0648-0448 Supporting Statement Part A

SUPPORTING STATEMENT

U.S. Department of Commerce

National Oceanic & Atmospheric Administration

Coral Reef Conservation Program

OMB Control No. 0648-0448

Abstract

This request is for revision and extension to an approved collection of information under the Paperwork Reduction Act, 44 U.S.C. § 3501 et seq., and implementing regulations at 5 C.F.R. Part 1320. The Coral Reef Conservation Act of 2000, 16 U.S.C. § 6401 et seq., has been amended since the last approval and the revised requirements for information collection are outlined below.

The Coral Reef Conservation Act was enacted to conserve and restore the condition of United States coral reef ecosystems challenged by natural and human-accelerated changes; to promote the science-based management and sustainable use of coral reef ecosystems to benefit local communities and the Nation; to develop sound scientific information on the condition of coral reef ecosystems, continuing and emerging threats to such ecosystems, and the efficacy of innovative tools, technologies, and strategies to mitigate stressors and restore such ecosystems; to assist in the preservation of coral reefs by supporting science-based, consensus-driven, and community-based coral reef management by covered States (Florida, Hawaii, and the territories of American Samoa, the Commonwealth of the Northern Mariana Islands, Guam, Puerto Rico, and the United States Virgin Islands) and covered Native entities (an Indian Tribe, the Department of Hawaiian Home Lands, the Office of Hawaiian Affairs, or a Native Hawaiian organization with interests in a coral reef ecosystem); to provide financial resources, technical assistance, and scientific expertise to supplement, complement, and strengthen community-based management programs and conservation and restoration projects of non-Federal reefs; to establish a formal mechanism for collecting and allocating monetary donations from the private sector to be used for coral reef conservation and restoration projects; to support rapid, effective, and science-based assessment and response to exigent circumstances that pose immediate and long-term threats to coral reefs; and to serve as a model for advancing similar international efforts to monitor, conserve, and restore coral reef ecosystems.

Under section 6406 of the Act (Block Grants), covered States are responsible for documenting and reporting the State’s use of Federal funds received under the Act; and expenditures of non-Federal funds made in furtherance of coral reef management and restoration as the NOAA Administrator (Administrator) deems appropriate. The Administrator is responsible for providing guidance on the proper documentation of expenditures.

Under section 6410 of the Act (Ruth D. Gates Coral Reef Conservation Grant Program), the NOAA Administrator, and subject to the availability of appropriations, is authorized to provide up to $3,500,000 annually (per section 6414(c)) in grants for coral reef conservation projects.

The match waiver requests and request for written comments are being removed from this collection as they are no longer applicable. The match waiver requests may still be made under Ruth D. Gates but are not expected and not requested of applicants. They were included in the original because all territories (5) requested a match waiver, however, their awards are now located in Block Grants, and there is no matching requirement.  The Ruth D. Gates application process now requires "evidence of support for the project by appropriate representatives of States...in which the project will be conducted" on the front end.

Additionally, the Performance Progress Report (PPR) from collection 0648-0718 is being added to this collection so that all program requirements are under a single control number. The PPR will be removed from 0648-0718 at the next renewal period.

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.

The Coral Reef Conservation Act of 2000 (16 U.S.C. 6401 et seq.) was enacted on December 14, 2000, to preserve, sustain and restore the condition of coral reef ecosystems; to promote the wise management and sustainable use of coral reef ecosystems to benefit local communities and the Nation; to develop sound scientific information on the condition of coral reef ecosystems and the threats to such ecosystems; to assist in the preservation of coral reefs by supporting conservation programs, including projects that involve affected local communities and non-governmental organizations; to provide financial resources for those programs and projects; and to establish a formal mechanism for the collecting and allocating of monetary donations from the private sector to be used for coral reef conservation projects. The act was amended on December 23, 2022, to revise existing collection requirements previously approved (application and reporting requirements under section 6410) and create new information collection (reporting of non-federal expenditures under section 6406 and coral reef stewardship partnership applications under section 6405).

Application requirements under section 6406 have minor revisions outlined in the Coral Reef Conservation Act (mostly due to applicant eligibility) but remain consistent with the original Coral Reef Conservation Act and are used in the review and selection of competitive financial assistance awards under the new Ruth D. Gates Coral Conservation Grant Program. NOAA will continue to use the information provided for this purpose. Reporting requirements for federal assistance awards remain consistent with prior submissions approved by OMB under collection 0648-0718 and the program seeks to integrate this approved form into the larger 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.

Covered States’ submissions of expenditures of non-Federal funds used to further coral reef management and restoration is required by statute (16 U.S.C. § 6406(c)(2)) and will be collected by secure email by June 30 of each year. Non-federal expenditure reports will be used as a variable in the b;pcl grant funding formula to determine the annual allocation of funding to individual covered States, per section 6406(b)(3). This information may be shared with other NOAA agencies, U.S. Coral Reef Task Force (USCRTF) members, and may be included in mandatory reports to Congress.

Coral reef stewardship partnership applications will be submitted to the U.S. Coral Reef Task Force via email using a NOAA-supplied PDF template form available on the NOAA CRCP website. Coral reef stewardship partnerships are optional for non-federal reefs and NOAA does not receive the submissions directly. Applications are not expected to be submitted more than once ever by any single applicant. Coral reef stewardship partnership members may be eligible for financial assistance opportunities and member lists will be used to verify eligibility of applicants.

Application requirements under the Ruth D. Gates Coral Reef Grant Program will be collected from applicants through Grants.gov. If electronic submission is not possible, paper submissions may be allowable pursuant to the Notice of Funding Opportunity. Information collected for grant applications is to be used in the review and selection process, as required under the Coral Reef Conservation Act. NOAA anticipates collecting application information with each Ruth D. Gates Coral Reef Grant Program Notice of Funding Opportunity, to occur no more frequently than annually. Per section 6410(c), eligible applicants may include a covered reef manager or a covered Native entity; a regional fishery management council; a coral reef stewardship partnership seeking to implement a coral reef action plan; a coral reef research center; or a nongovernmental organization or research institution with demonstrated expertise in the conservation or restoration of coral reefs in practice or through significant contributions to the body of existing scientific research on coral reefs. Specific applicant types for each Notice of Funding Opportunity (NOFO) will be outlined in the respective NOFO language and will be dependent upon the scope of the NOFO.

Performance (technical) reports for financial assistance awards will be collected electronically on a semi-annual basis via the Department of Commerce’s grant management system, eRA Commons. However, the program expects to require the Objectives and Indicators section annually. Performance (technical) progress reports have been used to monitor the performance of awards and are required by the Department of Commerce.

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.

All information will be collected electronically, by email or electronic system. In the event that electronic submission is not available for competitive financial assistance applications under the Ruth D. Gates Coral Reef Grant Program, paper submissions may be allowable pursuant to the Notice of Funding Opportunity.

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 Question 2

Information collected is specific to the Coral Reef Conservation Program and is not expected to be duplicated. The applicant/recipient would not make this information publicly available, so there is no other source from which this information could be obtained.

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

Small businesses are eligible applicants in specific circumstances and instructions are written to require a minimal burden of all applicant types.

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.

Non-federal expenditure values are one of the variables included in the block grant funding formula, which will be used to determine the annual allocation of funding to individual covered States, per section 6406(b)(3). Per section 6406(b)(2), NOAA is required to issue annual solicitations for block grants to the seven (7) covered States, thus necessitating the need for annual solicitation of expenditures of non-Federal funds. If this data is not collected annually, the funding formula would need to be modified and/or timely implementation of the block grant program may be hindered.

Coral reef stewardship partnerships are optional groups created to further community-based stewardship of Federally and non-Federally managed coral reefs (section 6405(a)). Applications are not expected to be submitted more than once ever by any single applicant. As noted in section 2 above, coral reef stewardship partnership applications will be submitted to the U.S. Coral Reef Task Force, via email using a NOAA-supplied PDF template form; NOAA will not receive submission directly. Per section 6405 (b)(2), NOAA must develop processes for adjudicating multiple stewardship partnership applicants for the same reef to ensure no geographic overlap. If the application data is not collected, NOAA will be unable to complete this task.

Information collection requirements for competitive financial assistance applications must be collected for each Notice of Funding Opportunity, and a non-federal entity is required to submit this information for each application. This information is a necessary component of the application process for federal funding.

Performance (technical) progress reports are required by the Department of Commerce to be collected semi-annually and are necessary to monitor progress of funded grant projects.

Coral reef stewardship partnership applications are not expected to be submitted more than once ever by any single applicant.

7. Explain any special circumstances that would cause an information collection to be conducted in a manner inconsistent with OMB guidelines.

There are currently no known circumstances that would cause an information collection to be conducted in a manner inconsistent with OMB guidelines:

● Respondents are NOT required to report information to the agency more often than quarterly;

● Respondents are NOT required to prepare a written response to a collection of information in fewer than 30 days after receipt of it;

● Respondents are NOT required to submit more than an original and two copies of any document;

● Respondents are NOT required to retain records, other than health, medical, government contract, grant-in- aid, or tax records for more than three years;

● Responses are NOT 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;

● NOAA is NOT requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

● NOAA does NOT require 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

● Respondents are NOT required to submit proprietary trade secrets, or other confidential information.

8. If applicable, provide a copy and identify the date and page number of publications 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.

A notice was published in the Federal Register on April 30, 2024 (89 FR 34211). No comments were received.

NOAA consulted with 8 individuals 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, and on the data elements to be recorded, disclosed, or reported. Comments were provided with regard to burden estimates and these comments were used to determine the appropriate burden response time for each collection.

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

The agency does not plan to provide a payment or gift to respondents.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy. If the collection requires a systems of records notice (SORN) or privacy impact assessment (PIA), those should be cited and described here.

In order to maintain confidentiality of Personal Identifiable Information (PII) (e.g., SSNs) and Business Identifiable Information (BII), all submissions are sent to the agency through a secured system. Applicants may also submit confidential information through certified mail or another secure email service of their choice. NOAA shares applications for review through either the eRA grants management system or Accellion Kiteworks (secured).

The collection of information for grant management is authorized under SORN GSA/GOV’T-9.

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or 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 agency does not find these types of questions necessary and does not ask them.

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

The burden estimates for these requirements were based on the time needed for CRCP staff to complete the forms. The Annual Non-Federal Expenditures Reports takes between 5 and 12 hours to complete, so an average of 8.5 hours was used. All burden estimates will be updated as appropriate based on feedback from respondents.

Information Collection	Type of Respondent (e.g., Occupational Title)*	# of Respondents/year (a)	Annual # of Responses / Respondent (b)	Total # of Annual Responses (c) = (a) x (b)	Burden Hrs / Response (d)	Total Annual Burden Hrs (e) = (c) x (d)	Hourly Wage Rate (for Type of Respondent)* (f)	Total Annual Wage Burden Costs (g) = (e) x (f)
CRCP Annual Non-federal Expenditures Report	General and Operations Manager	7	1	7	8.5	59.5	$62.18	$3,699.71
CRCP Ruth D. Gates Program proposal package development and submission	General and Operations Manager	15	1	15	46.5	697.5	$62.18	$43,370.55
CRCP performance progress report and indicator report submission	General and Operations Manager	20	2	40	6	240	$62.18	$14,923.20
Coral reef stewardship partnership applications	General and Operations Manager	7	1	7	1	7	$62.18	$435.26
Totals	En			69		1004*		$62,428.72

* ROCIS shows 1006 burden hours due to rounding.

The median hourly wage for occupational code 11-1021, General and Operations Managers, was used to calculate the hourly wage rate for respondents. https://www.bls.gov/oes/current/oes_nat.htm#11-0000

.

13. Provide an estimate for the total annual cost burden to respondents or record keepers resulting from the collection of information. (Do not include the cost of any hour burden already reflected on the burden worksheet).

Record keeping is done electronically by the Grants Online system. There is no measurable cost associated with this activity. There are no capital costs or operating 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.

Cost Descriptions	Grade/Step	Loaded Salary /Cost	% of Effort	Fringe (if Applicable)	Total Cost to Government
Federal Oversight	GS-14/3 (x 1)	$195,518	10%		$19,518
Other Federal Positions	GS-13/5 ( x 3)	$175,797	10%		$52,739
Contractor Cost (x 7)		$90,000	5%	n/a	$31,500
Travel
Other Costs:
TOTAL				n/a	$103,757

The Rest of U.S. locality rate was used since NOAA employees are geographically dispersed. A 1.5 multiplier was used to obtain the loaded salary. https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2024/RUS.pdf

15. Explain the reasons for any program changes or adjustments reported in ROCIS.

Information Collection	Respondents		Responses		Burden Hours		Reason for change or adjustment
	Current Renewal / Revision	Previous Renewal / Revision	Current Renewal / Revision	Previous Renewal / Revision	Current Renewal / Revision	Previous Renewal / Revision
Matching Funds Waiver Request	0	5	0	5	0	11	Removed from collection as no longer applicable. The match waiver requests may still be made under Ruth D. Gates but are not expected and not requested of applicants. They were included in the original because all territories (5) requested a match waiver, however, their awards are now located in Block Grants, and there is no matching requirement.
Reviewer Comments	0	7	0	42	0	126	Removed from collection as no longer applicable. The Ruth D. Gates application process now requires "evidence of support for the project by appropriate representatives of States...in which the project will be conducted" on the front end.
CRCP Annual Non-Federal Expenditures Report	7	0	7	0	59.5	0	New requirements pursuant to change in law.
CRCP Ruth D. Gates Program Proposal Pkg	15	0	15	0	697.5	0	New requirements pursuant to change in law.
CRCP Performance Progress Report	20	0	40	0	240	0	This form is being added to this collection so all CRCP grant documents are under a single control number. This form will be removed from 0648-0718 at the next renewal of that collection.
Coral Reef Stewardship Partnership Applications	7	0	7	0	7	0	New requirements pursuant to change in law.
Total for Collection	49	12	69	47	1004	137
Difference	37		22		867

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.

This information is not published or made publicly available.

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.

The agency plans to display the expiration date for OMB approval of the information collection on all instruments.

18. Explain each exception to the certification statement identified in “Certification for Paperwork Reduction Act Submissions."

The agency certifies compliance with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).

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