Supporting Statement A for 2133-0505 6.21.2023

Department of Transportation

Maritime Administration

Information Collection Request (ICR)

2133-0505

Voluntary Tanker Agreement

SUPPORTING STATEMENT

Introduction: This submission is to request a three-year approval from the Office of Management and Budget (OMB) for the information collection entitled OMB 2133-0505 (Voluntary Tanker Agreement), which expires on July 31, 2023. The public burden was updated to include mailing costs for respondents to submit responses for this collection. However, there are no changes to the form, so this collection will be submitted as a renewal of a previously approval collection.

1. Justification

1. Circumstances that make the Collection of Information Necessary

The Voluntary Tanker Agreement (VTA) is a voluntary agreement in accordance with Section 708, Defense Production Act, 1950, as amended (50 United States Code (U.S.C.) 4558). Under this agreement, 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 DOD’s essential needs for the transportation of petroleum and petroleum products in bulk by sea. The Maritime Administrator recertifies the need for the VTA, which is approved by the Attorney General every five years.

The Maritime Administration's (MARAD) VTA requires that each participant, when requested by the Maritime Administrator, submit reports setting forth information on controlled tonnage necessary for execution of this agreement. The submitted information is comprised 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 VTA. However, applicants must provide a list of the names of ships owned, chartered, or contracted by the participant, their size, and flags of registry to MARAD upon request. Technical data on the tanker is supplied from MARAD files. VTA participants do not need to maintain records until the VTA agreement is activated. MARAD will maintain all records of meetings and communication between MARAD and VTA program participants.

The Voluntary Tanker Agreement (VTA) information collection supports the Department of Transportation’s strategic goal for National Security. VTA is an emergency preparedness program created for the Tanker Security Program (TSP) and maintained through the Tanker Security Fleet authority detailed at 46 U.S.C. § 53407, which authorizes MARAD to establish emergency preparedness programs. Specifically, Section 53407 provides that participants that have a TSP operating agreement must enter into an emergency preparedness agreement to make commercial transportation resources (including services) available, upon request by the Secretary of Defense during a time of war or national emergency, or whenever the Secretary of Defense determines that it is necessary for national security or contingency operation. MARAD established the VTA program as an emergency preparedness program and the VTA is the TSP’s corresponding emergency preparedness agreement. Through advance arrangements in joint planning, including the development of VTAs, VTA Program participants will provide product tanker capacity to support a significant portion of surge and sustainment requirements in the deployment of U.S. military forces during armed conflicts or other national emergencies.

2. Purpose and Use of the Information Collection

MARAD personnel will use the information collected for the VTA to evaluate tanker capability and plans for the use of this capability to meet national emergency requirements. Collected information will also be used by both MARAD and DOD personnel to establish overall contingency plans. The contingency plans, with accompanying tanker data, are considered classified information that is unavailable to the general public.

3. Automation or Use of Information Technology (IT)

The VTA application forms is available on the MARAD website and provided by email when requested. The forms have been configured for digital completion. Applicants may submit the form electronically or mail them to MARAD for processing. The initial enrollment application must be submitted as two originals. Upon approval, one of the originals is returned to the applicant while the other is retained by MARAD. The agreement commits the applicant for one fiscal year and is automatically renewed, unless the participant provides written notification regarding their intent to terminate participation in the VTA.

4. Efforts to Identify Duplication

An examination of the Catalog of Federal Domestic Assistance and the Catalog of Federal Paperwork Requirements did not reveal any similar information collections. The data collected from each tanker company is unique and necessary and will be used to affirm the number of tankers committed to the VTA.

5. Impact on Small Businesses or Other Small Entities

This collection has no impact on small businesses or other small entities. However, there is no restriction against small business participation in the VTA.

6. Impacts of Not Conducting or Less Frequently Collection of Information

Without this collection neither MARAD nor DOD personnel would be able to determine the availability of suitable tankers that can support U.S. military requirements in times of war or a national emergency.

7. Special Circumstances Relating to the Guidelines 5 CFR 1320.5

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

8. Public Comments in Response to the Federal Register Notice and Outside

Consultation

MARAD published a 60-day notice and request for comments on this information collection in the Federal Register (FR 29177, Vol 88, No. 87) on May 5, 2023, indicating comments should be submitted on or before July 5, 2023. No comments were received. A 30-day notice will now be published in the Federal Register to solicit public comments.

9. Explanation of Any Payments or Gifts to Respondents

No payments or gifts are provided to respondents.

10. Assurance of Confidentiality and Protection of Privacy

MARAD personnel will maintain and treat all data collected from individual companies for the VTA as confidential. No data will be released to the general public. The VTA also requires MARAD to take all necessary steps to protect proprietary or classified data received for this program.

11. Justification for Any Sensitive Questions

There are no questions of a sensitive nature.

12. Estimate of Annualized Burden Hours and Cost

1. Estimated Annualized Burden

A total of 15 respondents will each take approximately one (1) hour to complete the VTA application. This estimate is based on information provided from applicants regarding the time taken to complete the application, review their responses, compile required data, and obtain a signature by an appropriate officer. Therefore, the total annual burden for the computation of data and completion of the application form is 15 hours, which is illustrated in the table below:

Number of Respondents		Responses Per Respondent		Total Annual Responses		Burden Hours Per Response		Total Annual Burden Hours
15	*	1	=	15	*	1	=	15

2. Estimated Annualized Cost Burden

The Department of Labor website ¹ shows that the average hourly wage rate for an Administrative Support Worker is $ 34.16. As such the estimated annualized cost burden to respondents to collect and assimilate the information submitted for this collection is $ 717.36, which can be calculated as follows:

Estimated Annualized Burden Cost to Respondents for the Computation of Data and Completion of Application Form
Administrative Support Worker 43-6011	Average Hourly Wage Rate		Total Annualized Burden Hours		Estimated Total		Benefits Multiplier		Total Annualized Cost Burden
	$34.16	*	15	=	$512.40	*	1.4		$ 717.36

13. Estimate of the Total Annual Cost Burden to Respondents and/or Recordkeepers

1. Total Capital and Start-Up Costs Estimate:

There are no capital or start-up costs associated with this information collection.

2. Total Operation and Maintenance and Purchase of Services Estimate:

The total cost for copying and mailing applications, for this collection is $ 63.60, which is detailed in the table below:

Applications (15 responses)
Copying 2 applications * (5 pages) @ $ .23 (Per price from FedEx2)	$ 2.30
1 Envelope @ $ .45 each (Per estimate from STAPLES)3	$ .45
Postage ($ .63 per stamp (Per USPS estimate4) * 3 stamps per application)	$ 1.89
Combined Total	$ 4.64
Total Cost ($ 4.64 (cost per respondent) * 15 (total responses)	$ 69.60/ $70

14. Estimates of Federal Government Costs

The total combined annual cost to the Federal Government for mailing and processing applications related to this collection is $ 2,514.78. One Federal employee ( i.e., GS-13, Step 4)⁵ is assigned to specific tasks related to the VTA program enrollment including mailing application materials for the VTA program for a total $ 35.10. This individual will also take a combined total 2 hours to prepare materials to be mailed to potential VTA applicants, and also receive and analyze submitted responses, follow-up with the applicants regarding updates, and confirm approval for the VTA program. The loaded wages associated with these tasks are $ 2,479.68. The total costs associated with these duties are also detailed in the tables below:

Applications
Copies	$0.00
Mailing	$35.10
IT Costs	$0.00
Total	$35.10

Total Mailing Costs
3 stamps per mailing @ ($ .63)6=$1.89		1 envelope per mailing @ ($.45) 7per envelope	=	Total Mailing Cost Per Application	*	Total Applications	=	Annual Mailing Cost
$ 1.89	+	$ .45	=	$2.34	*	15	=	$35.10

Total Combined Cost for Reviewing Applications			Benefits Multiplier		Total Loaded Wages
Review (est. 2 hrs. ea. on 15 applications 8– With an avg. grade level of GS-13 Step 4 @ $ 59.04)	$ 1,771.20	*	1.4	=	$ 2,479.68

Total Combined Federal Government Costs
Mailing Costs		Loaded Wages		Total Combined Costs
$ 35.10	+	$ 2,479.68	=	$ 2,514.78

15. Explanation of Program Changes or Adjustments

The total mailing cost was updated from 0 during the last renewal to $ 69.60/ $ 70 currently since respondents have the option to mail their responses to MARAD for processing in addition to submitting them electronically.

16. Publication of Program Changes or Adjustments

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

17. Display the OMB Expiration Date

MARAD is not seeking approval to omit publication of the expiration date.

18. Exception to the Certification Statement

There are no exceptions to the certification statement.

1 https://www.bls.gov/oes/current/oes_nat.htm

2Price estimates for copying applications were compiled from FedEx: https://www.office.fedex.com/default/copies.html

3 Price estimates for envelopes were compiled from Staples: https://www.staples.com/Quality-Park-10-x-13-Brown-Kraft-Extra-Heavyweight-Clasp-Envelopes-100-Box/product_426678

4 Price estimates for postage costs were compiled from USPS: https://www.usps.com/

5 *Hourly wage rates were taken from the GSA 2023 Pay Scale: https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/23Tables/html/DCB_h.aspx

6 Price estimates for postage costs were compiled from USPS: https://www.usps.com/

7 Price estimates for envelopes were compiled from Staples: https://www.staples.com/Quality-Park-10-x-13-Brown-Kraft-Extra-Heavyweight-Clasp-Envelopes-100-Box/product_426678

8