the form.  The mean wage of a records clerk nationally was $21.10 according to the Bureau of Labor Statistics’ May 2020 estimate, http://www.bls.gov/oes/current/oes_nat.htm#43-0000.  Collectively, it will cost all record keepers $886.20 to accomplish this task.

Estimated annual respondents: 56

Estimated annual responses: 56

Estimated annual burden hours: 42

Type of Respondent	Form Name / Form Number	No. of Respondents	No. of Responses per Respondent	Avg. Burden per Response (in hours)	Total Annual Burden (in hours)	Avg. Hourly Wage Rate	Total Annual Respondent Cost
	CGHQ-3923
Total		56	1	.75	42	21.10	$886.20

13) Estimate of capital and start-up costs.

None

14) Estimates of annualized cost to the Federal Government.

USCG staff members to review data = 56 submissions x $58.16/hr x 0.083 hrs to review each submission = $270.33

15) Reasons for change in the burden.

This is a new collection of information.

16) Plans for tabulation, statistical analysis and publication.

This information requested is a tabulation of vessel registration data submitted by states at least three months before it is due. In accordance with 33 CFR 174.123, reports under current requirements are due prior to 1 March of the following reporting year. So, for instance, CY20 data was due prior to 1 March 2021. Once received, the information is logged by the Statistician in the Office. It takes approximately five minutes to log each one and double check to make sure that numbers accurately tally. If there is an error, the Statistician will contact the State for clarification.

Once reviewed, the information is aggregated and reported out nationally in the annual Recreational Boating Statistics report.

17) Approval for not explaining the expiration date for OMB approval.

The Coast Guard will display the expiration date for OMB approval of this

information collection.

18) Explain each exception to the certification statement.

The Coast Guard does not request an exception to the certification of this information collection.

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