03122020_Supporting Statement 1010-0187

Supporting Statement for Paperwork Reduction Act Submissions

Project Planning for the Use of OCS Sand, Gravel, and

Shell Resources in Construction Projects that Qualify for a

Negotiated Noncompetitive Agreement

OMB Control Number 1010-0187

Current Expiration Date: 8/31/2020

Terms of Clearance: None

General Instructions

A completed Supporting Statement A must accompany each request for approval of a collection of information. The Supporting Statement must be prepared in the format described below, and must contain the information specified below. If an item is not applicable, provide a brief explanation. When the question, “Does this information collection request (ICR) contain surveys, censuses, or employ statistical methods?” is checked "Yes," then a Supporting Statement B must be completed. The Office of Management and Budget (OMB) reserves the right to require the submission of additional information with respect to any request for approval.

Specific Instructions

A. Justification

1. Explain the circumstances that make the collection of information necessary. Identify any legal or administrative requirements that necessitate the collection.

Under the authority delegated by the Secretary of the Interior, the Bureau of Ocean Energy Management (BOEM) is authorized, pursuant to section 8(k)(2) of the Outer Continental Shelf (OCS) Lands Act (43 U.S.C. 1337(k)(2)), to convey rights to OCS sand, gravel, and shell resources by negotiated noncompetitive agreement (NNA) for use in shore protection and beach and coastal restoration, or for use in construction projects funded in whole or part by or authorized by the Federal Government.

The program has seen an increase in demand for OCS resources due to the decreasing availability of sand sources located in state waters and an increase in coastal storm intensity, duration, and frequency. Since 2017, 17 projects have been processed. In order for BOEM to continue to meet the needs of local and state governments, information regarding upcoming projects must be acquired to plan for future projects and anticipated workload. Therefore, BOEM will issue calls for information about needed resources and locations from interested parties to develop and maintain a project schedule. It includes an annual call for information and the potential for a call in response to an emergency declaration, such as a tropical storm. This ICR has no significant changes from the 2017 OMB approved information collection.

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. Be specific. If this collection is a form or a questionnaire, every question needs to be justified.

BOEM manages a project schedule, based on information from previous solicitations of interest and current knowledge. BOEM seeks information pertaining to upcoming shore protection and beach and coastal restoration projects that may consider the use of OCS material. The call for information (e.g., letter, Federal Register notice) will request interested parties to submit a description of their proposed projects for which OCS resources will be used. The description must include the offshore borrow sites if known, the estimated date of construction, a short description of current project funding, and the name of a primary point of contact with that person’s mailing address, telephone number, and e-mail address, as well as any additional information concerning the status of the project that would be useful to BOEM. This information may include detailed maps, geospatial data and coordinates of desired sand resources and sites that would be nourished, a description of the environmental documents that have been completed to date concerning any portion of the project, a cited reference list, status of geological and geophysical permit (if required), information concerning known or suspected archaeological or historic artifacts, interpretations of geology and extent of sand areas, historical data related to the proposed borrow or placement area, and a description of the status of Federal, state, and/or local permits required for the project.

In the event the number of requested projects exceeds the limits of the current BOEM staff and funding resources, BOEM may request the relevant states to prioritize their own projects based on several criteria including likelihood of project funding and progress of environmental work.

The project schedule will help BOEM determine appropriate future resource allocation, identify potential conflicts of use, conduct environmental analyses, develop NNAs, and meet all necessary environmental and legal requirements. Hurricane Sandy demonstrated BOEM’s need for accurate and timely information following a natural disaster declaration. We also include a potential call in response to emergency declarations, such as a tropical storm.

BOEM publishes all ongoing projects on the Web site at http://www.boem.gov/Requests-and-Active-Leases/.

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 and specifically how this collection meets GPEA requirements.

Based on past experience with these types of projects, we expect 100 percent of all information will be submitted electronically.

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 collected is unique to BOEM and is not available from other sources.

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

This collection of information does not have a significant economic effect on small businesses or small entities, as defined by the Small Business Administration. We do not feel the amount of information requested will have a significant impact as businesses will be providing the minimum amount of information needed. The respondents are State or local government level agencies and offices only.

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 BOEM did not collect the information, we could not determine appropriate future resource allocation, identify potential conflicts of use, conduct environmental analyses, develop NNAs, and meet all necessary environmental and legal requirements.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner:

(a) requiring respondents to report information to the agency more often than quarterly.

Not applicable in this collection.

(b) requiring respondents to prepare a written response to a collection of information in fewer than 30 days after receipt of it.

Only applicable in this collection during emergency situations, such as before, during, or in response to a tropical storm. BOEM may then ask affected entities to respond to a call for information within 15 days/weeks of receipt in order to ensure emergency situations are given appropriate priority.

(c) requiring respondents to submit more than an original and two copies of any document.

Not applicable in this collection.

(d) requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records, for more than 3 years.

Not applicable in this collection.

(e) 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.

Not applicable in this collection.

(f) requiring the use of statistical data classification that has been reviewed and approved by OMB.

Not applicable in this collection.

(g) 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 of data with other agencies for compatible confidential use; or

This collection does not include a pledge of confidentiality not supported by statute or regulation.

(h) requiring respondents to submit proprietary trade secrets 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.

This collection does not require proprietary, trade secret, or other confidential information not protected by agency procedures.

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 in response to the PRA statement associated with the collection over the past 3 years 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 3 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.

As required in the PRA (5 CFR 1320.8(d)), BOEM published a 60-day review and comment notice in the Federal Register on December 11, 2019 (84 FR 67753). We received no comments in response to the 60-day Federal Register notice. Also, the PRA requires us to inform you that we may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB Control Number; therefore, we will display the OMB Control Number on all Calls for Information, as well as, provide the address for sending comments to BOEM.

During the comment period, BOEM requested input from the below respondents on the availability of data, frequency of collection, clarity of instructions, and elements being collected. BOEM also sent the respondents a copy of the Stakeholder Letter for their review and comment. The respondents had no changes or updates to our request for input.

Brevard County, FL, Natural Resource Management Office, Environmental Scientist, Viera, FL.

Carteret County, NC, Shore Protection Office, Shore Protection Manager, Emerald Isle, NC.

City of Virginia Beach, VA Public Works Coastal Department, Coastal Program Manager, Virginia Beach, Va.

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

BOEM will not provide payment or gifts to respondents in this collection.

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

BOEM will protect proprietary information according to the Freedom of Information Act (5 U.S.C. 552) and DOI’s implementing regulations (43 CFR 2).

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.

The collection does not include sensitive or private questions.

12. Provide estimates of the hour burden of the collection of information. The statement should:

(a) 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 hour burden, and explain the reasons for the variance. Generally, estimates should not include burden hours for customary and usual business practices.

(b) If this request for approval covers more than one form, provide separate hour burden estimates for each form and aggregate the hour burdens.

There are approximately 15 States and 25 counties that comprise potential respondents. The burden estimates below include the time for reviewing instructions, searching existing data sources, gathering and maintaining the data needed, and completing and reviewing the collection of information. The frequency of responses submitted to BOEM is annual and in response to an emergency declaration, and responses are required to obtain and or retain a benefit (43 U.S.C. 1337).  We estimate the total annual burden is 200 hours. Individual County Compilation: 25 counties x 1 hour/county x 2 responses/year = 50 hours; Individual State Compilation: 15 States x 5 hours/State x 2 responses/year = 150 hours (50 county hours and 150 State hours = 200 total burden hours).

(c) 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 under “Annual Cost to the Federal Government.”

The average respondent cost is $59/hour (rounded). This cost is broken out in the below table using the Bureau of Labor Statistics data for the Jacksonville, FL area*. See BLS website: https://www.bls.gov/oes/current/oessrcma.htm.

[All figures are rounded]

Position	Hourly Pay rate ($/hour estimate)	Hourly rate including benefits (1.6** x $/hour)	Percent of time spent on collection	Weighted Average ($/hour)
Secretary/Administrative (43-6011)	$25	$40	15%	$6
***County Project Mgr	$37	$59	50%	$30
***State Project Mgr	$42	$67	30%	$20
***Planning Supervisor	$42	$6	5%	$3
Weighted Average ($/hour)				$59

*Note that this BLS source reflects their last update from May 2018.

**A multiplier of 1.6 (as implied by BLS news release USDL-19-2195, December 18, 2019 (see http://www.bls.gov/news.release/ecec.nr0.htm)) was added for benefits.

***Management occupations (County Project Mgr relates to Urban and Regional Planner; 19-3051, State Project Mgr and Planning Supervisor relates to Natural Science Managers; 11-9121).

Based on a cost factor of $59 per hour, we estimate the total annual cost to industry is $11,800 ($59 x 200 hours = $11,800).

13. Provide an estimate of the total annual non-hour cost burden to respondents or recordkeepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected in Item 12).

(a) The cost estimate should be split into two components: (1) a total capital and start-up cost component (annualized over its expected useful life) and (2) 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 (including filing fees paid). 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.

(b) If cost estimates are expected to vary widely, agencies should present ranges of cost burden 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.

(c) 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.

There are no non-hour cost burdens associated with this collection of information.

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.

The average cost to the Federal government is $75/hour. This cost is broken out in the below table using the Office of Personnel Management pay schedule for the Washington, DC area (https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/2020/general-schedule/).

Position	Grade	Hourly Pay rate ($/hour estimate)	Hourly rate including benefits (1.6* x $/hour)	Percent of time spent on collection	Weighted Average** ($/hour)
Division Chief(s)	15/5	$77	$123	3.2%	$ 4
Branch Chief (s)	14/5	$66	$106	5.7%	$ 6
Physical Scientist	13/5	$56	$ 90	27.9%	$25
Physical Scientist	11/5	$39	$ 62	47.4%	$29
Biologist	12/5	$47	$ 75	4.3%	$ 3
Archeologist	12/5	$47	$ 75	7.2%	$ 5
Env. Protection Specialist	12/5	$47	$ 75	4.3%	$ 3
Weighted Average ($/hour)					$75

*A multiplier of 1.6 (as implied by BLS news release USDL 19-2195, December 18, 2019, (see http://www.bls.gov/news.release/ecec.nr0.htm)) was added for benefits.

** Rounded.

To analyze and review the information required by this ICR, we estimate the Government will spend 1,000 hours per year. Based on a cost factor of $75 per hour, the annual cost to the Government is $75,000 (1,000 hours x $75 = $75,000).

15. Explain the reasons for any program changes or adjustments in hour or cost burden.

The currently approved burden for this collection is 200 hours. With this renewal, we are requesting the same total of 200 burden hours. There are no non-hour cost burdens.

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.

BOEM will not tabulate the data; however, BOEM publishes all ongoing projects on the website at http://www.boem.gov/Requests-and-Active-Leases/.

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.

We will display the OMB control number and expiration date on the Call for Information.

18. Explain each exception to the topics of the certification statement identified in, “Certification for Paperwork Reduction Act Submission.”

To the extent that the topics apply to this collection of information, we are not making any exceptions to the “Certification for Paperwork Reduction Act Submissions.”