1625-0102_SS_r0_2020

1625-0102

Supporting Statement
for
National Response Resource Inventory
OMB No.: 1625-0102
COLLECTION INSTRUMENTS: Instruction
A. Justification
1. Circumstances that make the collection necessary.
The Oil Pollution Act of 1990 (OPA 90) (Pub. L. 101-380 sec. 4202(a); 33 U.S.C. 1321(j)(2)(A)) mandated
the creation of a national database of response resources maintained by the Coast Guard. This voluntary
equipment locator system is known as the Response Resource Inventory (RRI).
In 1995, the RRI was expanded to accommodate the Coast Guard’s Oil Spill Removal Organization
(OSRO)1 classification initiative. The OSRO classification process can streamline the preparation and
review of vessel and facility response plans by allowing planholders to list OSROs by name and
classification as an alternative to listing extensive resources in their plans, since their resources are listed
in the RRI. OSRO classification is a strictly voluntary program which planholders can use for regulatory
planning compliance purposes. An OSRO does not have to be classified and planholders do not have to
limit their response resources to Coast Guard classified OSROs. Information about the OSRO
classification program and how to participate in it is at this LINK.
2. Purpose of the information collection.
The voluntary submission of this information will assist in maintaining the established centralized
response equipment inventory. The collected information will allow for better organization and response
time in events similar to the M/V EXXON VALDEZ disaster, and thus help reduce environmental
damages. The information has been used to record the location and availability of response resources.
3. Consideration of the use of improved technology.
The information is submitted electronically via the web at https://cgrri.uscg.mil. We estimate that 100% of
the reporting requirements are done electronically.
4. Efforts to identify duplication.
There is no State or local regulation relating to this issue. No similar information collection is conducted
by other Federal agencies. Similar information does not exist in a centralized location.
5. Methods to minimize the burden to small businesses.
An OSRO supplies information only if it voluntarily decides to participate in the Coast Guard classification
process. This information collection does not have an impact on small businesses or other small entities.
6. Consequences to the Federal program if collection were conducted less frequently.
If information were collected less frequently, neither the Coast Guard nor the OSROs would have
complete knowledge of response equipment amounts or locations. This could significantly slow response
efforts to emergencies and potentially increase environmental damages from oil spills near
1

An Oil Spill Removal Organization (OSRO) owns or controls oil spill removal resources that are designed for, or
capable of, removing oil from the water or shoreline. OSROs provide response equipment and services, individually
or in combination with subcontractors, directly to an owner or operator of a tank vessel or facility required to have a
response plan under 33 U.S.C. 1321(j)(5).

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environmentally sensitive areas.
Timely collection or verification of resource data offers several benefits: (1) better organization of
response resources during an emergency; (2) potential decreases in the amount of time needed to
respond to a spill; and (3) the possibility of using acquired information for contingency planning by the
plan holders.
7. Special collection circumstances.
This information collection is conducted in manner consistent with the guidelines in 5 CFR 1320.5(d)(2).
8. Consultation.
A 60-Day Notice (See [USCG-2020-0185], May 13, 2020, 85 FR 28646) and 30-Day Notice (September
3, 2020, 85 FR 55019) were published in the Federal Register to obtain public comment on this collection.
The Coast Guard received four submissions to the 60-day notice. Three submissions were unrelated to
the Notice, and one submission had four ICR-related comments. In response to the comments, no
changes were made to the Collection.
9. Decision to provide payment or gift to respondents.
There is no offer of monetary or material value for this information collection.
10. Describe any assurance 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 Coast Guard Maritime Information eXchange
(CGMIX) Privacy Impact Assessment (PIA) and Marine Information for Safety and Law Enforcement
(MISLE) System of Records Notice (SORN). Links to the MISLE PIA and SORN are provided below:
 https://www.dhs.gov/publication/dhsuscgpia-022-coast-guard-maritime-information-exchange
 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. Estimate of the hour and cost burden to respondents.
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The estimated number of annual respondents is 147.
The estimated number of annual responses is 147.
The estimated hour burden is 1,378 hours.
The estimated cost burden is $107,484.

The burden to respondents is provided in Appendix A. The wage rates used are in accordance with the
current edition of COMDTINST 7310.1(series) for “Out-Government” personnel.
We estimate that the time it takes an OSRO specialist to enter data into the RRI depends on whether it is
a new OSRO application or an update to an existing OSRO application. The time also depends on the
size of the OSRO.2 We estimate that a new application takes about 40 hours for a large-size OSRO, 20
hours for a medium-size OSRO, and 10 hours for a small-size OSRO. We estimate that an application
update takes 24 hours for a large-size OSRO, 12 hours for a medium-size OSRO, and 6 hours for a
2

For estimation purposes, we have grouped OSROs by the number of Captain of the Port (COTP) zones and/or
Alternative Classification Cities (ACCs) that they offer coverage. A small-size OSRO provides coverage in 5 or fewer
COTP zones/ACCs. A medium-size OSRO provides coverage in 6 to 30 COTP zones/ACCs. A large-size OSRO
provides coverage in 31 or more COTP zones/ACCs.

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small-size OSRO. The position of an OSRO specialist is analogous to a GS-12.
13. Estimates of annualized capital and start-up costs.
There are no capital, start-up or maintenance costs associated with this information collection.
14. Estimates of annualized Federal Government costs.
The estimated annual Federal Government cost is $67,800 (see Appendix B). We estimate that the time
it takes a Coast Guard response specialist to review an OSRO application (new or update) depends on
the size of the OSRO. We estimate that a new application review takes 24 hours for a large-size OSRO,
16 hours for a medium-size OSRO, and 8 hours for a small-size OSRO. We estimate that an application
update review takes 12 hours for a large-size OSRO, 8 hours for a medium-size OSRO, and 4 hours for a
small-size OSRO. We estimate that the reviews are conducted by a GS-12. The wage rate shown is in
accordance with the current edition of COMDTINST 7310.1(series) for “In-Government” personnel.
15. Reasons for the change in burden.
The burden remains the same. The reporting requirements, and the methodology for calculating burden,
remain unchanged. .
16. Plans for tabulation, statistical analysis and publication.
This information collection will not be published for statistical purposes.
17. Approval for not displaying the expiration date for OMB approval.
The Coast Guard will display the expiration date for OMB approval of this information collection.
18. Exception to the certification statement.
The Coast Guard does not request an exception to the certification of this information collection.

B. Collection of Information Employing Statistical Methods
This information collection does not employ statistical methods.

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