Letter to OIRA

OIRA Ltr 06-16-2022-165001.pdf

Application and Reporting Elements for Participation in the Tanker Security Program (TSP)

Letter to OIRA

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U.S. Department
of Transportation


1200 New Jersey Avenue, SE
Washington, DC 20590

June 16, 2022
Dr. Dominic J. Mancini
Official Performing the Delegated Duties of Administrator,
Office of Information and Regulatory Affairs,
Office of Management and Budget
725 17th Street NW Washington, DC 20503
Dear Administrator Mancini:

The Maritime Administration seeks emergency processing of a request for approval of a collection of
information concerning the Maritime Administration's (MARAD) Tanker Security Program (TSP).
A classified Fuel Tanker Study (mandated by Fiscal Year (FY) 2020 National Defense Authorization
Act (NDAA)) examined the sufficiency of the U.S.-flag tanker fleet to meet National Defense Strategy
(NDS) requirements. The report's unclassified summary found there to be a substantial risk to the
nation's defense associated with a heavy reliance on foreign flagged tankers, particularly in the intra
theater area and within a contested environment. The location, timing, and specific missions
associated with some tanker requirements dictate the need for U.S .-flagged assets, for which there
currently are insufficient numbers available. The report's gap analysis found a clear and critical need
for a Tanker Security Program to increase U.S. -flag tanker capacity, to reduce the risk of reliance on
foreign flagged tankers for the most important fuel missions, and to ensure the DoD has sufficient
tanker capabilities to meet NDS objectives.

The FY21 NDAA responded to the critical need for U.S.-flag tanker capacity by authorizing the
creation of a new TSP. The FY21 NDAA directed that the Secretary of Transportation, in consultation
with the Secretary of Defense, establish a fleet of American vessels that are actively trading,
commercially viable, militarily useful, and privately owned for the purpose of meeting national
defense and other security requirements and to maintain a United States presence in international
petroleum transportation. To meet the current national security demand, MARAD is acting quickly to
ensure its ability to receive and process applications, followed by the review and execution of
supporting agreements with qualified vessel operators. The U.S. Transportation Command Combatant
Commander (4-star) has stated that the capabilities the Tanker Security Program will bring are a high
priority as the DoD rapidly evolves operations to match fully contested conflicts in the Indo-Pacific
and North Atlantic with pacing threats from China and Russia. DoD leadership has stated that while
the 10 -ship TSP is a good start to the effort to secure reliable tanker capacity, they also recognize a
need for more than the initial 10 ships. In addition, DoD is indicating a high degree of urgency in
MARAD implementing this new authority which will support critical USTRANSCOM bulk petroleum

objectives. DoD points to an urgent need for tankers especially with respect to the carriage of fuel that
DoD forces rely upon for land, air, and seaborne units.

In addition, this collection will be designed to requre the minimum amount of information necessary
for product tankvessel selection and administratio of the TSP. Items such as participant operational
certifications, payment vouchers, and financial report submissions will be included in the proposed
collection of information to monitor participant compliance with program requirements. MARAD has
made all efforts to reduce the administrative burden on the applicants while ensuring the requisite
information is received to make informed decisions on which vessels to select for the program.
For the reasons stated, and under the Paperwork Reduction Act of 1995 and its implementing
regulations at 5 CFR 1320.13, Emergency Processing, MARAD is respectfully requesting emergency
processing for a collection of information critical to its mission of ensuring the United States has
sufficient U.S.-flag tankers to meet NDS requirements. Concurrent with 0MB clearance of its
emergency clearance request, MARAD will continue policy development and follow the normal
clearance procedures for an information collection to implement the Tanker Security Program.

If you would like to discuss this further, please have your staff contact Mr. Mitch Hudson at 202302-7223 or at [email protected].


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