Information Collection 2133-0032 SS 2008

SUPPORTING STATEMENT FOR
PAPERWORK REDUCTION ACT SUBMISSION UNDER 5 CFR PART 1320
Information Collection: 2133-0032

Justification
1.
Explain the circumstances that make 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 Construction Reserve Fund (CRF) is a tax deferred ship construction fund authorized by 46
USC Chapter 533. The CRF is available to all citizens of the United States. Applications are
required only from citizens desiring to obtain benefits under the CRF program. Annual
statements are required from account holders to assure that the requirements of the program are
being satisfied. The CRF program supports the Department of Transportation’s strategic goal of
promoting trade and economic growth.
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.
Shipowners or operators who desire to obtain benefits of the CRF program must submit an
application for those benefits. The information provided in the application will be utilized by the
Maritime Administration (MARAD) to determine if an applicant qualifies for the benefits. The
annual statement is used by MARAD to assure that account holders are satisfying the
requirements of the program.
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. Also describe any consideration of using information technology to
reduce burden.
We will accept information, with appropriate authentications, that the respondent wishes to send
electronically.
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 item 2 above.
The CRF program is unique to MARAD and no other agency or organization has a similar or
related program.
5.
If the collection of information impacts small businesses or other small entities, describe
the methods used to minimize burden.

The collection of information may be from small shipping companies. Timely information is
requested when a shipowner or operator desires to obtain benefits of the CRF program. There is
no requirement for any shipowner or operator to submit any information if they do not desire the
CRF benefits. However, a company that is party to a CRF agreement must submit an annual
statement setting forth the detailed analysis of the status of the CRF fund when each income tax
return is filed. The only other requirement a party to a CRF agreement has is that when they
wish to withdraw monies from the fund, they send a check to the Maritime Administration where
it is countersigned and returned to them. This minimizes the burden as much as possible, i.e.,
submitting the original application, annual statements, and checks only when money is to be
withdrawn.
6.
Describe the consequence to Federal program or policy activities of the collection is not
conducted or is conducted less frequently, as well as any technical or legal obstacles to reducing
burden.
Once a shipowner or operator has submitted an application and has been approved for a CRF
agreement, the only requirement is for the respondent to submit to MARAD a statement setting
forth a detailed analysis of the CRF fund when each income tax return is filed for a taxable year.
Since a CRF account is a joint account between the fundholder and the Maritime Administration,
the annual fund statement is required in order for MARAD to properly administer the program
and make sure at the time of countersigning a check that there is sufficient funds in the particular
CRF account to cover the withdrawal. The consequence to the Federal program or policy
activities if the statements were not collected annually would be the Maritime Administration’s
inability to properly administer the program
7.
Explain any special circumstances that would cause information collected to be
conducted in a manner:
•

requiring respondents to report information to the agency more often than quarterly;

•

requiring respondents to prepare a written response to a collection of information in
fewer than 30 days after receipt of it;

•

requiring respondents to submit more than an original and two copies 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;

•

in connection with statistical survey, that is not designed to produce valid and reliable
results that can be generalized to the universe of study;

•

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

•

that includes 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

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consistent with the pledge, or which unnecessarily impedes sharing data with other
agencies for compatible confidential use; or
•

requiring respondents to submit proprietary trade secret, or other confidential information
unless the agency can demonstrate that it has instituted procedures to protect the
information’s confidentiality to the extent permitted by law.

There are no special circumstances that require the collection of information in a manner
described above.
8.
If applicable, provide a copy and identify the date and page number of publication 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.
•

Describe efforts to consult with persons outside the agency to obtain their views on the
availability of data, frequency of collection, the clarity of instructions and record keeping,
disclosure, or reporting format (if any), and on the data elements to be recorded,
disclosed, or reported.

•

Consultation with representatives of those from whom information is to be obtained or
those who must compile records should occur at least once every three years -even if the
collection of information activity is the same as in prior periods. There may be
circumstances that may preclude consultation in a specific situation. These circumstances
should be explained.

The Maritime Administration published a 60-day notice and request for comments on this
information collection in the Federal Register (73 FR 15256) on March 21, 2008, indicating
comments should be submitted by May 20, 2008. No comments were received.
In addition, a Maritime Administration staff member communicates with respondents regarding
the basis and reporting consistency of the information submitted. Since the CRF program is
unique to MARAD, no consultation outside the agency other than with respective depositories is
required.
9.
Explain any decision to provide any payment or gift to respondents, other than
remuneration of contractors or grantees.
No payments or gifts are provided to respondents.
10.
Describe any assurance of confidentiality provided to respondents and the basis for the
assurance in statute, regulation, or agency policy.
The information requested is not of a confidential nature and, consequently, no assurance of
confidentiality need be given.

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11.
Provide additional justification for any questions of a sensitive nature, such as sexual
behavior and 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.
Not applicable. There are no questions of a sensitive nature.
12.

Provide estimates of the hour burden of the collection of information. The statement
should:
• Indicate the number of respondents, frequency of response, annual hour burden, and an
explanation of how the burden was estimated. Unless directed to do so, agencies should
not conduct special surveys to obtain information on which to base hour burden
estimates. Consultation with a sample (fewer than 10) of potential respondents is
desirable. If the hour burden on respondents is expected to vary widely because of
differences in activity, size, or complexity, show the range of estimated burden and
explain the reasons for the variance. Generally, estimates should not include burden
hours for customary and usual business practices.
• If this request for approval covers more than one form, provide separate hour burden
estimates for each form and aggregate the hour burdens in item 13 of OMB Form 83-I.
• Provide estimates of annualized cost to respondents for the hour burdens for collections
of information, identifying and using appropriate wage rate categories. The cost of
contracting out or paying outside parties for information collection activities should not
be included here. Instead, this cost should be included in item 14.

It is estimated that 17 respondents will require nine hours per response (or a total of 153 hours)
to prepare the application.
Responses
Per
Respondent

Number of
Respondents
17

x

1

Total
Responses
Annuallv
=

17

Hours
Per
Response
x

9

Total
Hours
Annually
=

153

It is estimated that an employee in each of six separate areas spends nine hours of their time
collecting and assimilating the information submitted with each application. Therefore, given an
average salary of $225 per hour for each of the employees, the cost per application to the
respondent is estimated as follows:

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Number of
Employees
6

Hourly
Wage
x

$225

Total
Cost Per
Response

Project
Time
x

9 hours

=

Number of
Total
Respondents Cost

$12,150 x

17

= $206,550

1 Accountant, Auditor or Bookkeeper
1 Professional and Technical Worker
1 Clerical Worker
1 Manager/Administrator
1 Lawyer
1 Service Worker
It is estimated that an accountant, auditor or bookkeeper will spend one hour of their time
collecting and assimilating information for the annual statement. Therefore, the estimated cost to
respondents for annual statements is:

Number of
Respondents
17
x

Responses
per
Respondent
1
x

Cost
per
Hour
225
x

Hours
per
Response
1

Total Annualized Costs to the respondent is as follows:

=

Total
Cost
Annually
$3,825

$210,375

13.
Provide an estimate of the total annual cost burden to respondents or recordkeepers
resulting from the collection of information. (Do not include the cost of any hour burden shown
in items 12 and 14).
•

The cost estimate should be split into two components: (a) a total capital and start-up cost
component (annualized over its expected useful life); and (b) a total operation and
maintenance and purchase of services component. The estimates should take into
account costs associated with generating, maintaining and disclosing or providing the
information. Include descriptions of methods used to estimate major cost factors
including system and technology acquisition, expected useful life of capital equipment,
the discount rate(s), and the time period over which costs will be incurred. Capital and
start-up costs include, among other items, preparations for collecting information such as
purchasing computers and software; monitoring, sampling, drilling and testing
equipment; and record storage facilities.

•

If cost estimates are expected to vary widely, agencies should present ranges of cost
burdens and explain the reasons for the variance. The cost of purchasing or contracting
out information collection services should be a part of this cost burden estimate. In
developing cost burden estimates, agencies may consult with a sample of
respondents(fewer than 10), utilize the 60-day pre-OMB submission public comment

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process and use existing economic or regulatory impact analysis associated with the
rulemaking containing the information collection, as appropriate.
•

Generally, estimates should not include purchases of equipment or services, or portions
thereof, made: (1) prior to October 1, 1995, (2) to achieve regulatory compliance with
requirements not associated with the information collection, (3) for reasons other than to
provide information or keep records for the government, or (4) as part of customary and
usual business or private practices.

The estimated annual cost burden to the respondents is as follows:
(a)
Total Capital and Start-Up Costs Estimate: There are no capital or start-up costs
associated with this information collection.
(b)
Total Operation and Maintenance and Purchase of Services Estimate: There are no
maintenance costs.
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. Agencies also
may aggregate cost estimates from items 12, 13, and 14 in a single table.
The total annual cost to the Federal Government for processing the collection is estimated as
follows:
Cost of Application: $3,922
It is estimated that 10 employees in various areas of the Maritime Administration spend four
hours of their time collecting and assimilating information submitted with each application.
Therefore, given an average GS-14 salary of $53 per hour for each of the employees and an
overhead cost of 85 percent of the salary, the cost to the Government is estimated as follows:
Number of
Employees

Hourly
Wage

10
x
$53
Overhead at 85%
Sub-total

Project
Time
x

Cost of Annual Statement:

4 hours

Cost Per
Application
=
=
=

$2,120
$1,802
$3,922

$833.42

It is estimated that one employee receives the annual statement, enters the amount into the
ledger, and files the statement. Time required for these tasks is 30 minutes and the hourly rate is
$53.

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Number of
Employees

Hourly
Wage

1
x
$53
x
Overhead at 85%
Sub-total
Times 17 responses per year
Cost of Checks:

Project
Time

Cost Per
Application

.5 hours =
=
=
=

$26.50
$22.52
$49.02
$833.42

$550.12

It is estimated that one employee receives the check in the mail, verifies the amount in the
account, gives the check to the signing official, receives back the signed check, and mails the
check to the respondent. Time required for these tasks is 20 minutes at an hourly rate of $53.

Number of
Employees

Hourly
Wage

Project
Time

Cost Per
Application

1
x
$53
x .33 hours
=
Overhead at 85%
=
Sub-total
=
Times 17 checks (1 per respondent annually) =

$17.49
$14.87
$32.36
$550.06

Maximum Total Annual Cost to Federal Government: $5,305.48
15.
Explain the reasons for any program changes or adjustments reported in items 13 or 14 of
OMB Form 83-1.
There were no changes in the burden hour estimate.
16.
For collections of information whose results are planned to be published for statistical
use, outline plans for tabulation, statistical analysis, and publication. 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.
There are no plans to publish the results of the information collection.
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.
Not applicable.
18.
Explain each exception to the certification statement identified in Item 19, "Certification
for Paperwork Reduction Act Submissions," of OMB Form 83-1.
Not applicable. There are no exceptions to the certificate statement.

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