Supporting Statement A for 2133-0025 11.25.2024

Department of Transportation

Maritime Administration

Information Collection Request (ICR)

OMB 2133-0025

Automated Mutual-Assistance Vessel Rescue (AMVER) System

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 2133-0025 (Automated Mutual-Assistance Vessel Rescue (AMVER) System), which expires on November 30, 2024. Since the last renewal there was a slight increase in the total respondents to this collection, which contributed to more responses and burden hours. However, since there are no other changes, this collection will be submitted as an extension with change of a previously approved collection.

1. JUSTIFICATION

1. Circumstances Making the Collection of Information Necessary

In 1975, the Maritime Administration (MARAD), at the request of the Department of Navy, established the U.S. Flag Merchant Vessel Locator Filing System (USMER) to enable the Navy and the Maritime Administration (MARAD) to maintain a current plot of U.S.-flag, and certain non-U.S.-flag ships. This initiative was implemented to facilitate immediate marshaling of ships for national defense purposes.¹

Concurrently, the U.S. Coast Guard (USCG) operated the Automated Mutual-Assistance Vessel Rescue (AMVER) System, receiving reports from ships of all nations for the purpose of maintaining a plot for Search and Rescue (SAR) for safety of life at sea. Participation in AMVER is voluntary.

Subsequently, the Maritime Administrator and the Commandant of the USCG, with the concurrence of the Chief of Naval Operations, agreed that the objectives of USMER and AMVER should be met by a single reporting system. This merger was accomplished in 1986, eliminating the need for separate reports to two different agencies and effectively reducing reporting requirements by 50 percent. The new rule and reporting instructions was published in 46 Code of Federal Regulations (CFR) Subchapter F Part 307² as "Establishment of Mandatory Position Reporting System for Vessels." Safety, in terms of a reduction in transportation-related deaths and injuries, is a Department of Transportation (DOT) strategic goal. This AMVER information collection supports the DOT's strategic goal on safety at sea by providing the USCG with a vessel plot for Search and Rescue (SAR), including the medical evacuation of injured seamen. Additionally, this collection supports the Department of Homeland Security and USCG strategic goal of Response/Maritime Safety/Reducing deaths and injuries on vessels.

Authority: Section 204(b), 212(A), 1203(a) - Merchant Marine Act 1936, as amended (46 United States Code (U.S.C.) 1114(b), 1122.a, 1283; Public Law 9731 (95 Stat. 157 August 6, 1981); Regulation: 46 CFR Part 307 (51 FR 18329 May 19, 1986); 49 CFR 1.66 (46FR 47458 September 28, 1981). Search and Rescue (14 U.S.C. 2, 88, 90, 92, 93, 141, 142, 147, 149, 764, 821-832; 42 U.S.C. 249; 46 U.S.C. 721-731; P.L. 95-61; T.S.

502. 908); T.S. 576.

2. Purpose and Use of the Information Collection

AMVER's primary purpose is to assist the USCG in directing ocean-going ships to assist other ships that are in danger of sinking or experiencing other life-threatening situations. By maintaining a worldwide system of vessel positions, vessels can be diverted to assist a nearby vessel that is in distress. In 2016, 143 ships from 26 countries were diverted to make rescues or assist other vessels which resulted in 283 lives saved.³

MARAD personnel use AMVER in a limited way to access information only on U.S.-flag vessels or those foreign-flag vessels which request that their position reports be made available to MARAD. Specifically, AMVER information is used as follows:

1. To keep track of U.S.-flag vessels which are part of the Maritime Security Program. The ship owners of these militarily useful vessels receive an annual payment from MARAD to keep these vessels sailing commercially under U.S. registry and to make them available to the government in time of national emergency.

2. In the event of a localized area of danger (e.g., mines in a particular body of water), U.S. ships in the vicinity could be notified of the area to avoid.

3. A worldwide plot of U.S.-flag vessels under the Voluntary Intermodal Sealift Agreement (VISA) would assist with the possible use of these ships for national defense purposes.

3. Automation or Use of Information Technology

In recent years, the transmission of AMVER messages has greatly evolved due to the technical improvements and innovations in shipboard communications and satellite technology. Presently the preferred method for ships to send AMVER message to the USCG is by electronic mail to the following email addresses: [email protected] or [email protected]. Electronic mail may be sent via satellite or via HF radio, depending on the ship's equipment and arrangements with communications providers ashore. AMVER messages can also be combined with the National Oceanic and Atmospheric Administration (NOAA) weather reports. This system became functional in November 1998 under a cooperative agreement between NOAA and the U.S. Coast Guard. AMVER/SEAS software was developed for submitting both AMVER and weather reports. A ship can reduce reporting requirements since AMVER position reports are created from each weather message and automatically forwarded to the U.S. Coast Guard. Typically, NOAA weather reports are sent from ships at sea every six hours, whereas AMVER reports are sent every 48 hours. The e-mail path on shore to the AMVER center is at no-cost, but the communications service provider may still charge from ship-to-shore.

4. Efforts to Identify Duplication

MARAD and USCG do not maintain duplicate systems, as MARAD is a user of the USCG system. The Department of Defense’s (DOD’s) Office of Naval Intelligence (ONI) and certain law enforcement agencies also operate a classified locator system for military intelligence and drug enforcement purposes, which cannot be used for AMVER purposes.

5. Impacts on Small Businesses or Other Small Entities

This collection has no impact on small businesses or other small entities.

6. Impact of Not Conducting or Less Frequent Collection of Information

The continuous movement of ships at sea makes collection of positions any less frequently than every 48 hours impractical for maintaining the timely plots required for search and rescue and national security.

7. Special Circumstances Relating to the Guidelines 5 CFR 1320.5

With the exception of the 48-hour reporting requirement applicable to the first item, there are no special circumstances that require the collection of information to be conducted in a manner described below:

• Requiring respondents to prepare a written response in fewer than 30 days after receipt of a collection instrument;

• Requiring respondents to submit more than one original copy of any document;

• Requiring respondents to retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;

• Requiring the use of any statistical data that is not designed to produce valid and reliable results that can be generalized to the universe of study;

• Requiring the use of a statistical data classification that has not been reviewed and approved by OMB;

• Requiring any pledge of confidentiality; or

• Requiring respondents to submit any proprietary or trade secrets.

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 2024-20679, Vol 88, No. 177) on September 12, 2024, indicating comments should be submitted on or before November 12, 2024. No comments were received. A 30-day notice will now be published in the Federal Register to solicit public comments.

In carrying out their responsibilities, MARAD and USCG⁴ maintain continuous contact with U.S.-flag shipping companies and industry groups relative to AMVER and have been responsive to suggestions and improvements. The USCG cooperates with other national and international agencies concerned with search and rescue, such as the National Search and Rescue Committee (NSARC), as well as with foreign governments.

9. Explanation of Any Payment or Gift to Respondents

No payments or gifts^[5] are provided to respondents.

10. Assurance of confidentiality and Protection of Privacy

Per the Commandant Instruction 16122.2, information collected under AMVER will be released only to recognized SAR authorities during an emergency.

Per 46 CFR Part 307, ship location information from AMVER is used by MARAD only with proper safeguards, and when used jointly with the DOD may be classified at Confidential or higher levels during military exercises or actual national security situations.

11. Justification for Sensitive Questions

There are no questions of a sensitive nature.

12. Estimate of Annualized Burden Hours and Cost

1. Estimated Annualized Burden Hours

An estimated combined total 185 U.S-flag and other U.S. citizen-owned vessel owners/operators will each respond 183 times to this collection annually, for a total 33,855 responses. Each respondent will take approximately .07 hours (i.e. 4 minutes and 12 second) to complete each response for a total 2,370 hours, which can be calculated as shown in the table below:

Total Respondents		Total Responses per Respondent		Total Responses		Average Time Taken to Respond (Hour)		Total Burden Hours
185	*	183	=	33,855	*	0.07	=	2,369.85/2,370

2. Estimated Annualized Cost Burden

The Bureau of Labor and Statistics (BLS)⁶ estimates that the average hourly wage for Ship and Boat Captains and Operators (53-5021) is $47.03. When combined with the total compensation rate ⁷of 29%, the total annualized hourly rate is $60.67. Therefore, the estimated annualized cost burden to respondents to prepare and submit responses to this collection is $ 143,787.90, which can be calculated as shown in the table below:



Title and Code of Respondents	Hourly Wage	Compensation Rate of 29%	Number of Employees	Total Compensation Rate for Each Respondent	Total Annualized Burden Hours	Total Annualized Cost Burden
Ship and Boat Captains and Operators (53-5020)	$ 45.42	$ 58.59	1	$ 58.59	2,370	$ 138,858.30



There is no cost for radio equipment as this is the same as required by the Federal Communication Commission (FCC), USCG and International Maritime Organization (IMO) maritime regulations.

There are no other overhead or administrative expenses known to be incurred by respondents.

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

There are no capital, start-up, operations, or maintenance costs to respondents and/or record keepers associated with this information collection.

14. Estimates of Federal Government Costs

The total annual cost to the Federal Government for processing the collection is estimated as follows:

One-time Costs: None

Annual Costs: The estimated annual cost for the U.S. Coast Guard for AMVER is about $2.5 million. MARAD does not finance or operate the AMVER system and incurs no costs in its administration.

15. Explanation of Program Changes or Adjustments

Since the last renewal, the total number of U.S.-flag ships and other U.S. citizen-owned vessel owners/operators reporting to MARAD increased from 171 to 185. Consequently, the total responses and burden hours rose from 31,293 to 33,855 and from 2,190 hours to 2,370 hours respectively.

16. Publication of Data Collection Results

Information collected will not be published.

17. Display of the OMB Expiration Date.

MARAD is not seeking approval to avoid displaying the OMB expiration date.

18. Exception to the Certification Statement

There are no exceptions to the certificate statement.

1 This Information Collection Request (ICR) Supporting Statement (SS) represents a combine collection for MARAD and CG related to AMVER. The MARAD AMVER ICR is mandatory, while the CG AMVER ICR is voluntary. Where the SS language relates to both elements of the ICR, the section begins with MARAD/CG. Where the SS language relates to only one Agency’s input, the paragraphs within a section are broken into separate MARAD and CG elements

2 Available at— http://www.gpo.gov/fdsys/pkg/CFR-2009-title46-vol8/pdf/CFR-2009-title46-vol8-chapII-subchapF.pdf.

3 Per the 2016 AMVER business report: http://www.amver.com/reports.asp.

4 To enhance AMVER outreach, the CG maintains an AMVER-related Web site and an AMVER Maritime Relations Office: www.amver.com.

5 While no gifts are provided to AMVER participates, the CG has an AMVER Awards Program to recognize those vessels which regularly participate in the AMVER system, and those vessels/crews that have participated in rescues: http://www.amver.com/awardsprogram.asp

6 The hourly wage estimate is taken from current BLS tables: https://www.bls.gov/oes/current/oes535021.htm

7 Per BLS Employee Compensation Memo, the total compensation rate for the private sector is 29%, :https://www.bls.gov/news.release/pdf/ecec.pdf

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