IC 2133-0505 Supporting Statement

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SUPPORTING STATEMENT FOR PAPERWORK REDUCTION ACT SUBMISSIONS UNDER 5 CFR PART 1320

Information Collection: 2133-0505, Voluntary Tanker Agreement

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.

This collection of information supports DOT's Security, Preparedness and Response Strategic Goal.

The Voluntary Tanker Agreement is a voluntary agreement, in accordance with section 708, Defense Production Act, 1950, as amended (50 U.S.C. App. 2158), under which participants agree to contribute, either by direct charter to the Department of Defense (DOD) or to other participants, tanker capacity as requested by the Maritime Administrator at such times and in such amounts as the Administrator shall determine to be necessary to meet the essential needs of DOD for the transportation of petroleum and petroleum products in bulk by sea.

The Maritime Administrator recertifies the need for and the Attorney General approves the agreement every five years.

The Maritime Administration's (MARAD) Voluntary Tanker Agreement (VTA) asks that each participant, when requested by the Maritime Administrator, submit reports setting forth information on controlled tonnage necessary for the carrying out of the agreement. The information would consist of distribution of tanker capacity necessary to satisfy DOD emergency requirements.

Information on controlled tonnage is fleet inventory information that is maintained routinely for company operation and management purposes. No unique information is required by the Government for the purpose of the agreement and no report format is prescribed for submission of the information. All that is required is that a list of the names of ships owned, chartered or contracted for by the participant, and their size and flags of registry be provided to MARAD on request. Technical data on the tanker is supplied from MARAD files. As a practical matter, we do not foresee a need for the participants to maintain records until the agreement is activated. MARAD will maintain all records of meetings and communication between MARAD and participants.

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 information received will be used by MARAD personnel to evaluate tanker capability and make plans for the use of this capability to meet national emergency requirements. This information will be used by both MARAD and Department of Defense to establish overall contingency plans. The contingency plans, with accompanying tanker data, are classified and not available to the general public.

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. Also describe any consideration of using information technology to reduce burden.

The VTA application forms will be available on the MARAD website and provided by email when requested. The forms have been configured to be filled out digitally. While applicants may choose to submit parts of the form electronically, MARAD requires original signatures and corporate seals for the “Application to Participate in the Voluntary Tanker Agreement”.

The initial enrollment application must be submitted as two originals. Upon approval, one of the originals is returned to the applicant and one is retained by MARAD. The agreement commits the applicant for one fiscal year and is automatically renewed, unless the participant provides written notification of their intent to terminate participation in the VTA. MARAD requires the participants to provide annual updates of technical data for participating tank vessels. The annual data may be submitted by email and acknowledged by email.

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.

An examination of the Catalog of Federal Domestic Assistance and the Catalog of Federal Paperwork Requirements did not reveal any similar information collections.

The input of data from each tanker company will affirm the number of tankers committed to the Voluntary Tanker Agreement and is therefore unique and necessary.

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.

Tanker owners generally are not small business as defined by the Small Business Administration criteria. If small businesses want to apply, there is no restriction.

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 this collection is not conducted, this Agency and the Department of Defense would have no capacity for determining the availability of militarily useful tankers to support U.S. military requirements in time of war or national emergency.

7. Explain any special circumstances that would cause an information collection

to be conducted in a manner:

• requiring respondents to report information to the agency more often than

quarterly;

• requiring respondents to prepare a written response to a collection of

information in fewer than 30 days after receipt of it;

• requiring respondents to submit more than an original and two copies of any

document;

• requiring respondents to retain records, other than health, medical, government

contract, grant-in-aid, or tax records for more than three years;

• in connection with a statistical survey, that is not designed to produce valid and

reliable results that can be generalized to the universe of study;

• requiring the use of a statistical data classification that has not been reviewed

and approved by OMB;

• that includes a pledge of confidentiality that is not supported by authority

established in statute or regulation, that is not supported by disclosure and data

security policies that are consistent with the pledge, or which unnecessarily impedes sharing data with other agencies for compatible confidential use; or

• requiring respondents to submit proprietary trade secret, or other confidential

information unless the agency can demonstrate that it has instituted procedures

to protect the information's confidentiality to the extent permitted by law.

The original application must be submitted with two originals. Upon approval, one of the originals is returned to the applicant and one is retained by MARAD.

8. 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.

• Describe 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.

• Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every

three years - even if the collection of information activity is the same as in prior

periods. There may be circumstances that may preclude consultation in a

specific situation. These circumstances should be explained.

The Maritime Administration published a 60-day notice and request for comments on this information collection in the Federal Register on October 7, 2019 (84 F.R. 53558) indicating comments should be submitted on or before December 6, 2019. No comments were received. In addition, a 30-day notice was published in the Federal Register on October 24, 2019, (71069 F.R. 84, No. 247) indicating comments should be submitted on or before December 26, 2019. No comments were received.

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

No payments or gifts are provided to respondents.

10. Describe any assurance of confidentiality provided to respondents and the

basis for the assurance in statute, regulation, or agency policy.

All data collected from individual companies will be maintained and treated by MARAD as confidential and will not be released to the general public. The Voluntary Tanker Agreement requires MARAD to take all necessary steps to protect proprietary or classified data.

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.

Not applicable. There are no questions of a sensitive nature.

12. Provide estimates of the hour burden of the collection of information. The

statement should:

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. Unless directed to do so, agencies should not conduct special surveys to obtain information on which to base hour burden estimates. Consultation with a sample (fewer than 10) of potential respondents is desirable. If the hour burden on respondents is expected to vary widely because of differences in activity, size, or complexity, show the range of estimated burden and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

• If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens in item 13 of OMB Form 83-I.

• Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories. The cost of contracting out or paying outside parties for information collection activities should not be included here. Instead, this cost should be included in item 14.

No. of Respondents	Responses per Respondent	Total Responses Annually	Hours Per Response	Total Hours Annually
15	1	15	1	15

A determination of the estimated number of hours required per response was made after consultation with several respondents.

It is estimated that one administrative support worker spends approximately one hour of their time collecting and assimilating the information submitted with each response. Therefore, given an average salary of $29.59 per hour, the total cost to the respondents is as follows:

$29.59 (Hourly wage) x 1.4 (Overhead & Benefits) = $41.43 (Cost Per Hour)

No. of Respondents	Per Response	Cost per Hour	No. of Hours	Hours Cost Annually	Other Cost Annually	Total Cost Annually
15	1	$41.43	1	$621.45	See #13	$621.45

Median Hourly wage for an Administrative Support worker was taken from the BLS Occupational Wage table: https://www.bls.gov/oes/current/oes_nat.htm#43-6011.

13. Provide an estimate of the total annual cost burden to respondents or

recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden shown in items 12 and 14).

• The cost estimate should be split into two components: (a) a total capital and start-up cost component (annualized over its expected useful life); and (b) a total operation and maintenance and purchase of services component. The estimates should take into account costs associated with generating, maintaining and disclosing or providing the information. Include descriptions of methods used to estimate major cost factors including system and technology acquisition, expected useful life of capital equipment, the discount rate(s), and the time

period over which costs will be incurred. Capital and start-up costs include, among other items, preparations for collecting information such as purchasing computers and software; monitoring, sampling, drilling and testing equipment; and record storage facilities.

• If cost estimates are expected to vary widely, agencies should present ranges of cost burdens and explain the reasons for the variance. The cost of purchasing or contracting out information collection services should be a part of this cost burden estimate. In developing cost burden estimates, agencies may consult with a sample of respondents (fewer than 10), utilize the 60-day pre-OMB submission public comment process and use existing economic or regulatory impact analysis associated with the rulemaking containing the information collection, as appropriate.

• Generally, estimates should not include purchases of equipment or services, or portions thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with requirements not associated with the information collection, (3) for reasons other than to provide information or keep records for the government, or (4) as part of customary and usual business or private practices.

(a) Total Capital and Start-Up Costs Estimate: Materials and Postage Costs for return mailing of applications to MARAD (estimated at $24 per applicant) would be $360 for 15 applicants.

(b) Total Operation and Maintenance and Purchase of Services Estimate: There are no operation and 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.

The total annual cost to the Federal Government for processing the collection is estimated as follows:

One-time Costs: $0

Annual Costs: $2,218.59

It is estimated that 1 employee is assigned specific tasks related to the VTA program enrollment. These tasks include the preparation of materials to be mailed to potential VTA applicants, receiving incoming information from the VTA applicants, analysis of the information (ensuring that each potential VTA applicant has submitted all requested data), follow-up communication with the applicants where applicable, and the preparation of material to be sent to applicants that are approved for the VTA. The total time each employee dedicates to the VTA program enrollment process varies according to the assigned task. The total combined time is approximately 2 hours per respondent.

No. of Employees	Hourly Wage	Project Time (Hrs)	Benefits	Cost per Application
1 GS-13 Step 4	*$52.27	2	1.4	$146.36

Annual Labor Costs- $146.36 x 15 responses per year = $2,195.34

Annual Mailing Costs 15 x .55 (stamp) x 1.00 (envelope) = $23.25

Maximum Total Annual Cost to Federal Government: $2,218.59

*Hourly wage rates were taken from the GSA 2019 Pay Scale: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2019/DCB_H.pdf.

15. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of OMB Form 83-I.

There has been an increase ($) in the cost to the respondents since last reported in 2016. The cost for the respondents to prepare the necessary documents has increased from $626.35 to $721.39 due to labor costs.

16. For collections of information whose results will be published, outline plans for tabulation and publication. Address any complex analytical techniques that will be used. Provide the time schedule for the entire project, including beginning and ending dates of the collection of information, completion of report, publication dates and other actions.

There are no plans to publish the results of this information collection 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.

MARAD is not seeking such approval.

18. Explain each exception to the certification statement identified in Item 19,

"Certification for Paperwork Reduction Act Submissions," of OMB Form 83-I.

Not applicable. There are no exceptions to the certificate statement.

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